Don’t Get Locked Out of Accessibility

One of the most often-overlooked facets of Americans with Disabilities Act (ADA) compliance is the door.  While parking, restrooms and signage are all notorious for their complexities, doors remain on top of the list for the California Building Code (CBC) of priorities for removing architectural barriers.  This is because while restrooms are often the site of accessibility lawsuits (for reasons we can get into in another article), and parking lots are highly visible, doors are the only architectural barrier which can single-handedly stop someone from entering a site. They can also be a direct source of injury if the door closes too quickly or is so heavy that it pushes one off-balance. Fortunately, it is relatively inexpensive to improve your door’s accessibility, especially considering the benefits that it confers to all of your customers, and even the psychological impression that an easy or difficult entrance to your business can impart.

In general, the path of travel requires what is called a pedestrian envelope.  This means that as a person travels through a site (with or without a mobility aid), there needs to be a hazard-free zone surrounding them.  Some of these requirements include edge protection, lack of protruding objects, lack of slopes and cross-slopes and clear vertical head-space.  What often gets missed is that such requirements also extend through the doorway.

Already the door has many requirements unique to itself as an architectural component.  Between the ADA and the CBC there are almost 60 unique facets of a doorway each. But between the two (one a set of civil rights laws with building code, the other a set of building codes), almost 30 (depending on interpretation) of the door requirements are shared.  While many of these don’t apply to every door, some common requirements that do apply are to further ensure that the pedestrian envelope continues uninterrupted through the door way.

These requirements don’t include some of the unstated requirements that are because of the pedestrian envelope.  Some of these include the door closer height:

Door Closer Above Doorway: Not a Hazard	Door Closer Below Doorway: Possible Hazard

The door closer should always have its equipment above 80 inches.  Since commercial doors are often at 80 inches, to have the door closer arm extend under the doorway is a violation of the ADA.  While not all commercial doors are required to be accessible, as there can be multiple entrances to an area, or entrances to areas not serving the public within an employee area, doors that are accessible should be marked accessible when there are doors that are not accessible.  Thus door closers that go around the door-frame are preferred.  Door closers are a requirement for single user restrooms, so pay close attention to them.

Another common requirement for door closers is the closing time.  Doors that are self closing, such as those in restroom stalls, are required to take at least 3 seconds to close when held at a 70 degree position [diagram].  Door closers should also be adjusted so as to require less than 5 pounds of pressure.

Along with these height requirements there are also threshold requirements.  The ADA and CBC both allow for a maximum threshold height of ½ inches above the landing on either side if the threshold is beveled, ¼ inches if the threshold is not.  What is unstated in both and not allowed are horizontal gaps under the doorway of greater than ½ inches measured in the direction of travel.

While the pedestrian envelope constitutes one of the little understood applications of the code to doors, door usage goes beyond the code requirements.  Such knowledge requires a grasp of how the principles of the ADA apply to actual individuals using a given door.  Door hardware and door latch side clearances are two of such issues.

Door hardware constitutes one of the readily achievable facets of ADA compliance.  We are all familiar with the requirements of door usage — single knobs are no longer allowed.  What is often missed is the door latch (which in commercial doors can be at the bottom of the door) or the older style thumb-latch door handles.  Although not specifically mentioned, the use of a thumb with a pulling motion falls under the rubric of a complex twisting and grasping action which both the ADA and CBC outlaw.

Another set of requirements for the door which presents confusion involves the side clearances at doorways.  These clearances are essential to aid individuals using a mobility aid (such as a walker) in operating a door.  Wheelchair-using individuals and even parents with children inside strollers require level side clearances so they can get the leverage to pull open a door.  This space allows individuals to open the door without the added difficulty of moving backwards to make way for the door swing.  There are often a series of solutions that are co-present with solving latch side door clearances.  The most expensive but most encompassing is the installation of an automatic door opening device.  Alternative fixes would include reversing the door swing or moving it from one side to the other in order to comply with latch side clearances.  This of course, relies on knowledge about the local building code requirements on your building and about the different approach requirements to your door way.

Finally, the latch side clearances also constitute a usable space within a path of travel.  Often, fire extinguishers are placed there for convenience, blocking usage of that space.  Protruding object fire extinguishers can be made to no longer be protruding objects by having the lowest edge mounted below 27 inches, or by placing furniture or detectable warnings under them.  But these solutions to removing the hazard of a protruding object would only interfere with the clear floor space, making the door less usage or even unusable for individuals with mobility impairments.  Further investigation is required per site.

These are only some of the common considerations for doorway accessibility.  Doors are often taken for granted, as people think the width is the only requirement.  Doors constitute the single most important architectural barrier as an inaccessible main entrance means that any work done — whether it be with the restroom, the lobby, any common areas or even in the parking lot can become pointless if your customer cannot enter your business in the first place.

Improving the accessibility of your business may seem like an expensive endeavor, but with the right expertise, you can save both time and thousands of dollars from unnecessary construction. Make it easier, not harder, for your customers to come inside to your store. For any questions or assistance in improving your accessibility, call us today at 866-982-3212 or email us at help@accesssolutionllc.com.

For a comprehensive list of applicable ADA/CBC codes, [DDET click here.]

Note: Many of these codes are subject to interpretation and may not reflect the latest versions applicable, especially in the case of official DSA Interpretations or Addendums. ICC/ANSI codes have been omitted. This list does not accurately reflect the full scope of methodology used by YTA and is published for informational purposes only.

CBC		ADA
1133B.1.1.2	This nonaccessible exit does not have a directional sign.
		4.1.2(7)(c)	This entrance is not accessible.
1133B.2.6	The bottom 10 inches of the door creates a hazardous condition.
1133B.2.4.2 and Figure 11B-26A(a)	There is not enough latchside clearance on the inside of the door.
1133B.2.5.1	The door closes too fast.	4.13.10	The door closes too fast.
1133B.2.5.1	The door does not close.	4.13.10	The door does not close.
1117B.5.2	The symbol on this door for the restroom is not of contrasting colors.
1115B.6	There is no symbol on this door for the restroom.
1133B.2.4.4	There is not enough room inside this vestibule for doors in series.	4.13.7	There is not enough room inside this vestibule for doors in series.
1008.1.2 and 1133B.2.5.2	The door hardware is not mounted at an accessible height.	4.13.9	The door hardware is not mounted at an accessible height.
1133B.2.5.2.c	The vertical actuation bars outside the door are not at the required height.
1133B.2.5.2.c	One or more controls operating this automatic door do not have a level clear floor space centering on the automated controls.
1117B.5.8.1, 1117B.5.5.3, 1133B.2.5.2.e, and 1133B.2.5.2.c	One or more controls operating this automatic door are missing the full sized International Symbol of Accessibility.
1133B.2.5.c	One or more controls operating this automatic door are not placed in a conspicuous location.
1133B.2.5.2.c	The higher push plate inside this door is not the required height.
1133B.2.5.2.c	The push plate operating the auto door outside this door does not open the door or there is only one push plate.
1133B.2.5.2	The door hardware is not accessible.	4.13.9	The door hardware is not accessible.
1133B.2.2 and 1133B.8.6.2	The door is too low.	4.4.2	The door is too low.
		4.13.6 and Fig 25(b) and Fig 25(c)	The Inside landing length is too shallow.
1133B.2.5.3	There is not enough latchside clearance on the inside of the door due to the alcove.
1133B.2.4.2	The inside landing slope is too great.	4.13.6	The inside landing slope is too great.
1133B.2.4.3, 1133B.2.4.5 and 1133B.2.5.3	The inside latch side clearance is too narrow.
1133B.2.4.2	The inside landing is too short.	4.13.6 and Fig 25(a)	The Inside latch side clearance is too narrow.
1133B.2.4.2 and Figure 11B-26A(b)	There is not enough width on the inside door landing.
1133B.2.4	There is no landing inside this door.	4.13.6	There is no landing inside this door.
1117B.5.2, 1117B.5.5, 1117B.5.5.4 and 1117B.5.8.1.3	The International Symbol of Accessibility on this entrance is not readily visible from the entrance to individuals with vision impairment.	4.1.2(7)(c) and 4.1and 4.30.5	The International Symbol of Accessibility on this entrance is not readily visible from the entrance to individuals with vision impairment.
1133B.2.5.2	The door latch is not accessible.	4.13.9	The door latch is not accessible.
1133B.2.5.3	There is not enough latchside clearance on the outside of the door due to the alcove.
1133B.2.4.2 and Figure 11B-26A(c)	There is not enough latchside clearance on the inside of the door.
1133B.2.4.2	The outside landing slope is too great.	4.13.6	The outside landing slope is too great.
1133B.2.4.3, 1133B.2.4.5 and 1133B.2.5.3	The outside latch side clearance is too narrow.
1133B.2.4.2	The outside landing is too short.
1133B.2.4.2 and Figure 11B-26A(b)	There is not enough width on the outside door landing.
1133B.2.4	There is no landing outside this door.	4.13.6	There is no landing outside this door.
1115B.3.2.7 and 1117B.6	The privacy latch is not accessible.	4.13.9	The privacy latch is not accessible.
1115B.3.2.7 and 1117B.6	The privacy latch is too high.	4.13.9	The door hardware is not mounted at an accessible height.
1115B.6.1	The sign on the door does not correctly identify the proper designation of this restroom.
1133B.2.5	The door pressure is too great.	4.13.11(2)	The door pressure is too great.
1117B.5.7	There is no Braille on this sign.	4.30.4	There is no Braille on this sign.
1117B.5.7	The sign is too close to the door swing.	4.30.5	The sign is too close to the door swing.
1117B.5.7	The sign for this door is mounted too low.	4.30.6	The sign for this door is mounted too low.
1117B.5.5.4	The posted International Symbol of Accessibility on this entrance is too small.	4.30.4	The posted International Symbol of Accessibility on this entrance is too small.
1117B.5.8.1.2	There is no International Symbol of Accessibility on this entrance.	4.1.2(7)(c) and 4.1and 4.30.7	There is no International Symbol of Accessibility on this entrance.
1117B.5.5	The sign has no raised lettering.	4.30.4	The sign has no raised lettering.
1117B.5.2 and 1117B.5.7	The sign is not easily visible to individuals with vision impairment.
1117B.5.1	There is no sign on the latch side marking the usage of the permanent space behind this door.	4.30.1 and 4.1.3(7)	There is no sign on the latch side marking the usage of the permanent space behind this door.
1133B.2.4.2 and Figure 11B-33	The sliding door is flush with the frame.	4.13.9	The sliding door is flush with the frame.
1133B.2.4.1	This threshold at the door is too high.	4.5.2 and 4.13.8	This threshold at the door is too high.
1124B.4	The gap in the path of travel is too great.	4.5.2 and 4.13.8	The gap in the path of travel is too great.
1133B.2.3.3	A revolving door is an entrance.	4.13.2	A revolving door is an entrance.
1133B.2.3.4	A turnstile, rail or another kind of pedestrian control is the only path of travel.		A turnstile, rail or another kind of pedestrian control is the only path of travel.
1133B.2.2	The door is too narrow.	4.13.5	The door is too narrow.
		4.13.6 and Fig 25(a)	The inside latch side clearance is too narrow.
		4.13.6 and Fig 25(b)	The Inside landing width is too narrow.
		4.13.6 and Fig 25(b) and Fig 25(c)	The outside landing length is too shallow.
		4.13.6 and Fig 25(a)	The outside latch side clearance is too narrow.
		4.13.6 and Fig 25(b)	The outside landing width is too narrow.
		4.13.2	A turnstile is an entrance.
		4.13.7	The doors in this vestibule swing towards each other.

Overlapping	28
Unique CBC	21
Unique ADA	9
Total Unique	30
Total Combined	58

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Questions? Call us at 866 982 3212 x2 or email us at help@accesssolutionllc.com