Maneuvering Clearance - ADA

[LGreene]

An architect just asked me what to specify for battery backup for automatic door operators. I have never had that request so I dug a little deeper and found a change in the 2010 ADA that I was unaware of:

404.3 Automatic and Power-Assisted Doors and Gates. Automatic doors and automatic gates shall comply with 404.3. Full-powered automatic doors shall comply with ANSI/BHMA A156.10 (incorporated by reference, see "Referenced Standards" in Chapter 1). Low-energy and power-assisted doors shall comply with ANSI/BHMA A156.19 (1997 or 2002 edition) (incorporated by reference, see "Referenced Standards" in Chapter 1).

404.3.1 Clear Width. Doorways shall provide a clear opening of 32 inches (815 mm) minimum in power-on and power-off mode. The minimum clear width for automatic door systems in a doorway shall be based on the clear opening provided by all leaves in the open position.

404.3.2 Maneuvering Clearance. Clearances at power-assisted doors and gates shall comply with 404.2.4. Clearances at automatic doors and gates without standby power and serving an accessible means of egress shall comply with 404.2.4.

EXCEPTION: Where automatic doors and gates remain open in the power-off condition, compliance with 404.2.4 shall not be required.

I have 2 questions:

1) 404.3.1 says that doors have to provide the required clear opening width (32") in power-on and power-off mode. I have seen door openings with two 30" door leaves, where auto operators were installed to open both doors simultaneously to provide more clear width. The first sentence of this paragraph seems to indicate that you need 32" clear even in power-off mode so it looks like the auto operator route is not an option for narrow pairs any longer. But the second sentence confuses me - how can both leaves be used for clear width in power-off mode? Would two 30"-wide leaves be acceptable?

2) 404.3.2 says that automatic doors without stand-by power have to provide the same maneuvering clearances that are required for manual doors. So if an auto operator is added to an existing door because the door doesn't provide the proper maneuvering clearance, the operator needs to be on stand-by power. Do you agree with that unofficial interpretation?

As always, thanks for your help.

- Lori

 

[Gene Boecker]

Hi Lori,

Neither the ADA standard nor the BHMA standards are specific about the duration of the standby power. With that void, the default is the NEC which requires 90 minutes of power.

I have a call into the Access Board for another issue. Once I get that call, I'll ask if there was something in mind for this provision.

 

[Gene Boecker]

Just for curiosity, is this a real problem?

If its a MEO door its likely to swing in the direction of travel and most automatic doors do not have latches so the maneuvering clearances are simply the width of the door on the push side.

 

[Gene Boecker]

Short answer: 90 minutes.

(But for what activity on the door???)

I spoke with the Access Board. This is an item that will be addressed in more detail in the Commentary that they are producing to assist in understanding the new rules. It was a last minute change that went in to appease a certain element of the group that was providing input on the document - a consensus addition - not universally recognized as necessary but now a regulation. Hence, it was not thoroughly addressed.

Anyway. . . .

The standby power needs to be what the IBC would call standby power since 207 of the new ADAAG requires compliance with the 200 or 2003 IBC for accessible means of egress. Neither of them address this in specific detail. Eventually, you get back to the NEC by way of Chapter 27 and NFPA 110. The NEC says that standby power by battery must have a duration of 90 minutes. Then I asked about frequency of use during that time frame. Obviously a battery is drained when used so it would make a big difference if the door is operated almost continuously for 90 minutes or if it only needs to operate for the first two minutes continuously and then once at 90 minutes. The answer is that "it depends."

The battery must be sized for the anticipated load. If it is for a simple tenant space, then maybe 2 minutes and once at 90 minutes is all that's needed based on an egress analysis. On the other hand, if this is for a main door of a 48 story high-rise, it will need to operate much more. It will be an engineered solution one way or the other based on the duration of egress. Simple, huh?

Oh, and in case the next question comes up; it's only required on the egress side of the door. If the door is swinging outward, the pull side maneuverability is not even an issue since its about egress. They are not allowed to re-enter the building to get their laptop.

And, there's no time frame yet on the 2010 ADAAG Commentary.

 

[Coug Dad]

Welcome back Gene! It is good to see you back in the saddle.

 

[alora]

And, there's no time frame yet on the 2010 ADAAG Commentary.

How will that be different than the published "Guidance on the 2010 ADA Standards for Accessible Design"?

 

[Gene Boecker]

How will that be different than the published "Guidance on the 2010 ADA Standards for Accessible Design"?

They are actually planning on a new document to explain the details in the 2010 Standards "technical" provisions. Much of the "Guidance" document is about the authority, thresholds and scoping requirements. There is little about the technical provisions. Because most of the 2010 Standards are based on the 2003 ICC/ANSI A117.1 the ANSI Commentary addresses most of those questions. However, the 2010 Standards include a few things (actually a LOT if you consider all the recreational provisions) that are not in the ANSI standard so that commentary will be limited. The question above is case in point. It contains the first sentence the same as ANSI but the federal provisions added the second - with no insight into its reason or application. This sort of thing is intended to be included in the ADAAG Commentary (what ARE we calling this new thing anyway??? I've heard six different names and that's just from the federal folks!)

Anyway, as I understand it, the new ADAAG Commentary is intended to address the provisions in a section by section discussion similar to the ANSI Commentary.

 

[mark handler]

Guidance on the 2010 ADA Standards for Accessible Design

404 Doors, Doorways, and Gates

Automatic Door Break Out Openings. The 1991 Standards do not contain any technical requirement for automatic door break out openings. The 2010 Standards at sections 404.1, 404.3, 404.3.1, and 404.3.6 require automatic doors that are part of a means of egress and that do not have standby power to have a 32-inch minimum clear break out opening when operated in emergency mode. The minimum clear opening width for automatic doors is measured with all leaves in the open position. Automatic bi-parting doors or pairs of swinging doors that provide a 32-inch minimum clear break out opening in emergency mode when both leaves are opened manually meet the technical requirement. Section 404.3.6 of the 2010 Standards includes an exception that exempts automatic doors from the technical requirement for break out openings when accessible manual swinging doors serve the same means of egress.

Maneuvering Clearance or Standby Power for Automatic Doors. Section 4.13.6 of the 1991 Standards does not require maneuvering clearance at automatic doors. Section 404.3.2 of the 2010 Standards requires automatic doors that serve as an accessible means of egress to either provide maneuvering clearance or to have standby power to operate the door in emergencies. This provision has limited application and will affect, among others, in-swinging automatic doors that serve small spaces.

Commenters urged the Department to reconsider provisions that would require maneuvering clearance or standby power for automatic doors. They assert that these requirements would impose unreasonable financial and administrative burdens on all covered entities, particularly smaller entities. The Department declines to change these provisions because they are fundamental life-safety issues. The requirement applies only to doors that are part of a means of egress that must be accessible in an emergency. If an emergency-related power failure prevents the operation of the automatic door, a person with a disability could be trapped unless there is either adequate maneuvering room to open the door manually or a back-up power source.

http://www.ada.gov/regs2010/2010ADAStandards/Guidance2010ADAstandards.htm

 

[Examiner]

In the Building Code isn't each door leaf to have a 32" clear opening anyway?

 

[Gene Boecker]

Examiner, Exception #3 to Section 1008.1.4.2 (2009) allows for the individual leaf to be less than 32 inches for bi-parting power operated doors.

 

[LGreene]

Thanks so much Gene and everyone else! The specific doors in question are existing bathroom doors where there isn't enough maneuvering clearance, so operators are being installed. If the maneuvering clearance problem is only on the outside, and the egress side maneuvering clearance is fine, I wonder if the back-up power would still be required.

The question about the pairs was just for future reference. The bathroom doors are singles, but the narrow pairs are a common application for operators. The doors would often have panic hardware, so in a non-powered situation you would have to release the latches on both panics in order to use the full width of the opening manually.

 

[peach]

I guess another question would be.. are the automatic openers for ADA really even required?

 

[mark handler]

I guess another question would be.. are the automatic openers for ADA really even required?

Required, no, but if provided, they must meet the standards.

 

[LGreene]

Peach: I guess another question would be.. are the automatic openers for ADA really even required?

In this case they're only required because the existing doors don't have the required maneuvering clearance for manually-operated doors so the options are to make them automatic doors or do some major demo and reconstruction to provide the maneuvering clearance.