Printed from the blog of Lori Greene, AHC/CDC, CCPR, FDAI
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Email: lori_greene@allegion.com, Blog: www.idighardware.com or www.ihatehardware.com


Mar 30 2012

Decoded: Flush Bottom Rails (April 2012)

Category: Accessibility,DHI,Doors & FramesLori @ 12:48 pm Comments (27)
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This post was printed in the April 2012 issue of Doors & Hardware

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

The 2010 ADA Standards for Accessible Design (available for download at www.ada.gov) officially went into effect on March 15, 2012. The requirement for a 10-inch-high flush bottom rail on manual doors is now included in the ADA standards. Previously, it was not included in the ADA standards but was a requirement of ICC A117.1, Accessible and Usable Buildings and Facilities. These standards are applicable to doors that are required to be accessible.

The text of both standards is very similar, except that the ADA addresses existing doors. Here is the section from the ADA standards:

404.2.10 Door and Gate Surfaces. Swinging door and gate surfaces within 10 inches (255 mm) of the finish floor or ground measured vertically shall have a smooth surface on the push side extending the full width of the door or gate. Parts creating horizontal or vertical joints in these surfaces shall be within 1/16 inch (1.6 mm) of the same plane as the other. Cavities created by added kick plates shall be capped.

EXCEPTIONS:

1. Sliding doors shall not be required to comply with 404.2.10.

2. Tempered glass doors without stiles and having a bottom rail or shoe with the top leading edge tapered at 60 degrees minimum from the horizontal shall not be required to meet the 10 inch (255 mm) bottom smooth surface height requirement.

3. Doors and gates that do not extend to within 10 inches (255 mm) of the finish floor or ground shall not be required to comply with 404.2.10.

4. Existing doors and gates without smooth surfaces within 10 inches (255 mm) of the finish floor or ground shall not be required to provide smooth surfaces complying with 404.2.10 provided that if added kick plates are installed, cavities created by such kick plates are capped.

This requirement appears in the “Manual Doors” section of both publications, so it does not apply to automatic doors. The purpose is to avoid creating a projection that could catch a cane, crutch, walker, or wheelchair and inhibit passage through the door opening, so the requirement applies to the push side of the door only. The 10-inch measurement is taken from the floor or ground to the top of the horizontal bottom rail, extending the full width of the door. Prior to the 2003 edition of A117.1, the required dimension was 12 inches, versus the 10 inches required by today’s standards.

The 10-inch-high space must have a smooth surface, so bottom rods and latches of surface-mounted vertical exit devices, kick-down and plunger holders, surface bolts, automatic door bottoms, and full-height door pulls would not meet the intent of this requirement. This also affects the door’s bottom rail, the top of which must be at least 10 inches above the floor. If kick plates are added to create a wider bottom rail, the space between the top of the kick plate and the glass must be capped, and the joints between surfaces are limited to a 1/16-inch variation in plane.

Tempered glass doors with no vertical stiles and a tapered bottom rail do not have to meet the requirement for a 10” bottom rail, although they are still subject to the prohibition on projections. Sliding doors and doors that do not extend to within 10 inches of the floor are exempt from the flush bottom rail requirement. As outlined in the ADA, existing doors are not required to provide the 10-inch smooth surface, but if kick plates are added to widen the bottom rail, the gap between the top of the plate and the glass must be capped. This is not addressed by A117.1, which is typically used for new applications as referenced by the International Building Code.

Now that the standards are consistent, expect to see increased awareness and enforcement of this requirement. And if the wider bottom rail results in a wider top rail and stiles, you won’t hear me complaining!

This post was originally created on March 20, 2009, and was updated to include the 2010 ADA standards and printed in the April 2012 issue of Doors & Hardware magazine.

27 Responses to “Decoded: Flush Bottom Rails (April 2012)”

  1. B says:

    I hope this is enforced, and as for the 60 degree angle on glass doors I have only seen that bottom rail in the catalog never on a job so maybe that will change as well.

  2. Bob Caron says:

    So, are surface vertical bottom rods a thing of the past, or can you use those rod protectors like Von Duprin LGO-3 and LGO-4?

  3. Jamo Ladd says:

    Thank you Lori. I do appreciate all of your updates and other post

  4. leftcoastpdx says:

    So, no more surface mounted automatic door bottoms, it would seem to me. Who needs ’em?

  5. SK says:

    Lori,

    Thank you for the excellent info. I am an architect working on a project in NYC.

    You say above “This requirement appears in the “Manual Doors” section of both publications, so it does not apply to automatic doors.” Does a power operated door count as an automatic door? If I have two doors at an entrance area, one of which is power-operated with a wall panel, would it be acceptable to have a 5″ bottom rail on both doors?

  6. SK says:

    Thank you very much, Lori. Both, your response here and the responses at the Codes Forum are helpful and much appreciated. Following the logic expressed, it would seem that if both the swing doors were to be made ‘automatic’ (power operated), we could have 5″ rails on each while meeting the accessibility requirements. Would you agree with that?
    Thanks again!

    • Lori says:

      It looks like most of the AHJs on the Building Code Forum would like to see a 10″ bottom rail on the manual door, but yes – if both were automatic you could have 5″ stiles on both.

  7. Brian says:

    I have been told that states adopt their own ammendments to this code, which leads to the statement of one of my associates that NC only requires 7 1/2″ bottom rail for storefront doors. Is this correct?

    • Lori says:

      Hi Brian –

      Some states do develop their own accessibility standards and there is a process to have the state’s standards approved by the US Access Board. In Massachusetts, where I live, we have 521 CMR which is our state accessibility guideline, and there is not requirement for a flush bottom rail of any height. I’m not sure what happens when someone challenges an installation because it is not compliant with the ADA, since the ADA is a federal law. So there is definitely the possibility that local requirements are different, but you can sometimes end up in a situation where the codes conflict. I saw this recently in the State of Illinois vs. City of Chicago building and fire codes, regarding a fatal fire.

      – Lori

  8. Michael says:

    I appreciate the article and am curious about the commentary / rational for this requirement.

    “The purpose is to avoid creating a projection that could catch a cane, crutch, walker, or wheelchair and inhibit passage through the door opening, so the requirement applies to the push side of the door only.”

    For the typical door thickness of 1-3/4″, how much of a projection from the face of the door creates this ledge condition that could catch a cane crutch or walker? What study test or procedure has lead to this finding that at lease 12″ or 10″ or 7 1/2″ or some other arbitrary number will prevent this from impeding those with disabilities from navigating door openings? What finding allows for the exception of a slope of no less than 60 deg from horizontal at heights less than 10″ above floor finish for all glass entries with bottom rails of 1″-6″ high?

    I could be wrong, but I don’t believe there are any and I don’t believe there is anyway for mfrs to prove that products they make are not hazardous for not being in compliance with these profile restrictions. Many glass office fronts and glass entry systems still do not comply.

    • Michael says:

      Is 1/16 (.0625) inch really a maximum projection off the face of the door? It seems to me that a kick plate could be thicker material than this… Are we not allowed to install kick plates less than 10″ tall? 14 Gage material = .0625″

      • Lori says:

        The most common kick plate thickness is .050″ so technically it would not create a change in plane of more than 1/16″.

  9. michael says:

    Thanks for the reply, but my question was more rhetorical… Btw there are 14 ga. kick plates available. My point is really that this maximum 1/16″ ledge is not a scientific conclusion.There is no test method or procedure to demonstrate efficacy for this rule. If there is no data to support this there should be no restriction, but someone has sued someone else and so we end up with this nonsense. Why do door hardware manufacturers not challenge this? For instance Teknion Optos w/framed glass door option or Blumcraft door series 1301 or Doralco Slimline door rails all are all products which appear not ADA compliant as a result of a strict interpretation of this rule or are we to use a custom 60 deg slope top cladding for these products? Why not apply a fillet bead of clear silicone “only on the push side” to make the profile compliant? Now that ANSI 117.1 ADAAG and IBC are “coordinating” accessibility requirment better- which is a good thing, I would hope they could think through this a bit more.

    • Lori says:

      I know that there are 14 gauge kick plates…I’ve even seen 1/4″ steel plate bolted to a door face as a kick plate, and other variations on the theme. In my experience with code development, once something is in a code or standard you’d need to prove why it shouldn’t be there and it’s very difficult to get this type of change approved. The ADAAG and A117.1 committees probably wouldn’t “think through this” on their own, but you could certainly propose a code change if you have sound reasoning that might be convincing to the committee.

  10. Laurie says:

    I am completely and utterly confused with regard to the requirement for a 10″ bottom rail height. Please explain once and for all under what circumstances is a 10″ bottom rail height required. Per 404.2.10, ” . . . Swing door and gate surfaces within 10″ of the finish floor or ground measured vertically shall have a smooth surface on the push side extending the full width of the door or gate”. I interpret this to mean that anything up to 10″ from the finished floor is to be smooth (with no “interruption” or projection); and as long as it is smooth, a height less than 10″ is OK. Is this correct, or have I completely misinterpreted the statement?

    Also, “This requirement appears in the ‘manual doors’ section of both publications, so it does not apply to automatic doors”. Does this mean that if a door is auto operated, or has the option of being operated automatically, it is NOT required to also have a 10″ bottom rail? Does the auto operation alone allow the door to meet the ADA requirement?

    I have been led to believe that all exterior entrance doors MUST have 10″ bottom rails to be ADA compliant. If this is incorrect, please provide a clear statement regarding the circumstances under which a 10″ bottom rail is required. Thank you for your help!!

    • Lori says:

      Hi Laurie –

      This requirement is in the section for manual doors, so it applies to manual doors on an accessible route. It doesn’t apply to automatic doors.

      The door needs to have a smooth surface for 10″ above the floor, on the push side. The top of the bottom rail has to be at least 10″ above the floor or ground. If the door has a bottom rail that’s less than 10″ above the floor, a kick plate can be added to provide the smooth surface, but the space between the top of the kick plate and the glass has to be capped.

      There can be no projections off the face of the door in the space between the floor and 10″ up on the push side. Kick-down stops, surface-vertical rods, surface auto door bottoms, surface bolts, and full length pulls are all hardware that would normally project in this area and would be in conflict with this requirement.

      There are exceptions – all-glass doors with no vertical stiles and a bottom rail that tapers back to the glass at a 60 degree angle are exempt from the 10″ height but are not allowed to have projections. If the door doesn’t come within 10″ of the floor, it is exempt. Sliding doors are also exempt.

      Does that help?

      – Lori

  11. Dawn says:

    In the case of an exempt tempered glass door, does the bottom rail need to be continuous across the entire door with a tapered, 60 degree minimum, top leading edge? Or can you use patch fittings that are not continuous across the entire door? It would seem that the patch fittings would not meet the requirement for vertical joints in the bottom surface to be within 1/16″. A patch fitting would create a vertical joint that would be about 3/4″.

  12. Draddle says:

    Very informative site. Is the 10″ requirement for interior doors with a “full view glass” or just egress doors to the exterior?

    • Lori says:

      The 10″ requirement applies to manual doors on an accessible route. Doors that are not “full glass” / storefront would meet the bottom rail requirement easily, but they would also have to have no projecting hardware in that 10″ area.

  13. Jim says:

    Has this code been enforced anywhere? We are still using SVR panics with bottom rods all the time, and we have not run into any issues. Additionally, we frequently use auto door bottoms. These things seem to go in waves of being enforced. for the longest time, the 43″ visible lite code just was never enforced, and then all of the sudden it was like all of the inspectors got together and decided that was the new code to check on. I just don’t want to get burned on this one.

    • Lori says:

      Yes, I have seen it enforced. Both the 10-inch flush bottom and the lite location were recently added to the ADA standards. Previously they were in ICC A117.1 but not in the ADA. I think we will see wider enforcement now.

  14. John says:

    So, all common doors in an apartment building cannot be a 6-panel type? The panels end approx. 9″ above finish floor. They do not project. Only an 8″ kick plate can be used on panel doors, because a 10″ would cause a gap at the panels. I have found no product to “cap” the gap created.

    • Lori says:

      That’s a REALLY good question, and it depends on which accessibility standard the doors are required to meet. The Fair Housing Act allows any of 10 sets of guidelines to be used. Some of them include the 10″ requirement, some do not.

      This is from the Fair Housing Act Design Manual: “Doors to Covered Units. Doors to adaptable (or covered) dwelling units must meet ANSI 4.13 on the exterior or public and common use side, but need only meet Guidelines Requirement Three: Usable Doors on the inside. See Chapter 3: Usable Doors.” But there is no mention of the 10″ flush bottom rail in the manual. I checked the 1986 edition of A117.1, which is referenced by the Design Manual, and it does not include the 10″ requirement. I think the 1992 edition was the first to include a 12″ flush bottom requirement and then it went to 10″ in the 1998 edition.

      So if the accessibility standard for a particular project is the 1986 A117.1, an addition of the ADA prior to the 2010 edition, or a state standard that doesn’t have this requirement (like Massachusetts), then the 10″ requirement probably doesn’t apply. If a current standard is being enforced, then the 10” requirement would apply to the corridor side of the doors.

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