Is a deadbolt NOT a "latch"?

[Michael.L]

I'll admit: it took me a few days of pondering to finally understand why extra clear floor space was needed for doors with both a closer and a latch, but not for a door with either a closer or a latch. Additionally, I couldn't imagine a scenario where a single-occupancy restroom would have a door without some way of securing it for privacy.

Then it dawned on me that a "latch" must be defined as a spring-loaded device that the user must perform an action upon in order to release the door (turn a lever, press a paddle, etc) and that the user must continue to hold that "latch" in the released position (against the pressure of the latch's spring mechanism) while the door is then being pushed or pulled open against the force of the closer. In other words, the user must perform two separate but simultaneous actions: (1) hold open the latch against spring pressure; and (2) push or pull open the door against the pressure of the closer.

Remove the closer, and the user can release the latch and then freely swing the door open.

Remove the latch, and the user can simply push through the door (or pull it open).

Add both a closer and a latch and it becomes very challenging for a disabled person to perform both actions at the same time. Hence the need for additional maneuvering space.

Am I understanding this correctly so far?

So that leads me to four questions:

1. If a door has a closer and a deadbolt for privacy (with no spring-loaded "latch" that automatically secures the door when the door closes), does that negate the requirement for additional clear floor space?

2. Is it permitted to have a door to a single-occupancy restroom with only a deadbolt, but no latch?

3. If the previous two questions are true, is this widely known and accepted by inspectors?

4. Is there any ADA code reference that specifically backs this up?
​

Just to be clear, my definition of a deadbolt would be a manually-activated device that has an operating lever on the inside and a keyed cylinder on the outside. The deadbolt requires a user to perform an action on the inside lever to lock or unlock the door; the bolt remains in whichever position is selected by the user. For a single-occupancy restroom, the deadbolt would have an indicator that shows that the restroom is "Occupied" when the deadbolt is locked, and "Vacant" when the deadbolt is unlocked.

 

[cda]

not into handicap bathrooms,

But I think you are applying latch wrongly,

I have seen slide latches and other type, where you open it and it stays open. Then you just open the door

 

[Michael.L]

I have seen slide latches and other type, where you open it and it stays open. Then you just open the door

I realize those are called latches in common vernacular. But does a slide latch meet the definition of a "latch" for the purposes of ADA clear floor space requirements? I would think that it doesn't. Is the word "latch" defined anywhere in the ADA code? I couldn't find it.

 

[cda]

Ok I was thinking the actual stall door

And I think you mean the room door

Sorry


Not sure if it has to be spring loaded?

 

[cda]

Read through this

May help


http://idighardware.com/?s=Restroom&submit=

Plus use different search terms


Plus you can email a question


http://idighardware.com/about-2/

 

[mp25]

1. If a door has a closer and a deadbolt for privacy (with no spring-loaded "latch" that automatically secures the door when the door closes), does that negate the requirement for additional clear floor space?
​

​

While I am not a building inspector, I have always interpreted it the same way as you have described it.

 

[north star]

# # # #

1. No
2. IMO, Yes !
3. Nothing is widely known or accepted by Inspectors, ...anywhere !
4. Back what up ?......What are you trying to find out ?

latch = [ One definition ]: "A device for holding a door, gate, or the
like, closed, consisting basically of a bar falling or sliding into a catch,
groove, hole, etc." [ i.e. - no spring is required ]

# # # #

 

[Michael.L]

1. No

May I ask what you're basing this determination on? I'm not seeking opinion, but something either in the ADA code or in widely-accepted practice.

4. Back what up ?......What are you trying to find out ?

I thought that was clear from my post. I'm trying to find out if it's possible to have a closer and a "deadbolt" (as opposed to a closer and a "latch") to avoid the extra clear floor space requirement.

latch = [ One definition ]: "A device for holding a door, gate, or the like, closed, consisting basically of a bar falling or sliding into a catch, groove, hole, etc." [ i.e. - no spring is required ]

This appears to be a dictionary definition. I'm seeking the legal definition of a "latch" with respect to the ADA code.

 

[Builder Bob]

The problem with code is that it is subject to interpretation by the AHJ --- A deadbolt in my humble opinion does not meet the requirement for a latch, however in the next city, USA it may...... the best guidance is to look at DOJ lawsuits for improper ADA accessibility and determine what is most probably the norm.... Crappy answer I know, but in most cases if you ask a code related question, the response you will get is "It depends"

 

[Michael.L]

The problem with code is that it is subject to interpretation by the AHJ --- A deadbolt in my humble opinion does not meet the requirement for a latch, however in the next city, USA it may...... the best guidance is to look at DOJ lawsuits for improper ADA accessibility and determine what is most probably the norm.... Crappy answer I know, but in most cases if you ask a code related question, the response you will get is "It depends"

Wow. So the ADA code has been in existence since 1990, with a major revision in 2010, and in almost 3 decades, no one has bothered to establish definitions for the binding legal language used in the code? How hard is it to write a glossary of terms? Instead, they're leaving it up to local interpretation (and perhaps even leaving it to the interpretation of various individuals)? To me, this is unacceptable.

 

[Michael.L]

Btw, this is the type of deadbolt I'm thinking about putting on the single occupancy restroom (with no other latch). So someone inside can unlock the deadbolt and then push through the door as if no latch exists.

 

[Michael.L]

I just found an interesting tidbit that seems to back up my position that a deadbolt, by itself, is not a latch.

Because this is a fire door, it must close and latch to deter the spread of smoke and flames. NFPA 80 addresses products which do not latch each time the door closes, but requires that “in a fire emergency, the door becomes positively latched by means of an automatic fail-safe device that is activated by an automatic fire detector.”

Note the focus on the requirement for a "latch" to actually latch (secure) the door automatically when the door is in the closed position. A manually-operated deadbolt will never automatically latch a door. To me, this means that a deadbolt is not considered a "latch" for the purposes of building, fire, and accessibility codes; instead, a deadbolt falls under the category of "a product which does not latch each time the door closes."

 

[LGreene]

Hi All -

I just submitted a request for a staff opinion to the ICC, and I will report back. In my opinion, a deadbolt is not the same thing as a latch, based on industry terminology and the requirements for latching on fire doors. The building occupant would not be holding a latch retracted and pushing against the force of the closer simultaneously, so I don't think the extra maneuvering clearance is needed. But I will let you know what the ICC says.

- Lori

 

[Michael.L]

Thank you, Lori!

 

[ADAguy]

Michael:
1. ADA "is not" a code, it is merely a model.
2. 201.4 Terms not defined refers you to "other commonly implied in the context of its use", (wordsmithing required and an English major (smiling)).
You are expending a great amount of time seeking an affirmative definition where one does not presently exist. The intent of the code is not to have to define "every" term used or it will increase in size tremendously. This is where "it depends" is left to the AHJ and "others" to determine what is acceptable or not.

 

[Michael.L]

You are expending a great amount of time seeking an affirmative definition where one does not presently exist. The intent of the code is not to have to define "every" term used or it will increase in size tremendously. This is where "it depends" is left to the AHJ and "others" to determine what is acceptable or not.

Considering that people are able to sue a business into oblivion over "civil rights violations" established by this "model," I'd say it's pretty damn important that the terms be affirmatively defined. Why should it be left to the discretion of the AHJ where it can vary from county to county? Laws and regulations should be standardized, uniform, and clear.

And since when has the government been concerned about the size of paperwork?

 

[mtlogcabin]

Latch is used 57 times throughout the I-codes and it includes self latching, night latch, hook-and-eye-type latch incorporating a spring-actuated retaining lever such as a safety gate hook, three-point latch and latch bolt.

1. If a door has a closer and a deadbolt for privacy (with no spring-loaded "latch" that automatically secures the door when the door closes), does that negate the requirement for additional clear floor space? No you would still have to meet the clearance requirements for a compartment door which is 52 inches from hinge side A117.1 section 604.9.3.1

2. Is it permitted to have a door to a single-occupancy restroom with only a deadbolt, but no latch? Yes if is is an accessible thumbturn. See answer above and http://idighardware.com/2010/08/accessible-thumbturns/

3. If the previous two questions are true, is this widely known and accepted by inspectors? IMHO No

4. Is there any ADA code reference that specifically backs this up? Not to my knowledge



604.9.3 Doors.
Toilet compartment doors, including door hardware, shall comply with Section 404, except if the approach is to the latch side of the compartment door clearance between the door side of the stall and any obstruction shall be 42 inches (1065 mm) minimum. The door shall be self-closing. A door pull complying with Section 404.2.6 shall be placed on both sides of the door near the latch. Toilet compartment doors shall not swing into the required minimum area of the compartment.

404.2.6 Door Hardware.
Handles, pulls, latches, locks, and other operable parts on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, pinching, or twisting of the wrist to operate. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the floor. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.

EXCEPTION: Locks used only for security purposes and not used for normal operation shall not be required to comply with Section 404.2.6.

404.2.7 Closing Speed.

404.2.7.1 Door Closers.
Door closers shall be adjusted so that from an open position of 90 degrees, the time required to move the door to an open position of 12 degrees shall be 5 seconds minimum.

404.2.7.2 Spring Hinges.
Door spring hinges shall be adjusted so that from an open position of 70 degrees, the door shall move to the closed position in 1.5 seconds minimum.

404.2.8 Door-Opening Force.
Fire doors shall have the minimum opening force allowable by the appropriate administrative authority. The force for pushing or pulling open doors other than fire doors shall be as follows:

1. Interior hinged door: 5.0 pounds (22.2 N) maximum

2. Sliding or folding door: 5.0 pounds (22.2 N) maximum

These forces do not apply to the force required to retract latch bolts or disengage other devices that hold the door in a closed position.

 

[Michael.L]

1. If a door has a closer and a deadbolt for privacy (with no spring-loaded "latch" that automatically secures the door when the door closes), does that negate the requirement for additional clear floor space? No you would still have to meet the clearance requirements for a compartment door which is 52 inches from hinge side A117.1 section 604.9.3.1

Thank you for this information, but that code section is for toilet compartments (i.e., toilet stalls). I don't believe it applies to entry doors to single-occupancy toilet facilities (single-occupancy restrooms).

 

[mtlogcabin]

I would consider a single occupancy toilet room as either a compartment or a room and allow whichever section will give you the smallest clearance requirement at the door (alternate means and methods). If it works for a compartment it will work for a toilet room door, A compartment is required to have a pull handle on both sides as you may have to pull on the door to engage the slide latch/bar I would require a pull handle if you installed anything other than a self-latching device, maybe that is the reason for the clearance requirements I do not know.

 

[cda]

Hi All -

I just submitted a request for a staff opinion to the ICC, and I will report back. In my opinion, a deadbolt is not the same thing as a latch, based on industry terminology and the requirements for latching on fire doors. The building occupant would not be holding a latch retracted and pushing against the force of the closer simultaneously, so I don't think the extra maneuvering clearance is needed. But I will let you know what the ICC says.

- Lori

Idea what could be used?

 

[Michael.L]

I would consider a single occupancy toilet room as either a compartment or a room and allow whichever section will give you the smallest clearance requirement at the door (alternate means and methods). If it works for a compartment it will work for a toilet room door, A compartment is required to have a pull handle on both sides as you may have to pull on the door to engage the slide latch/bar I would require a pull handle if you installed anything other than a self-latching device, maybe that is the reason for the clearance requirements I do not know.

Since I'll only be building a single-occupancy restroom (no compartments/stalls), I'll limit my discussion to only this type of facility.

I think it would be a good idea to have a pull-handle on a door that has only a deadbolt (no self-latching device), even if the door has a closer.

 

[ADAguy]

Good "Best Practice", code required? Only for Accessible stalls, required on both sides.

 

[LGreene]

I talked with an ICC staff member today, and she agreed that a deadbolt is not a latch. So a door with a closer and a deadbolt would not require the additional maneuvering clearance needed when a door has a closer and a latch.

 

[Yikes]

I look forward to Lori's research and response. I believe the reason for the extra 12" push side clearance when equipped with both closer AND latch is that the extra force and dexterity required to SIMULTANEOUSLY operate the latch and closer means that a person with weak limbs might have to physically center their body at the latch handle in order to both turn it and open the door.

Therefore, if the latch can be opened first and it stays open, then in a second step the door can be pushed open without needing to simultaneously hold onto the latch, there should be no need for the 12" push.

As I say, I think this is the code intent. how it is worded and what was intended are sometimes different things.