Question Regarding AHJ Authority in NFPA 72 and ADA Compliance for Pull Station Covers

[YOUNG EE]

I’m reviewing the compliance of pull station covers with ADA and NFPA 72 standards. Specifically, the covers protrude about 5.2 inches from the wall(Surface Mounted), which exceeds the ADA guideline of 4 inches for objects in circulation paths. The vendor has stated that the pull station is ADA compliant for operation but not for the projection, and they mentioned that the final determination should be up to the Authority Having Jurisdiction (AHJ). Note these pull station covers are used everywhere. However clarification and an exception explanation will be good to have.

I’m looking for clarification on a few points:

1. Does NFPA 72 allow for the AHJ to make the final call on whether protrusions beyond the 4-inch limit are acceptable, and does it provide any guidance on how the AHJ should interpret or approve these situations?
2. Does the ADA contain any specific language that suggests the AHJ has the authority to approve deviations from the 4-inch protrusion limit, or should the design strictly adhere to the 4-inch rule?
3. If an exception is allowed by the AHJ, what kind of documentation or justification would be needed to support the decision? Spec Sheet

 

[Joe.B]

I'm sure we can help provide some clarification, but first, could you provide a little more background? Such as:
New or existing?
Size of building, type of construction, occupancy group?
What's your role? (Who do you work for?)

 

[Joe.B]

Oh, and what area is the project in?

 

[Yankee Chronicler]

I’m reviewing the compliance of pull station covers with ADA and NFPA 72 standards. Specifically, the covers protrude about 5.2 inches from the wall(Surface Mounted), which exceeds the ADA guideline of 4 inches for objects in circulation paths. The vendor has stated that the pull station is ADA compliant for operation but not for the projection, and they mentioned that the final determination should be up to the Authority Having Jurisdiction (AHJ). Note these pull station covers are used everywhere. However clarification and an exception explanation will be good to have.

I’m looking for clarification on a few points:

1. Does NFPA 72 allow for the AHJ to make the final call on whether protrusions beyond the 4-inch limit are acceptable, and does it provide any guidance on how the AHJ should interpret or approve these situations?

I don't know about in California but in most jurisdictions NFPA standards such as NFPA 72 are not adopted directly as primary codes, they are adopted as referenced standards under the building code (and/or fire code). As referenced standards, their enforcement by the AHJ is as spelled out in the applicable building (or fire) code. I don't have the current edition of NFPA 72 but the 2013 edition says:

1.7 Code Adoption Requirements. This Code shall be administered and enforced by the authority having jurisdiction designated by the governing authority.

So that's how you get the AHJ having authority over NFPA 72.

1. Does the ADA contain any specific language that suggests the AHJ has the authority to approve deviations from the 4-inch protrusion limit, or should the design strictly adhere to the 4-inch rule?

No.

1. If an exception is allowed by the AHJ, what kind of documentation or justification would be needed to support the decision? Spec Sheet

This is a guess, but IMHO the only viable justification would be technical infeasibility.

 

[arwat23]

2. Does the ADA contain any specific language that suggests the AHJ has the authority to approve deviations from the 4-inch protrusion limit, or should the design strictly adhere to the 4-inch rule?

Not as far as I know. Even if a jurisdiction missed this, is wouldn't shield the owner from potential lawsuits. ADAS isn't something you can just ignore without cause.

3. If an exception is allowed by the AHJ, what kind of documentation or justification would be needed to support the decision? Spec Sheet

MAYBE unreasonable hardship. Assuming this is in California, CBC 11B-202.4, exception 8. But since these are all new, that almost certainly wouldn't apply. Maybe technical infeasibility?

 

[mtlogcabin]

Maybe they just need to purchase compliant covers

https://www.amazon.com/Safety-Technology-International-STI-13010FR-Polycarbonate/dp/B007885Y3K/ref=sr_1_1?dib=eyJ2IjoiMSJ9.NU0dd5S0vFIghmApopSfofuKZ_HKTKQnPXAoaKts7_s3C6rLBeHVggd1zhi7m-avC58yDFvW40t8CW5YR6JlwAgA4LvoV6jByegMuyRkrI7MDwqoi0JdJOR3jZiL2bPeo7xlnkBKo9nJQQaPg7qEZfweoG0qFiP1nnwXkSm4C-whYyaINZIB-GITp_RXnN9vENVxD45x4W2pQARxrwzYmOKFGfvuPFdRUBOL3btGBExIAjwLzKQG8-KII_Y1Cfahnl0mYkBO_5pZFjmLoRusWOOhh94NYITwHbAVEH0TyGmuT6E5V7CiDM3at25AMFUK-IfAJKLJwkwkRapYtIa3jqdA5sZCUkcs6FY_YGU1kxR7f79CebWvXffJ_6vxh1V86MlSMD1VgDUeZSO_SxvVRZAV6HtDcBS7c1-O4CtxX6Pr8WuuO0vvvz_cSKn0m2JJ.bELP-9OaAo8B8AmhVn9gGKFQSfsCz3Ez8lr7F2J3-cE&dib_tag=se&keywords=fire+pull+station+cover&qid=1737763808&sr=8-1

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Brand	STI
Color	Red
Material	Polycarbonate
Style	Stopper
Product Dimensions	8.13"L x 5.31"W

---

About this item​

• Indoor outdoor cover protects against vandalism and accidental damage
• Protects pull stations keypads intercom stations emergency buttons electrical light switches duplex plugs etc
• Cover molded from thick tough polycarbonate material. Maximum protrusion is 4 inches deep
• High strength continuous hinge
• UL/CUL listed, ADA Compliant

› See more product details

 

[Yankee Chronicler]

Maybe they just need to purchase compliant covers

Oh, come on. That's just crazy talk!

 

[steveray]

Phones, tvs, hand sanitizers, countertop cantilevers often are in violation of the 4” rule which is Al’s covered in 1003.1.3 (maybe) of the IBC … the interpretation is whether or not it is a circulation path….

 

[BN4537]

The DOJ is the AHJ for the ADA, not the local jurisdiction. The DOJ is not going to create an exception for a manufacturer who is not getting with the program on a federal law that has been adopted since 2010.

Edit: It was in the '91 ADA too... 35 years? The manufacturer is dead wrong.

 

[Yikes]

A fire alarm pull station is intended to be used by any building occupant. Therefore whatever pathway it is on is considered an accessible path.

Please note that if they are already purchased / installed, a simple solution may be to provide a cane-detectable protrusion below it.
Example: This sounds ugly, but you could literally tack on a scrap of 2x4 onto the wall at 24" high, located underneath the pull station cover. The 2x4 is 1.5" thick. That means anything mounted above it can protrude up to 5.5" from the edge of the walking surface and it will still be incompliance with 11B-307.2. You would just need to confirm it is OK to reduce the provided exit width by 1.5" inches.

 

[steveray]

I was close.. #itsnotjustaccessibility

1003.3.3​

Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the finished floor shall not project horizontally more than 4 inches (102 mm) into the circulation path.

Exception: Handrails are permitted to protrude 41/2 inches (114 mm) from the wall or guard.

 

[Yikes]

I was close.. #itsnotjustaccessibility

1003.3.3​

Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the finished floor shall not project horizontally more than 4 inches (102 mm) into the circulation path.

Exception: Handrails are permitted to protrude 41/2 inches (114 mm) from the wall or guard.

I think the difference between chapter 10 and chapter 11B is that 1003.3.4 is a bit more limited, referring to the "minimum clear width" of accessible routes on the "means of egress system" (1003.1). 11B-307 applies not just the MOE system but to all circulation paths covered under division 2.

CBC 1003 and 1003.3.4 also includes cross-references to CBC 11A and 11B to make sure the designer follows whatever applicable code is more restrictive.

 

[ICE]

A fire alarm pull station is intended to be used by any building occupant. Therefore whatever pathway it is on is considered an accessible path.

Please note that if they are already purchased / installed, a simple solution may be to provide a cane-detectable protrusion below it.
Example: This sounds ugly, but you could literally tack on a scrap of 2x4 onto the wall at 24" high, located underneath the pull station cover. The 2x4 is 1.5" thick. That means anything mounted above it can protrude up to 5.5" from the edge of the walking surface and it will still be incompliance with 11B-307.2. You would just need to confirm it is OK to reduce the provided exit width by 1.5" inches.

That sounds goofy. Can you get them made out of rubber.

 

[princeofpen]

Projection of cover subject aside ...........
I'll add that operable parts are to be used by one hand. How is it that you can operate the cover and reach in with the same hand to operate the FA device? From what I remember the covers do not have a hold "up" and would require use of two hands

 

[Yikes]

Projection of cover subject aside ...........
I'll add that operable parts are to be used by one hand. How is it that you can operate the cover and reach in with the same hand to operate the FA device? From what I remember the covers do not have a hold "up" and would require use of two hands

One-handed demonstration:

 

[steveray]

I've seen closed fist, but never one hand for operable parts....Where does that kick in?

 

[steveray]

I think the difference between chapter 10 and chapter 11B is that 1003.3.4 is a bit more limited, referring to the "minimum clear width" of accessible routes on the "means of egress system" (1003.1). 11B-307 applies not just the MOE system but to all circulation paths covered under division 2.

CBC 1003 and 1003.3.4 also includes cross-references to CBC 11A and 11B to make sure the designer follows whatever applicable code is more restrictive.

FYI....1003.3.3 is the circulation path and has nothing to do with accessible clear width....

 

[Yikes]

FYI....1003.3.3 is the circulation path and has nothing to do with accessible clear width....

Right. 1003.3.3 applies to all circulation paths on the means of egress system, whether or not that circulation path also happens to be an accessible route.
CBC 1003.3.4 further clarifies that if it is an accessible route protruding objects are still subject to 11A and 11B (which incorporates much of the ADA standards.

Example: A 61" wide corridor has a 5.2" pull station located directly across from a door that swings into the corridor. Let's say the chapter 10 occupant load only requires a 44" wide corridor.

• 1003.3.3 would require a cane detection at max 27" AFF that sticks out at least 1.2" into the corridor. That leaves max 4" pull station projection beyond the cane detection, so it complies with 1003.3.3.
• The cane detection leaves 59.8" clear corridor width. The pull station projection also leaves 55.8" clear corridor width, so that's better than 44", so it complies with Chapter 10 minimum egress width and with.
• However, looking at 1003.3.4 tells us to also comply with accessible route requirements. Both the pull station and the cane detection below it fail to provide the minimum 60" door maneuvering clearance found in 11B/ADA.

 

[redeyedfly]

• However, looking at 1003.3.4 tells us to also comply with accessible route requirements. Both the pull station and the cane detection below it fail to provide the minimum 60" door maneuvering clearance found in 11B/ADA.

Unless it's a hinge or latch approach.

1003.3.4 is a bit more limited, referring to the "minimum clear width" of accessible routes on the "means of egress system"

It applies to any projection in a circulation path, not only when it may be within the minimum width. You could have a 10' wide hallway which requires 44" minimum egress width and you still can't have 5" projection per 1003.

 

[tbz]

Now its been over 30 years since I was working in the fire-alarm system industry, but this is a very old issue when mounted to a box on a concrete wall and not recessed in the block wall.

The simple fix we used was to take a 4ft length of plastic wire mold run from under the pull station down to the floor and now the projection was less than 4 with its stand, aka the wire mold which was less than 27 inches off the floor.

Not sure if they are still accepting this fix, again been 30 plus years, but it worked in my younger years, before the cane.

The other option is to recess the pull station flush and then the STI covers don't project more than 4 inches and comply.

 

[steveray]

Now its been over 30 years since I was working in the fire-alarm system industry, but this is a very old issue when mounted to a box on a concrete wall and not recessed in the block wall.

The simple fix we used was to take a 4ft length of plastic wire mold run from under the pull station down to the floor and now the projection was less than 4 with its stand, aka the wire mold which was less than 27 inches off the floor.

Not sure if they are still accepting this fix, again been 30 plus years, but it worked in my younger years, before the cane.

The other option is to recess the pull station flush and then the STI covers don't project more than 4 inches and comply.

Yep...."cane barrier" type thing...