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

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.