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Aug 05 2011

Decoded: Auto Operators – Stand-By Power (August 2011)

Category: Accessibility,Automatic Operators,DHILori @ 1:35 pm Comments (8)
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This post was printed in the August 2011 issue of Doors & Hardware

[Click here to download a reprint of this article.]

I was recently asked about battery back-up for an automatic operator, after an architect noted that it was required by the 2010 ADA guidelines.  The doors in question were existing bathroom doors that did not have the maneuvering clearance required for manual doors (as described in section 404.2.4), so operators were being added.  Before I go any further I should say that the 2010 ADA guidelines do not go into effect until 2012, but apparently some facilities are already using them.

Here’s the section of the ADA that refers to automatic doors:

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.

Translation:

404.3 – This paragraph refers to two different ANSI standards depending on which type of operator is used.  These standards contain additional information such as requirements for safety devices, signage, opening force, and closing speed.  Full-power operators, sometimes called high-energy operators, are the type that you might see on a grocery store entrance.  Low-energy operators are often used on an accessible entrance or bathroom door, and typically have a push button actuator.  Power-assisted doors require the user to push or pull the door and the operator reduces the opening force required to operate the door.  This is different from the “push-n-go” feature on a low-energy operator which is completely automatic once the door is pushed or pulled slightly.

404.3.1 – According to the accessibility standards and also the egress requirements, most doors have to provide at least 32″ of clear opening width.  If it’s a pair of doors, at least one leaf has to provide 32″ clear.  This paragraph states that 32″ of clear opening width must be provided “in power-on and power-off mode.”  In some instances, I have seen a code official allow the use of auto operators on a pair that didn’t have one leaf providing 32″ clear.  I saw one of these just the other day on a 4′-wide pair.  The building was a historic house that had been turned into offices, and the auto operators created a 4′ wide (nominal) opening when the doors were operated automatically.  When I originally read paragraph 404.3.1, I thought it meant that automating a narrow pair wouldn’t be an option any longer, but the last sentence seems to state that the full width of the opening would be considered, so I think this would still be an acceptable solution.

404.3.2 – Section 404.2.4 is the part of the ADA that talks about maneuvering clearance – the space around the door that someone using a wheelchair needs in order to be able to operate the door manually.  Paragraph 404.3.2 says that power-assisted doors and gates have to have the same maneuvering clearance as manual doors, which makes sense because the doors are basically operated manually but require less force.  The next sentence says that doors without standby power would also need the required maneuvering clearance.  Therefore, doors WITH standby power do not need the maneuvering clearance.  If an existing door serving an accessible means of egress does not have the required maneuvering clearance and an auto operator is added to overcome that problem, the operator needs standby power (unless the door stands open on power failure per the exception).  In my opinion, if an accessible bathroom has the required maneuvering clearance on the inside (egress side) but does not have the required maneuvering clearance on the outside, standby power shouldn’t be needed because the door provides an accessible means of egress without the operator.  You don’t have to let people into the bathroom in an emergency (unless it’s a bathroom emergency).  Of course, the AHJ has the final say on that.  In the example used for this post, the maneuvering clearance problem is on the egress side, so the standby power is required if the 2010 ADA is being used.

Keep in mind that fire-rated doors with automatic operators are required to be deactivated upon fire alarm, so in my opinion an automatic operator with battery back-up can not be used on a fire-rated door to overcome the maneuvering clearance problems.  

Here is some additional information from the DOJ’s guidance document:

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.

Still with me??  Here’s a link to a back-up power supply that may work depending on the requirements of a specific auto operator, and here’s a link to a discussion about this issue on the Advanced Code Group discussion forum.  If you know any automatic door gurus, pass this post along and see if they have any additional info to add.

Thank you to SAS Architects for the use of the photos and floor plan, and to John Gant of Ingersoll Rand Security Technologies for bringing the issue to my attention.

UPDATE:  Check the comments for some discussion about the fire door conflict.

This post was originally created on April 5, 2011, and was printed in the August 2011 issue of Doors & Hardware magazine.

8 Responses to “Decoded: Auto Operators – Stand-By Power (August 2011)”

  1. Roger Black says:

    What about the conflict of having an low energy operator on an egress door with inadequate maneuvering room that is also a fire door? ADA mandates back up power to the operator during emergency (which a fire alarm condition certainly is) and NFPA mandates that the operator be disabled in a fire alarm condition.

  2. Joe Proser says:

    Roger/Lori, in general it seems that fire rated openings must comply with fire-codes over accesibiility codes. I would think in the rare instance that this might come up, using an automatic operator to overcome maneuvering components of ADA would not be allowed at a fire-rated opening. The opening would have to be redesigned.

    However, automatic sliding fire shutters in a path of egress are required to have battery backup. I would imagine that these backup systems must have some type of heat sensor that would disconnect power at some point. You certainly wouldn’t want the backup system to malfunction and open the door.

    • Lori says:

      That’s exactly right, Joe, and you beat me to it! An auto operator on a fire door has to be deactivated on fire alarm, and an auto operator used in lieu of maneuvering clearance on an accessible door needs to be on standby power. Although the accessibility code doesn’t specifically say that the operator can’t be deactivated by the fire alarm (you could squint and read the standby power requirement as during power failure only), I think the intent of the ADA requirement would require the operator to work during a fire alarm. It’s a direct conflict. If the AHJ wouldn’t allow a variance of some sort, the rated door opening would have to be re-worked so the proper maneuvering clearance is provided.

  3. Jess says:

    hello Lori, from what I read, it sounds to me that they will be “retiring” the closers on the 2 doors in the bathroom and be installing auto operators in their place??

    it’s sad to me since I hate when the codes take away cheractor of a building that has historic hardware on it (such as the 2 closers on the doors)

    I know its to make life easier for those who cannot push a door open that has a strong springed closer (such as the 2 in the photos, even with the hold open on the inner door) but I still think they (ADAAG codes panel) need to think about historic buildings and try to adapt their operators or devices to try to counterbalance the tension (make door feel lighter to pull or push, allowing a vintage closer still pass ADAAG guidelines and remain in place)

    (the hold-open doohickey used for that door is actually a part of the closer and the closer’s main arm,the device used looked like a band that goes around the top of the (non-IR product) closer along with a ball bearing in the arm (detent hold open)

    best placement of a traditional closer (if you like keeping things original in a historic building) is best done on doors that dont have to fall within the guidelines of ADAAg because of the spring. (migrate them old traditonals to different doors that wheelchair users arent required to use)

    another way to combat this because of the nature of how a these old closers work, (i have one of these and mine freeswings) being these 2 closers are traditionals, its easy to make them “freeswing” (no spring tension pulling on door) all you have to do on (this brand, NON-IR) closer is with a hook wrench, turn gear thing alittle and remove peg and let the gear slide past the stop on top of the closer (unwind the spring) and then install the power operator on the push side of these doors. (keeps character of building, and closers stay in place and can be seen from inside the bathroom without seeing the openers)

    another option, go with a dor-o-matic invisible doorman(I’m sure they are not made anymore, or are obsolete, plus they are a pain to install because of how they work, they use pumps and fluid reservoirs, pump controls flow of fluid controlling door. (they may be available in Canada…who knows)

    sorry if that was a long one Lori, just helping to keep the traditionals were they belong while helping the building stay within the new codes. if possible, can you forward my idea to the contractor in charge of this building’s upgrading (SAS contracting or john Gant???)

    I will be more then happy to help deal with making the traditionals code compliant while staying put on the doors.

    -Jess the door(closer)doctor

  4. Rod Ishizu, AHC says:

    Lori,
    Under 2007 California Building Code Section 1133B.2.5 Door opening Force under exceptions paragraph 2b states: powered doors serving a building or facility with an occupancy of 150 or more shall be provided with a back-up battery or back-up generator. The back-up power source shall be able to to cycle the door a minimum of 100 cycles.
    This would qualify for one of the “Stand-By Power” requirements.

  5. Mark Lineberger says:

    Interesting new requirement twist. Been down this road before on the battery back-up issue. Same issue has always applied for fire-rated openings.

    The challenge for battery back-up is where the power source comes from and “packaging”. The best opportunity is connection to a facility generator where operators would be part of the facility “life-safety” power system. Where not feasible or available, a separate UPS (similar to your posted link) will work, assuming it is sized properly (number of cycles needed/required based on electrical load for all components, etc…). An added benefit is electrical spike protection. Virtually all of these types of UPS devices include this. Why is this good? With all of the electronic controls and processors used on automatics now a UPS will protect those components from nasty electrical gremlins. If you really want to make the UPS easy to maintain (’cause those batteries don’t last forever!), depending on the UPS model capabilities, you can connect the UPS to the computer network and they will send “alarms” indicating what the problem is so it can be addressed.

    As far as fire-rated openings, the doors simply cannot be held open. Meaning the ever-present hold open switch would need to be disabled. This could happen any number of ways, but the most important thing to keep in mind is AHJ acceptance. That cannot happen without a well thought out description of operation and then demonstration prior to final inspection (just in case someone changes their mind, or someone else shows up!). Removing power is the typically used – and easiest – way to meet the closing requirement. I would argue that it is not the most user-friendly or equipment-friendly method (think about why operators are installed, especially low energy ones), and now it appears there will be language requiring continued operation. My question is: How long are these supposed to remain functional? Time, number of operations, a combination? That directly effects product choices, design, and costs.

    I would love to see more operator manufacturers include a fire alarm input on their controllers to address this issue. It is done on plenty of other electronic controls and would simplify the problem with hold open switches. It would also prevent screwing up operator controls every time power gets yanked. Bottom line is – to me anyway – this can be successfully done today without costing really that much.

  6. Ferdinand Bautista says:

    Our Accessibility Commission requires that even low energy operated doors with battery standby power needs to have maneuvering clearances since the back up power can die. The project is renovation and I disagree with this requirement as it addresses the worst case scenario. Why even have a push button automatic door opener if you still need the maneuvering clearance? It seems to defeat the purpose.

    • Lori says:

      Is that based on an actual written requirement or just a preference? I think California may have a similar requirement.

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