Proposed OSHPD 3 changes: fewer small-clinic toilets, no med-prep sink

Here's a thing that trips up small-clinic tenant improvements: a three-exam-room physical therapy clinic can't share its patient toilet with the waiting room today. A primary care clinic that size can. Same footprint, same code chapter — different answer, because of two words.

Every licensed clinic in California is an OSHPD 3 occupancy, and OSHPD 3 is enforced by your local building department, not HCAI. Layout and fixture count on these suites run off CBC Section 1226 and California Plumbing Code Section 422.3.1. HCAI's final express terms for the 2025 Intervening Code Cycle change three of the rules that drive those small-suite plans.

One caution first: none of this is law yet. These terms went to the Building Standards Commission at its August 25–27, 2026 meeting in the GREEN (uncontested) set, with the advisory committee recommending Approve and the agency Accept. A proposal can still be approved, disapproved, or sent back, so verify the recorded vote before you rely on it. If approved, it publishes as a supplement to the 2025 code and takes effect July 1, 2027.

1. The small-clinic patient toilet can serve the waiting room

Today, both CBC 1226.4.14.1 and CPC 422.3.1, Exception 1 give the patient-toilet-serves-waiting relief to one clinic type only:

Verified against the current 2025 CPC §422.3.1, Exception 1: "For Primary Care Clinics where a facility contains no more than three examination and/or treatment rooms, the patient toilet shall be permitted to serve waiting areas." CBC §1226.4.14.1 carries the matching "primary care clinics" limit.

The express terms strike "primary care." The exception becomes available to any Section 1226 clinic with three or fewer examination and/or treatment rooms — rehabilitation (think PT), psychology, chronic dialysis, alternative birthing, and the rest. For a small behavioral-health or PT suite, that's one fewer plumbing fixture to find room for.

2. An all-gender staff restroom, if staff occupant load is 10 or less

The separate-sex rule in CPC 422.2 carries a banner today: its exceptions are "[Not adopted for OSHPD 1, 2, 3, 4 & 5]." So an OSHPD 3 clinic can't lean on the usual single-unisex-toilet exceptions, and staff toilets end up split into men's and women's.

The express terms repeal that banner and add a new Exception 5: "[OSHPD 1, 2, 3, 4 & 5] For staff occupant load of 10 or less, one toilet facility shall be permitted to be used by both sexes." The same exception keeps the guardrail that already lives in 422.3.1: toilet facilities shall not be shared between patients, staff and visitors.

Two things to read carefully. Exception 2 stays not-adopted for OSHPD — the terms add a banner saying exactly that. And the waiting-area single-user all-gender allowance moves to a new Exception 6 (relocated from 422.3.1). The staff all-gender relief is specifically Exception 5 — don't reach for the general business-occupancy exception, because a clinic still owes patients, staff, and visitors separate facilities.

3. The medication-prep sink comes off the required list

CBC 1226.4.13.2.1 lists what a medication preparation room or area must contain. Today that list includes a sink. The express terms repeal "Sink" and renumber what's left:

• Work counter
• Lockable refrigerator
• Immediate access to a handwashing station
• Locked storage for biologicals and drugs

A handwashing station is still required nearby — you're losing the dedicated prep sink, not hand hygiene.

Two more that touch layout

• Contiguity (1226.4.3.5). The old line — "Basic services of a single licensed clinic may be located in separate suites" — is deleted. The rewrite says general support spaces may sit in separate suites, while each clinic suite must be contiguous with internal circulation to its required functions. If you're splitting clinical services across suites, re-check this one.
• Toilet-room doors (1226.4.4.1). The door rule is narrowed to patient toilets and single-occupant toilet rooms in the waiting area — not every toilet in the suite.

Table 4-2 in the Plumbing Code also picks up clinic rows in the same package.

The Monday-morning move

If this adopts as written, an architect laying out a two- or three-exam-room PT or behavioral-health clinic can plan one patient/waiting toilet and one all-gender staff toilet (where the staff occupant load is 10 or less) instead of separate men's and women's staff rooms — and delete the med-prep sink. Plan checkers: update the clinic TI checklist so a small non–primary-care clinic isn't red-lined for sharing its patient toilet. None of this is law yet, and none of it is legal advice — confirm the current requirement and effective date with your local building department before you redraw a plan.

What CrossBeam does with it

CrossBeam reads a clinic TI's room list and fixture plan, works out how many toilets Section 1226 and CPC 422 actually require for that suite, and flags a layout still carrying separate-sex staff rooms or a med-prep sink the code no longer asks for. You get the right fixture count for the clinic in front of you — and the date each rule starts to apply — without cross-referencing three code sections by hand.