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Code advisory group debates scrapping minimum unit area, narrowing kitchen clearances
Summary
The Washington State Building Code Council technical advisory group debated removing a 190-square-foot minimum dwelling-unit area in favor of component-based requirements and whether to reduce kitchen clearances from 36 to 30 inches; members split and no formal action was taken due to lack of quorum.
Members of the Washington State Building Code Council technical advisory group met virtually on Dec. 11, 2025, and spent the bulk of a work session debating how to define minimum dwelling-unit requirements for small or efficiency units. The discussion centered on whether to eliminate a 190-square-foot minimum area and instead require specific components (a habitable sleeping space, a 120-square-foot habitable room, a bathroom, and minimum fixture and clearances), and whether clear working space in front of kitchen appliances could be narrowed from 36 inches to 30 inches.
The proposal to drop the overall area minimum and require component elements was put forward by Micah, who argued that “if we define what a minimum dwelling unit has to include… why do we even need a minimum dwelling unit size?” He said architects could meet component requirements (minimum room dimensions, plumbing fixture clearances) without an arbitrary total-area threshold. Micah also presented draft language that would align some building-code provisions with residential-code language being considered through the State Building Code Council (SBCC) process.
Opponents cautioned that reducing clearances could create future problems. Hoyt and other members said keeping a 36-inch passageway provides circulation and reduces the chance of discovering later that a change was too small once built. “I think 3 feet is correct,” Hoyt said, urging caution about reducing dimensions before widespread real-world experience. An architect on the call noted that a 36-inch clearance alone does not satisfy accessibility requirements, stressing that accessibility and minimum working clearances are governed by different code sections.
Staff and other members discussed technical relationships to existing code provisions: Dustin pointed out that a 30-inch clearance aligns with minimum working clearances elsewhere in the code, while Michael noted the IBC clear opening width for doors (IBC 1010.1) requires a 32-inch minimum clear opening. Members repeatedly emphasized distinguishing circulation/working clearances from accessibility and means-of-egress requirements, which remain governed by separate sections.
Members also urged retaining the enumerated components now present in the efficiency-dwelling-unit section (kitchen and sanitation bullets, fixture requirements, closet and water‑closet/lavatory/shower references) even if the group removes minimum-area language, noting those bullets may not exist elsewhere in the code and should not be lost in restructuring.
No formal vote was taken on any change during the Dec. 11 session because the advisory group lacked a quorum; the discussion was recorded as a work session. Members agreed as homework to draft proposed code language reflecting the directions heard—whether that is removing 12.0.8.3 (the minimum-area provision), retaining the efficiency-unit bullets elsewhere, or adopting component-based language—and share drafts before upcoming meetings. Staff noted related work on Dec. 18 (temporary emergency shelters) and that dwelling-unit topics will likely resume in January.
Next steps: members will circulate draft language based on today’s discussion; the group plans to continue the topic in a future meeting where it may present recommendations to the council for formal consideration.
