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

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.