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UBC 2406.4, Item 6 addresses tempered glass in bathrooms (2406 addresses tempered/safety glass in general). The requirement is that tempered glass be installed when the bottom of the glass panel is within 60 inches of the standing surface of a tub, shower, etc.

The AHJ will interpret this as any standing surface that they believe will be wet during normal use. You can get into lots of debates with the inspector if the window is in the bathroom, but off to the side of the tub/shower. The section specifically says "Glazing in doors and enclosures...any portion of a building wall enclosing these compartments." Where the debate will come in is whether the bathroom itself is the "enclosure" for the tub.

If you have tempered glass there is no debate, if you don't then there can be.

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Q: What UBC code states residential bathroom windows must have tempered glass?
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