It doesn’t take long working in medical facilities to encounter the problem in defining differences between exam rooms, diagnostic rooms, and treatment rooms. It is important to know the differences because the 2013 CBC has different accessibility requirements that apply to the required clearances for each of these. This applies to all types of medical facilities, whether under the jurisdiction of OSHPD (hospitals and skilled nursing), local AHJ’s (clinics and medical office buildings) or self-certified facilities (correctional medical facilities, State-owned medical facilities).

Unfortunately, the building code doesn’t clearly define these three different types of rooms, and yet has different requirements for each, which is what makes this issue less than ‘black-and-white’.

Different Accessibility Code Requirements

Section 805.4.1 of the 2013 CBC reads as shown below:

  • 11B-805.4.1 Beds, Exam Tables, Procedure Tables, Gurneys and Lounge Chairs. A 36 inch (914 mm) minimum wide clear space shall be provided along the full length of each side of beds, exam tables, procedure tables, gurneys and lounge chairs.
  • EXCEPTION: <span style="=&quot;text-decoration:" underline;"="">General exam rooms in non-emergency settings may provide clear space on only one side of beds, gurneys and exam tables.

Also, new amendments to the 2013 CBC which are to be effective as of July 1, 2015 include additional text in the ‘OSHPD’ code sections of 1224 that will affect us in application of access requirements, see below:

“1224.4.4.1 Examination and treatment rooms.

1224. Examination room.Unless specified elsewhere, if an examination room is provided, it shall have a minimum clear floor area of 80 square feet, the least dimension of which shall be 8 feet. The room shall contain a handwashing fixture and accommodations for written or electronic documentation shall be provided.

1224. Treatment room. Unless specified elsewhere, if an examination room is provided, it shall have a minimum clear floor area of 120 square feet, the least dimension of which shall be 10 feet. A minimum of 3 feet is required between the sides and foot of the bed/gurney/table and any fixed wall or obstruction. The room shall contain an examination light, work counter for medical equipment, a handwashing fixture, cabinets, medication storage, and counter space for writing or electronic documentation. Multi-bed treatment rooms shall have separate patient cubicles with a minimum clear floor area of 80 square feet. Each cubicle shall contain an examination light, counter and storage facilities. In multi-bed treatment rooms, a hand washing fixture shall be provided in the room for each three or fewer cubicles.”

While this code section obviously addresses issues outside of accessibility, OSHPD has already identified a particular portion of these code amendments in their accessibility interpretation document Code Application Notice 2-11B which notes on page 17 that treatment rooms will be required to have accessible writing surfaces.

In brief summary, there are a few, but important differences between these three types of rooms that make accessibility code application in medical facilities a bit tricky:

  1. ‘Examination, treatment and diagnostic rooms: Are required to have a 36” clear aisle along the full length of both sides of the bed, table, gurney or lounge chair.
  2. ‘General’ exam rooms: (that are in a non-emergency setting) are allowed to have the clear aisle on only one side. The question of what is a ‘general’ exam room is discussed below.
  3. Examination and treatment rooms:Will be required to have accessible writing surfaces starting July 1, 2015. Diagnostic rooms will not be required to provide this.

Accessibility for Staff

The deeper that one gets into the specific application of the 2013 CBC to medical facilities; the more important it is to understand the OSHPD mindset when they developed the text of 11B-805. In multiple discussions with OSHPD code-writing staff regarding 11B-805 it has been made very clear that OSHPD is specifically requiring accessibility for staff. On multiple occasions OSHPD has noted that the specific choice of words and clearances is intended to give disabled staff access to a patient at pretty much all locations. Thus they have used the term ‘along the full length’ at exam tables to allow disabled staff to get access up around a patients head and shoulder area. While all may not agree that this is appropriate, it is important to understand the code-writer’s intent and mind-set.


Unfortunately, the code isn’t crystal-clear in defining these three types of rooms, and the nuances between them. The good news is that in practical terms, the definitions are almost intuitive.


The 2013 CBC has a definition in Section 1224.3:

“A room with a bed, stretcher, or examination table and capability for periodic monitoring (eg., measurement of blood pressure or pulse oximetry) in which procedures that do not require a specialized suite can be performed (eg., pelvic examination, blood transfusion).”

This generally equates to what we all experience when we visit our own doctor for a general examination. I like to apply the not-so-technical test: ‘If it looks like a duck, walks like a duck, and quakes like a duck; it is probably a duck”. Consequently, if a room looks and feels like an exam room, such as the ones that we all have experienced throughout our lives…it probably is an exam room.

‘General’ exam room: OSHPD has clarified in their CAN 2-11B on page 17 that a ‘general’ exam room is one that fits the definition of an ‘exam room’. Thus, a ‘general exam room’ is the same as an ‘exam room’. This leaves an open-ended assumption that there must then be some sort of exam room that is not classified as ‘general’.

Specialized exam rooms: This is where it gets less crystal clear. There are many rooms in which examinations occur that look and are labeled differently. For example:

  • Optometric Examination
  • Sonogram Room
  • Audiology testing
  • Mammography testing
  • Cardiology Stress Testing

In most cases, these rooms are not classified as ‘general exam rooms’. They typically fail the ‘walks like a duck’ test. Typically, they would be classified as diagnostic rooms, although there is admittedly, some room to argue that they are specialty examination’ rooms rather than diagnostic rooms.

Functional Application: When OSHPD encounters a difficult to classify room, they will frequently analyze the specific function of the room and equipment; and then determine the most logical code requirements. For example; in the case of the mammography exam room, the mammography testing machine is approached from the front. There is little point to requiring a clear aisle at the two sides of the equipment. However, OSHPD does consider the staff areas as requiring accessibility compliance, so they will ask where the staff will be operating the equipment from, and where the staff will need to be to properly assist the patient. They will then establish requirements for clear 36” aisles at those locations.


The 2013 CBC does not have a definition for treatment rooms. This creates somewhat of a dilemma when the required writing surface requirement is applied at ‘treatment’ rooms, but not in ‘diagnostic’ rooms.

OSHPD has a long-standing history of applying a non-technical, intuitive definition of ‘treatment’, as effectively cutting into a patient, or otherwise breaking through the skin. The exception to this is that needles ‘don’t count’ as ‘breaking the skin’.

Thus, a ‘treatment’ room is one that is designed for actually cutting into, or otherwise providing physical treatment of a patient.


Similarly, the 2013 CBC does not actually define ‘diagnostic room’, but OSHPD’s long-standing traditions of code application leaves us with a more intuitive application. Our dictionary understanding of the word ‘diagnostics’ pretty much matches the OSHPD application, and also matches our real-world usage of the term. These are rooms where medical staff use specialized equipment (such as an x-ray machine) to diagnose a patient’s medical condition.

Since, these rooms do not include rooms where we ‘break the skin’, they are left as those that are neither ‘treatment’ rooms, nor are classified as, ‘general exam’ rooms. Thus, we all pretty much categorize ‘diagnostic’ rooms the same way to include rooms such as:

  • X-Ray Room
  • CT Scan Room
  • CAT Scan Room
  • Sonogram Room
  • Pulmonary Function Testing Room

The difference between examination and diagnostics can be subtle, and maybe even debatable. I have found that the best clue to determine which category is the best fit is this:

  • Diagnostic Rooms have ‘Diagnostic Equipment’
  • Exam Rooms do not have ‘Diagnostic Equipment’

Therefore, an eye-examination room may have a piece of equipment that allows an optician to try a series of lenses, but we don’t usually refer to it as ‘diagnostic’ equipment. Therefore, I would classify it as an examination room, or more accurately, a ‘specialty’ examination room. This may not be a perfect and flawless method, but it works fairly well.


In terms of access-compliance in medical facilities, it is important to properly categorize rooms into these three categories. It is equally important to understand that the code-writer’s intent is to provide access for disabled medical staff, which is a significant departure from other accessibility code compliance.

Bill Zellmer is a California licensed architect and certified Access Specialist with over 30 years of professional experience in various capacities including:

  • Architect performing barrier removal work (2009-2012)
  • Accessibility field surveyor (2010-2014)
  • OSHPD Senior Architect (1995 – 2009)
  • Sutter Healthcare in-house accessibility expert (2014-2015)
Submitted by Bill Zellmer