New AS 1428.1 (2021) Requirement for the Toilet Paper Zone
This accessible toilet at a regional rest stop has the most toilet paper dispensers we’ve encountered to date.
Image copyright Realm Access 2025.
This article discusses:
AS 1428.1 (2021)’s new requirement for the toilet paper zone;
The intent behind the location of the zone; and
Whether echidna-shaped toilet paper roll holders are capable of compliance (yes, you read that right).
Can providing too much toilet paper be a non-compliance?
In short – yes, when it comes to accessible sanitary facilities.
One of the most common non-compliances you see when undertaking access audits of accessible sanitary facilities is the provision of oversized toilet paper dispensers that don’t provide the toilet paper outlet within the required zone. It’s also common to see toilet paper dispensers that were originally located in a compliant location removed and replaced with oversized toilet paper dispensers installed in non-compliant locations.
It’s perfectly understandable why asset owners, facility managers and maintenance teams would want to install oversized toilet paper dispensers or multiple toilet paper dispensers. We recently saw a photo of a sign in a US National Park amenities building that warned visitors: “Bathroom supplies may not be available here. Please check the roll before you commit.” Enough said.
Even so, locating toilet paper outside the zone prescribed by AS 1428.1 can have serious implications for safety and usability.
AS 1428.1 (2021)’s new requirement for the toilet paper zone
Clause 12.2.6 and Figure 41 of AS 1428.1 (2021) prescribe the required zone for the outlet for toilet paper dispensers within accessible sanitary facilities. The outlet must be:
within 300 mm of the front of the toilet pan;
above the line of the top of the toilet seat; and
no higher than 700 mm above the floor level.
The dispenser itself must not encroach into the minimum 50 mm clearance below the grabrail required by Clause 14.
The above requirements are unchanged from the 2009 edition of AS 1428.1, however the 2021 edition, which is now referenced by the NCC / BCA and the Premises Standards, introduces a new requirement:
The toilet roll must not have a projection from the wall of more than 150 mm.
Setout requirements for the zone for the position of toilet paper in accessible sanitary facilities as per AS 1428.1 (2021).
Image copyright Realm Access 2025.
The intent behind the location of the toilet paper zone
Many people who need to use an accessible toilet have limited mobility and strength, especially core strength, and may have issues with balance and dexterity. Locating the toilet paper close to the pan ensures people can comfortably and safely reach it.
Research undertaken by the University of Technology Sydney (UTS) Disability Research Network on accessible public toilets showed there is a high level of dissatisfaction with inappropriate placement of key access features among the surveyed users (read more here). One of the issues highlighted was that if a toilet paper dispenser is not close enough to the pan, people have to plan ahead and take enough toilet paper from the dispenser before they transfer onto the pan.
This isn’t just an inconvenience: the appropriate placement of toilet paper is crucial for safety. If a toilet paper dispenser is mounted too far forward of the pan, or too low to the ground, there is the very real risk of people becoming unstable and falling off the toilet as they lean forward or down to try to reach the paper.
The prescribed location of the toilet paper and requirement to ensure it does not project too far from the wall is also intended to minimise the risk of it encroaching into clearances around the toilet pan. The way people transfer from their wheelchairs onto the pan can vary greatly, and it’s estimated that approximately 20% of people transfer from a frontal position. People may also use an accessible toilet by straddling the pan and facing the cistern or rear wall. Hence, it’s important to ensure that sufficient space for people’s knees and legs is provided between the pan and the wall without encroachments.
Similarly, clearances must be maintained below and above grabrails so people can safely and comfortably reach and use them. Clause 14 of AS 1428.1 (2021) requires minimum clearances to grabrails of:
50 mm below horizontal and angled sections (except at fixing points); and
600 mm above the horizontal sections.
The location of this toilet paper dispenser significantly impacts useability of this grabrail. How would you be able to grab the top of the vertical section to help lower yourself down onto, or pull yourself off the pan? Note also the holes in the wall below the grabrail indicate there was once a toilet paper dispenser in a compliant location.
Image copyright Realm Access 2025.
Are echidna-shaped toilet paper dispensers capable of compliance?
It’s very rare to say that you’ve had a delightful surprise upon walking into a toilet cubicle, but that was our experience recently when visiting a restaurant in Montville in the Sunshine Coast hinterland. The restaurant’s toilets feature a toilet paper roll holder carved in the shape of an echidna. Although we were not there in our capacity as access consultants and did not have a measuring tape, it definitely warranted a photo and made us wonder whether it was capable of compliance. Our verdict based on eyeballing it: maybe… but probably not. With a fresh toilet roll, the toilet paper looks like it might project more than 150mm from the wall.
Echidna-shaped toilet paper holder by Sunshine Coast artist, Jack Wilms.
Image copyright Realm Access.
Posted 30th September 2025.