From a practical viewpoint, most toilet flanges are a cone, so they flare out from the pipe. Thus, if the joist was right next to the pipe, you may not be able to slide the flange on while gluing it in place - at least you may not be able to slide it all the way in. Now, this is often more of an issue with a 3" pipe than a 4" pipe where you could use an internal flange.
Don't know if there's an actual code issue here, but more of a practical issue on what will fit.





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