36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

404 Doors, Doorways, and Gates

This section covers both doors, doorways, and gates that are manually operated (404.2) and those that are automated (404.3). Changes made to the requirements for manually operated doors:

• clarify coverage of gates and the application of this section to manual doors and doorways intended for user passage (404.2)

• clarify and modify maneuvering clearance requirements (404.2.4)

• modify requirements for doors and gates in series (404.2.6)

• clarify the height of door and gate hardware and add an exception for gates at pools, spas, and hot tubs (404.2.7)

• revise an exception for door and gate surface requirements (404.2.10, Exception 2) and add a new exception for existing doors and gates (Exception 4)

In the proposed rule, section 404 referenced doors and doorways. The original ADAAG included a provision for gates which were subject to all relevant specifications for doors and doorways. The final rule includes references to gates throughout section 404 so that they are equally covered, consistent with the intent of this section and with scoping provisions for doors, doorways, and gates in section 206.5. In addition, clarification has been added that the requirements for manual doors, doorways, and gates in section 404.2 apply to those "intended for user passage."

Comment. Commenters requested that the Board specifically address doors which do not provide user passage.

Response. Section 404, as all of Chapter 4, addresses accessible routes and components of such routes. Doors which do not provide user passage would not be considered part of an accessible route. However, doors not providing user passage, such as those at many types of closets and wall mounted cabinets, are subject to requirements for storage (811) and for operable parts (309) where they are required to be accessible.

Comment. Table 404.2.4.1 specifies maneuvering clearances for manual swinging doors and gates. At doors that provide a latch side approach, the minimum depth of this clearance is increased where a closer is provided because additional space is needed to counteract the force of closers while maneuvering through the door from either the push or the pull side. In the proposed rule, this additional depth (6 inches) was specified when both a closer and a latch are provided. Comments indicated that this requirement should apply based on the provision of a closer since the addition of a latch does not impact the need for additional maneuvering clearance.

Response. The specification in Table 404.2.4.1, footnote 4, has been revised to apply where a closer is provided at doors with latch side approaches. The reference to latches has been removed.

Section 404.2.4 addresses maneuvering clearances at manual doors, doorways, and gates. It includes tables that specify these clearances according to the type of door, doorway, or gate (swinging, sliding, folding, and doorways without doors or gates) and the approach (front, latch side, hinge side). Clearances are specified for the pull side and the push side in the case of swinging doors. The final rule includes clarification, which was partially contained in a previous footnote to Table 404.2.4.1, that maneuvering clearances "shall extend the full width of the doorway and the required latch side or hinge side clearance," consistent with corresponding figures.

Comment. The proposed rule exempted doors to hospital patient rooms that are at least 44 inches wide from the specifications for latch side clearances. This exception derives from the original ADAAG and was intended to apply to those types of patient rooms where patients are typically transported in and out by hospital staff. Commenters pointed out that this exception should be limited to acute care patient bedrooms, as in the original ADAAG. The 44 inch specification pertains to the clear opening width of doors intended to accommodate gurneys.

Response. The exception, located at section 404.2.4 in the final rule, remains generally applicable to entry doors serving hospital patient rooms. The 44 inch width criterion has been removed so that the exception may be applied without regard to the door width. The Board opted not to limit the application of this exception due to concerns about the impact on the standard design and size of patient rooms. Doors to patient rooms are often located close to adjacent interior walls in order to facilitate circulation and to enhance privacy. As a matter of design, practice, or code requirement, such doors are typically wider in order to accommodate beds and gurneys.

Comment. Section 404.2.5 addresses the height of thresholds. A maximum height of ½ inch is generally specified, although an exception permits a maximum height of ¾ inch at existing or altered thresholds that have a beveled edge on each side. Many comments opposed any threshold height above ½ inch. Conversely, a few comments urged that this exception be broadened to restore a similar allowance for exterior sliding doors.

Response. The Board has retained the ¾ inch height allowed for thresholds with a beveled edge on each side that are existing or altered because compliance with the ½ inch requirement can, in some cases, significantly increase alteration costs and necessitate replacement of door assemblies. An exception in original ADAAG that allowed a ¾ inch threshold at exterior sliding doors was removed in the proposed rule because products are available, including swinging doors, that meet the ½ inch maximum specified for all other doors. No changes to the criteria for thresholds have been made in the final rule.

Section 404.2.6 specifies the minimum separation between doors and gates in series (48 inches plus the width of doors or gates swinging into the space). The proposed rule, consistent with the original ADAAG, included a requirement that doors and gates in series swing either in the same direction or away from the space in between. The Board has removed this requirement for consistency with the ANSI A117.1 standard. The required separation between doors and gates in series and specifications for maneuvering clearances at doors will ensure sufficient space regardless of the door swing. The height of door and gate hardware (34 to 48 inches) is specified in section 404.2.7. In the final rule, the Board has clarified that this height pertains to the operable parts of hardware, consistent with the ANSI A117.1 standard.

In finalizing this rule and incorporating its guidelines for recreation facilities, the Board determined that the specified height for door and gate hardware conflicts with industry practice or safety standards for swimming pools which specify a higher range for the location of latches beyond the reach of young children. The Model Barrier Code for Residential Swimming Pools, Spas, and Hot Tubs (ANSI/NSPI−8 1996) permits latch releases for chain link or picket fence gates to be above 54 inches. The model safety standard does not apply this requirement to key locks, electronic openers, and integral openers which have a self-latching device that is also self-locking. To reconcile this conflict, the Board has added an exception in the final rule for barrier walls and fences protecting pools, spas, and hot tubs (404.2.7, Exception 2). Under this exception, a 54 inch maximum height is permitted for the operable parts of the latch release on self-latching devices. Although the final guidelines specify 48 inches as the maximum forward or side reach, the original ADAAG recognized a maximum of 54 inches for side reach. Consistent with the model safety standard, this exception is not permitted for self-locking devices operated by keys, electronic openers, or integral combination locks.

Comment. Section 404.2.7 also covers the operating characteristics and height of door and gate hardware. An exception is provided for "existing locks at existing glazed doors without stiles, existing overhead rolling doors or grilles, and similar existing doors or grilles that are designed with locks that are activated only at the top or bottom rail." The advisory committee had recommended a broader exception that would have permitted any location for locks used only for security purposes and not for normal operation. Several comments preferred the exception put forth by the advisory committee over the one proposed by the Board.

Response. The Board sought to limit the exception to existing doors or grilles because design solutions for accessible doors and gates are available in new construction. In addition, the Board felt that the advisory committee’s language concerning "locks used only for security purposes" could be construed as applying to any lock. No changes have been made to the exception.

Comment. Section 404.2.7 also covers the operating characteristics and height of door and gate hardware. An exception is provided for "existing locks at existing glazed doors without stiles, existing overhead rolling doors or grilles, and similar existing doors or grilles that are designed with locks that are activated only at the top or bottom rail." The advisory committee had recommended a broader exception that would have permitted any location for locks used only for security purposes and not for normal operation. Several comments preferred the exception put forth by the advisory committee over the one proposed by the Board.

Response. The Board sought to limit the exception to existing doors or grilles because design solutions for accessible doors and gates are available in new construction. In addition, the Board felt that the advisory committee’s language concerning "locks used only for security purposes" could be construed as applying to any lock. No changes have been made to the exception.

Comment. Section 404.2.9 addresses the opening force of doors and gates. The provisions are consistent with existing ADAAG specifications by requiring a maximum 5 pounds of force for sliding, folding, and interior hinged doors. Fire doors are required to have the minimum opening force permitted by the appropriate administrative authority. No maximum opening force was proposed for exterior hinged doors. Many comments urged the Board to address exterior hinged doors, with a majority proposing a maximum of 8.5 pounds of force. Where this maximum cannot be met, the door should be required to be automatic or power-assisted, according to these comments. Some commenters felt that automatic doors should be made mandatory regardless of the opening force of manual hinged doors.

Response. Historically, the Board has not specified a maximum opening force for exterior hinged doors to avoid conflicts with model building codes. The closing force required by building codes usually exceeds 5 pounds, the maximum considered to be accessible. Factors that affect closing force include the weight of the door, wind and other exterior conditions, gasketing, air pressure, heating, ventilation, and air conditioning (HVAC) systems, and energy conservation, among others. Research previously sponsored by the Board indicates that a force of 15 pounds is probably the most practicable as a specified maximum. Considering that closing force is 60% efficient, a 15 pound maximum for opening force may be sufficient for closure and positive latching of most doors, but is triple the recognized maximum for accessibility. A maximum opening force for exterior hinged doors has not been included in the final rule.

Section 404.2.10 requires that swinging doors and gates have a smooth surface on the push side that extends their full width. This provision derives from the ANSI A117.1‒1992 standard and is intended to permit wheelchair footrests to be used in pushing open doors without risking entrapment on the stile. This provision requires that parts creating joints in the smooth surface are to be within 1/16 inch of the same plane as the other. Also, cavities created by added kick plates must be capped. Exceptions from this requirement are recognized for sliding doors (Exception 1), certain tempered glass doors without stiles (Exception 2), doors and gates that do not extend to within 10 inches of the floor or ground (Exception 3), and existing doors and gates (Exception 4).

Comment. Exception 2 exempts tempered glass doors without stiles that have a bottom rail or shoe with the top leading edge tapered at 60 degrees minimum from the horizontal. Comments indicated that these types of doors should be exempt from the requirement for the smooth surface area on the push side, but should be subject to other portions of the provision covering surface joints and added kick plates.

Response. In the final rule, section 404.2.10, Exception 2 has been revised to exempt the type of tempered glass doors described only from the requirement for a smooth surface on the push side that extends the full width of the door. Such doors remain subject to specifications for parts creating joints in the surface and for provided kick plates.

In finalizing the rule, the Board determined that the cost of making existing doors or gates comply with the smooth surface requirement in alterations can be significant. An exception from this requirement for existing doors and gates is provided in the final rule (404.2.9, Exception 4). Under this exception, such doors or gates do not have to comply with the surface requirements, provided that cavities created by added kick plates are capped.

Section 404.3 addresses automatic doors and gates, including those that are full-powered, low-energy, and power-assisted. In addition to the provisions of section 404.3, such doors are subject to industry standards (ANSI/BHMA 156.10 and 156.19). The reference to these standards in section 105.2 has been updated in the final rule to refer to the most recent editions: ANSI/BHMA A156.10‒1999 Power- Operated Pedestrian Doors and the 1997 or 2002 editions of ANSI/BHMA A156.19 Power-Assist and Low-Energy Power-Operated Doors. The Board’s website at www.access-board.gov provides further information on these referenced standards. Provisions in section 404.3 address clear width; maneuvering clearance; thresholds; doors and gates in series; operable parts; break out opening; and revolving doors, gates, and turnstiles.

Changes made to this section include:

• removal of unnecessary language from the charging statement (404.3)

• modification of maneuvering clearance specifications (404.3.2)

• removal of requirements for door labels and warnings (404.3.6 in the proposed rule)

• revision of specifications for break out opening (404.3.6)

• addition of a provision for revolving doors, gates, and turnstiles (404.3.7)

Comment. In the proposed rule, section 404.3 noted that "[a]utomatic doors shall be permitted on an accessible route." Commenters indicated that this language was unnecessary since any type of door complying with section 404 may be on an accessible route (404.1).

Response. The statement permitting automatic doors on accessible routes in section 404.3 has been removed.

In the proposed rule, section 404.3.2 required that maneuvering clearances specified for swinging doors be provided at power-assisted doors and gates since their activation, unlike those that are fully automated, involves manual operation. In the final rule, this provision has been revised to also apply to automatic doors and gates not equipped with standby power that are part of an accessible means of egress. In cases of building power failure, this will help provide access where manual operation of the door or gate is required, unless the opening device has its own back-up power supply. A new exception exempts those automatic doors or gates that remain open in the power-off condition since manual operation is not necessary during power outages.

The proposed rule included a requirement that labels and warning signs for automatic doors meet requirements in section 703.4 for non-tactile signage (404.3.6). The Board has removed this requirement in the final rule since the referenced industry standards address the characteristics of these signs and labels.

Comment. In the proposed rule, the Board included a requirement that the clear break out opening for swinging or sliding automatic doors be at least 32 inches in emergency mode so that an accessible route through them is maintained in emergencies (404.3.7). Several comments opposed this requirement because of a common accessibility retrofit in which 60 inch wide double doors are automated so that both 30 inch leaves open simultaneously to meet the minimum 32 inch clear opening requirement. However, neither leaf would provide the minimum 32 inch clearance in emergency mode required by this provision.

Response. The Board has revised the requirement so that it applies only to those automatic doors and gates without standby power that are part of a means of egress (404.3.6). Automatic doors equipped with backup power would meet this requirement, including those with double leaves less than 32 inches wide. In addition, the Board has added an exception under which compliance with this provision is not required where accessible manual swinging doors or gates serve the same means of egress.

Comment. A commenter advised that no revolving doors or turnstiles should be permitted on an accessible route.

Response. As indicated in the proposed rule, manual revolving doors, gates, and turnstiles cannot be part of an accessible route (404.2.1). The Board has included a provision clarifying that automatic types of revolving doors, gates, and turnstiles cannot be the only means of passage at an accessible entrance (404.3.7). While automated revolving doors, if large enough, may be usable by people with disabilities, certain questions remain about the appropriate maximum speed, minimum diameter, compartment size, width and configuration of openings, break out openings, and safety systems such as motion detectors that stop door movement without contact. An alternate door in full compliance with 404 is considered necessary since some people with disabilities may be uncertain of their usability or may not move quickly enough to use them.