Latch vs. Exit Device

[Gizmo]

That would be less than one foot from the door and place the activating switch in the door swing.

The intent of "placing the activating switch in the door swing" is putting the switch in a place that the door will hit the person in the wheelchair upon activating the door. That is just logical. For instance... you can't put the switch behind the door where the door would actually pin the person and the wall or pedestal. It's safe to say that if you mount the switch on the push side of the door and upon pushing it allows the door to automatically swing open and away from the disabled person, I would think that would be the intent of the author. Again, dismissing the letter of the law and the logical intent to the requirements does not make for a common sense inspector. Does anyone ever ask why or what the intent to a code requirement is there for? In order to problem solve, we need to find acceptable resolutions, not just keep reiterating verbatim a code requirement without knowing why. If you never ask 'why', you'll never find solution to problems and resolve issues. 99% of the code requirements make common-sense and do not need to be further investigated. It's the 1% of these issues that cannot be easily explained away and therefore require some active problem solving. In resolving some of these issues, the remedy comes into question, and this is where we need to collectively put our minds together to resolve the problem.

 

[JPohling]

when you use your common sense on an accessibility issue your exposing the property owner to being sued for a civil rights violation

 

[Gizmo]

On the door is not 1' from the door. obviously could not be on the pull side. Believe me, I would love to have the ability to eliminate push side clearances by adding a panic bar. I have fought that battle many times over the years. Wheelers approach and pass thru doorways in a very specific series of operations. I am sure many wheelers could get thru the panic device without the clearance, but it requires a different approach and until they specifically allow it as an exception your not able to have it approved as such.

Again... why does the button or whatever unlatches the door need to be 12" away. Does it not work the same if it's 11" away? 12" away from the pull side seems a bit close and would still probably hit the wheelchair if the person in the chair approached from either the center or the side. I truly believe if this issue is truly argued to the powers that be, I feel that they would indeed clarify that an exit device is not a latch in what they are vaguely implying. I also believe that they included the 12" side clearance to facilitate the unlatching of a levered device... not to push the pad of an exit device. No one here has proven to me that the intent of the author was to include the exit device with the limitations as such that the 12" side access is warranted. Since the panic device can be operated more than 12" away from the edge of door, unlike a levered device, I feel that authors didn't include an exit device as a "Latch". The authors know the difference and do not identify a Panic as Latch in this section of the code. I believe that the powers that be will eventually address this issue and clarify that the exit device does not require the 12" side clearance. Peculiar thing though... throughout the past 15 years or so, this was an acceptable fix to the side clearance issue on hundreds of LAUSD openings... as directed by DSA Architects and Inspectors. For some reason, on one of my schools it was flagged and hence spurred this debate.

Does the authority of one inspector override the authority of another? Since it's obvious that this debate is subjective to interpretation, can the actual author of this particular code requirement be summoned to answer the issue once and for all?

 

[Gizmo]

when you use your common sense on an accessibility issue your exposing the property owner to being sued for a civil rights violation

Any lawyer can argue in a court of law that a "Latch" is not an "Exit Device"... I have effectively done it here and I am not a lawyer. When I am referring to "Common Sense", I'm essentially asking what the intent of a certain code requirement is logically for. If the 12" requirement is not for the actual unlatching of an exit device, and not for pushing a self-closing door open with push/pulls, then it's obvious that the logical intent is for the access to the lever handles. That's what I mean by "common sense" and logic.

 

[cda]

""""Does anyone ever ask why or what the intent to a code requirement is there for?"""

Everyday I go to work.

"""""can the actual author of this particular code requirement be summoned to answer the issue once and for all"""""

Might be more than the author, might be a few people that shaped the langauge

You can present code changes to future editions!!!!!!!!!!!

 

[Gizmo]

Thank you all for this spirited debate and insight... although I am still not convinced that the purpose of the 12" side clearance includes exit devices, I do appreciate all the replies.

Thanks everyone for the attachments and pictures.

CDA, how can I present code changes to future editions?

 

[JPohling]

Just because it took 15 years for an inspector to actually enforce the written code instead of ignoring it does not mean it was done properly for 15 years. This is not a new requirement. Until there is a code exception for the situation your describing utilizing your common sense exposes property owners to legal action.

If the DSA issues an exception for use in the schools that they have jurisdiction over.................... then hang your hat on that.

I do not believe you have successfully argued anything at this point. The door is latched irregardless of the method that is used to release the latch and allow the door to swing.

I wish you success in instituting a code change.

 

[mtlogcabin]

If the 12" requirement is not for the actual unlatching of an exit device, and not for pushing a self-closing door open with push/pulls, then it's obvious that the logical intent is for the access to the lever handles.

It is strictly for maneuvering clearances at a door with a closure and a device that secures the door in a closed position regardless of the terminology/name used for such a device.

I see your point with regards to an electronically controlled device no matter where the pad is mounted provided there is ample time to open the door before the latch engages again and it disengages during a power outage . As for panic devices I am not in complete agreement.

 

[JPohling]

I think under alternative means you might be able to get away with a proximity detector that would release the auto latch or strike. So whenever a person is detected the door is automatically unlatched therefore no 12" push side clearance required. connected to e-power of course.

 

[Frank]

So a panic device with a delayed latching strike is acceptable to you? What about a panic bar with a breakaway strike. This type doesn't actually retract the bolt but actually releases it, when the bar is pushed, so it swivels out of the way when the door is pushed open. It stays in this unlatched mode for a set period of time. Then when the door self-closes, relatches itself. So the code allows for this device as an exception to the rule? Where can I find this exception?As I keep reiterating... if the 12" is not for unlatching the levered device, then it must be for pushing a self-closing door open. But if the door doesn't have a latch and only a closer, the 12" isn't required. So then the 12" isn't for pushing the door open... it must be for unlatching the door. In your explanation, how does providing the 12" help with a door with a levered latch from continuously closing and self-latching while the person in the wheelchair keeps trying to maneuver through the opening. Basically, in your rebuttal, explain how providing this 12" somehow prevents a door from repeatedly latching if the door is equipped with a levered device, and the person in the wheelchair lets go of the door hardware to grab his wheels and maneuver away from the immovable 12" of wall space to the 32" clear space through the door? The code writers obviously know that a person in a wheelchair must be able to negotiate a lever, push the self-closing door open, and maneuver their wheelchair with the extra 12" side clearance. Allowing a person in a wheelchair to navigate to the actuator of the exit device, the push-bar, eliminates the need of the extra 12" and therefore makes the process easier to maneuver.

The first might be grounds for a modification depending on the specific hardship of the case and the specific products proposed.

In the second case the 12 inch clearance lets the disabled person approach the door at an angle part of the back of the wheelchair beside the door overlapping into this clear space with the footrest against the door they can anchor the near wheel, use the near hand to unlatch the door while using the far hand to swivel the chair against the door to push and hold it open while the near hand releases the brake and pushes on through the door. You should take an opportunity to watch disabled people maneuvering around obstacles.

Note that a lot of these provisions were proposed by disabled people and various disabled people were on the committee considering them. They knew the ins and outs and challenges of barriers

 

[LGreene]

I confirmed with both of my California contacts that the DSA has allowed panic hardware as a retrofit to resolve maneuvering clearance issues. They both said that it is a resolution for existing problems only, and they would not use it for new work. As I said before, I have not run into this myself, and to me it indicated that DSA has compromised on this but it does not establish that the standard means different maneuvering clearances should be applied to doors with panic hardware. I have put it on my list to explore with the next code development cycle for A117.1, but that will be a while.

 

[Gizmo]

I confirmed with both of my California contacts that the DSA has allowed panic hardware as a retrofit to resolve maneuvering clearance issues. They both said that it is a resolution for existing problems only, and they would not use it for new work. As I said before, I have not run into this myself, and to me it indicated that DSA has compromised on this but it does not establish that the standard means different maneuvering clearances should be applied to doors with panic hardware. I have put it on my list to explore with the next code development cycle for A117.1, but that will be a while.

Thanks Lori, also when you stand before the house of the ADA Gods, can you ask them to further identify the word "Latch". I truly stand by my belief that the intent of the code authors is that the Latch they are referring to is a "Levered Device" and not an Exit Device. Since this is left up to interpretation, I think it would behove them to further identify the intent of the law. I truly believe that the purpose of the 12" space is only there to help aid the person in the wheelchair to unlatch the device that is closest to that location... a levered latch. If they wish to include panics in this section of the code, I think it should be spelled out as such. The revision should read, "12" side clearance required on doors equipped with a Closer and Latch or Exit Device".

Since you are an architectural hardware expert yourself... have you ever ordered a Latch set and expected a Panic Device to show up at your door?

 

[mark handler]

Since you are an architectural hardware expert yourself... have you ever ordered a Latch set and expected a Panic Device to show up at your door?

A panic device does have a latch.

Pushing the bar retracts the latch

A latch is a function and part and can be in a variety of devices, and a noun and verb.

On that note, I have used panic devices to skrit the 12 in requirements. And we have had this conversation on this site before.

 

[Gizmo]

A panic device does have a latch.Pushing the bar retracts the latch

So what does pushing the actuator button on an electrified exit device retract? An electrified panic has a latch, so by your logic requires the 12"?

Mark, for the record, pushing the bar retracts the strike from the strike plate! I don't think that the author of the code is specifying an actual component that is spring-loaded in a device. When he refers to "Closer", they are not implying that it includes a baseball pitcher that comes in relief at the end of the game to try and win it for the team. Again, this is another loose interpretation of someone's opinion of what a "Latch" is referring to.

 

[mark handler]

So what does pushing the actuator button on an electrified exit device retract? An electrified panic has a latch, so by your logic requires the 12"?Mark, for the record, pushing the bar retracts the strike from the strike plate! I don't think that the author of the code is specifying an actual component that is spring-loaded in a device. When he refers to "Closer", they are not implying that it includes a baseball pitcher that comes in relief at the end of the game to try and win it for the team. Again, this is another loose interpretation of someone's opinion of what a "Latch" is referring to.

Contact the hardware manufacture the strike is what the latch interacts with.

Your definitions are not the hardware manufactures definitions.

 

[cda]

715.4.8.1 Latch required. Unless otherwise specifically permitted, single fire doors and both leaves of pairs of side-hinged swinging fire doors shall be provided with an active latch bolt that will secure the door when it is closed.

 

[Gizmo]

Again... the same rhetoric... While considering the intent of the law, explain intelligently what the 12" is required for. This argument is about what the intent of the 12" of side clearance that the author of the code implied. Simply reiterating that the panic latches is not logically explaining why the 12" is needed if the door can be unlatched from elsewhere. Even an electrified exit device can be construed as a latching device, yet everyone here agrees that it is an acceptable application that doesn't require the 12". It's also a Latch, by your definitions, yet you seem to think that it's exempt from the 12" side clearance. Using your own logic that it's exempt because it can be unlatched from an accessible location, is exactly what an exit device gives the user.

CDA: That is an entirely different code section and that explanation is better served, "... active latch bolt". That describes a device that has a component that will secure the door(s) when they close. It could be a vertical rod device, lock or latch set, rim panic, mortised panic, self-latching flushbolts, etc.. But the code for ADA access through the push side of an opening is not describing a component inside a device... a Closer is not a component inside another device, yet it's called out with a "Latch", which some here think should include an exit device because it has a latching quality, or the spring loaded strike bolt is a latch bolt in their eyes.

I've logically argued that the 12" is required for access to a levered device, which I truly believe what the author of the code implied, yet for whatever reason, most disagree with me; without a logical explanation why. Most won't even consider without a shadow of a doubt, that I may actually be right... I guess that rigidity is what is taught in "Inspector School Training". Inspector Motto: "Once you take a position on an issue, correct or not, never relinquish your convictions, the mortals will sense weakness.":banghd

 

[mark handler]

Because most do not agree with you should tell you that your theory maybe flawed. You might want to learn the terms before you determine their definitions.

I posted that I have used a panic device to mitigate the strike clearance. That is not the same old rhetoric.

You are passionate about the issue, and your logic is valid. But take a breath.

Also understand that this board has many people with diverse backgrounds and a wide variety of knowledge, not all are inspectors. And not all inspector training is the same. Not everyone here went to "Inspector training School".

Fill out an alternate means and methods form

concentrate on the function of the hardware, interaction of the user, and the physical conditions resulting in the reason for the request and not the presence of a latch.

Remove the emotion from the request.

 

[cda]

Again... the same rhetoric... While considering the intent of the law, explain intelligently what the 12" is required for. This argument is about what the intent of the 12" of side clearance that the author of the code implied. Simply reiterating that the panic latches is not logically explaining why the 12" is needed if the door can be unlatched from elsewhere. Even an electrified exit device can be construed as a latching device, yet everyone here agrees that it is an acceptable application that doesn't require the 12". It's also a Latch, by your definitions, yet you seem to think that it's exempt from the 12" side clearance. Using your own logic that it's exempt because it can be unlatched from an accessible location, is exactly what an exit device gives the user. CDA: That is an entirely different code section and that explanation is better served, "... active latch bolt". That describes a device that has a component that will secure the door(s) when they close. It could be a vertical rod device, lock or latch set, rim panic, mortised panic, self-latching flushbolts, etc.. But the code for ADA access through the push side of an opening is not describing a component inside a device... a Closer is not a component inside another device, yet it's called out with a "Latch", which some here think should include an exit device because it has a latching quality, or the spring loaded strike bolt is a latch bolt in their eyes.

I've logically argued that the 12" is required for access to a levered device, which I truly believe what the author of the code implied, yet for whatever reason, most disagree with me; without a logical explanation why. Most won't even consider without a shadow of a doubt, that I may actually be right... I guess that rigidity is what is taught in "Inspector School Training". Inspector Motto: "Once you take a position on an issue, correct or not, never relinquish your convictions, the mortals will sense weakness.":banghd

""""Once you take a position on an issue, correct or not, never relinquish your convictions, the mortals will sense weakness.""""

""""Mine is show me in the book I am wrong"""

The codes are adopted by my ahj and that is what they aspect me to follow. And, not make up my own. Yes there is some interpretation involved, but I rarely stray to far, and try to be consistent.

Sounds like you would like to get into the next code development cycle????

 

[mark handler]

""""Once you take a position on an issue, correct or not, never relinquish your convictions, the mortals will sense weakness.""""""""Mine is show me in the book I am wrong"""

The codes are adopted by my ahj and that is what they aspect me to follow. And, not make up my own. Yes there is some interpretation involved, but I rarely stray to far, and try to be consistent.

Sounds like you would like to get into the next code development cycle????

Next code development cycle, 2015 is done deal... try the one after that 2018, but he is in CA, which is now based on the ADA.... next update 10 years? 2020?

 

[ADAguy]

Unlike Umpires, Inspectors don't have the "benefit" of instant replay.

Mistakes are often concealed and don't reveal themselves until the next "big one" happens.

Or a disabled person is denied "access" due to an attempt to circumvent (second guess) having to meet the letter/letters of the code/standards (which as we know can often be cloudy in their directions) by a contractor or building owner.

 

[Gizmo]

Unlike Umpires, Inspectors don't have the "benefit" of instant replay. Mistakes are often concealed and don't reveal themselves until the next "big one" happens.

Or a disabled person is denied "access" due to an attempt to circumvent (second guess) having to meet the letter/letters of the code/standards (which as we know can often be cloudy in their directions) by a contractor or building owner.

Because an Inspector or Architect couldn't possibly make a mistake or interpret a code incorrectly... they are nearly as infallible as the Pope or God himself.

 

[cda]

Because an Inspector or Architect couldn't possibly make a mistake or interpret a code incorrectly... they are nearly as infallible as the Pope or God himself.

during a good project there are plenty of checks and balances. Stuff does get missed, plus you are leaving out a few steps through the process where stuff can get caught, corrected or questioned.

Even as the building goes up any item can be questioned. does stuff get missed, are there wrong calls, YES

Hopefully it does not happen to often.

The codes are not always clear, or may not fit a certain item. But, there are plenty people in place to question. I do not always like what the code says, but that is what the city adopted.

that is the major reason this forum exists, either cannot figure out what the code is trying to say, or may have never had to deal with a specific section, and you want to ask a question so you can try to get it right.

 

[mark handler]

Because an Inspector or Architect couldn't possibly make a mistake or interpret a code incorrectly... they are nearly as infallible as the Pope or God himself.

ad hominem

If you know all the answers, why ask the question?