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

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.