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


Sep 20 2012

Q&A: Mounting Height for Glass Lites

Category: Accessibility,Glass,Q&ALori @ 1:43 pm Comments (27)
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Question:  Is there a requirement for the location of a glass lite in a door or sidelite?

Answer:  Yes!  For many years there has been a requirement in ICC A117.1 – Accessible and Usable Buildings and Facilities, which is referenced by the International Building Code and other publications.  If a door has a vision lite or a sidelite, at least one lite has to be installed with the bottom of the lite no more than 43″ above the floor.  This does not mean that every door is required to have a vision lite or sidelite, but if there is a lite, it must be located where someone using a wheelchair can see through it.

There is an exception in A117.1 for doors that have a lite with the bottom edge more than 66″ above the floor.  An example of this would be the 6-panel residential entrance doors with lites in the top two panel locations.  Because these lites are too high to look through and are there for aesthetics or light transmission, doors with this configuration are not required to comply with the 43″ height requirement.

The 2010 edition of the 2010 ADA-ABA Accessibility Guidelines (effective 3/15/12) includes the same requirement as A117.1.  This requirement was not in the previous edition of the ADAAG.

Here is the text from the 2009 edition of A117.1:

2009 A117.1: 404.2.10 Vision Lites. Doors and sidelites adjacent to doors containing one or more glazing panels that permit viewing through the panels shall have the bottom of at least one panel on either the door or an adjacent sidelite 43 inches (1090 mm) maximum above the floor.

EXCEPTION: Vision lites with the lowest part more than 66 inches (1675 mm) above the floor shall not be required to comply with Section 404.2.10.

And from the 2010 ADA-ABA standard:

404.2.11 Vision Lights. Doors, gates, and side lights adjacent to doors or gates, containing one or more glazing panels that permit viewing through the panels shall have the bottom of at least one glazed panel located 43 inches (1090 mm) maximum above the finish floor.

EXCEPTION: Vision lights with the lowest part more than 66 inches (1675 mm) from the finish floor or ground shall not be required to comply with 404.2.11.

The door on the left below would not comply with the lite height requirement (it may not have been mandated depending on when the door was installed and what code was used).  The photo on the right shows how a compliant door might look.  As you can see, you need to watch out for lite/lock conflicts when the 43″ height is used.

 

 

27 Responses to “Q&A: Mounting Height for Glass Lites”

  1. Nathan Langley says:

    The 66″ exception would also apply to the 10 x 10 vision lite that may be allowed depending upon fire rating as well, correct? Or will we start seeing these small lites in the middle of the door now?

    • Lori says:

      Hi Nathan –

      The typical mounting height for a 10 x 10 lite would not meet the criteria for the exception, because the bottom edge has to be more than 66″ above the floor. I don’t think the 10 x 10 lites were installed that high.

  2. Ron Hansen says:

    It is my opinion that in the future we will be seeing narrow vision lites moved lower and more towards the center of the door, away from the lock edge, in order to comply with ADA requirements, and at the same time, avoiding lock/lite conflict.

    • Lori says:

      That would make a lot of sense and avoid a lot of headaches. I wonder how many years it will take for the standard location to move to the vertical centerline of the door.

  3. Jack Ostergaard says:

    And then there is IBC 715.4.7.1 which limits size to 100 sq in with a max dim of 10″ effectively eliminating the slit window from rated doors.

    • Lori says:

      Hi Jack –

      The 10″ limitation is specific to fire doors in fire walls, which are not that common. It doesn’t apply to fire doors in fire barriers or fire partitions. I think we will see more 3″ x 33″ lites than 4″ x 25″ because of the 43″ requirement.

      – Lori

  4. Mike Quinn says:

    Is Mass. CMR 521 also consistent with the current ICC and ADA requirements?

    • Lori says:

      The only place I’ve seen a similar requirement in 521 CMR is in the transient lodging section:

      8.00: TRANSIENT LODGING FACILITIES
      8.5.5 Visitor Identification: Every entry door to each accessible unit shall have a means by which the person can visually identify a visitor before opening the door. This may be achieved by any of the following means:
      a. A peephole mounted at 42 inches (42″ = 1067mm) above the floor;
      b. A vision panel in the door with its bottom edge no higher than 42 inches (42″ = 1067mm) above the floor
      c. A sidelight with its bottom edge no higher than 42 inches (42″ = 1067mm) above the floor.

  5. Stephen says:

    What is the solution for fire doors for a combination of IBC and ADA? This happens all the time in commercial construction, it is not rare. IBC can’t have greater than 10″ dimension or greater than 100 sq in. ADA has to be bottom of light at 43″ or lower, or 66″ or higher. Either of these per ADA puts the door light too high or too low for most people to use as intended so you can see through and not open the door in someone’s face on the other side… Does IBC allow two smaller door lights?

    • Lori says:

      Hi Stephen –

      Sorry for the delay…for some reason your comment wasn’t sent to me by email so I didn’t see it until now. I think this is the IBC section you’re referring to:

      715.4.7.1 Size limitations. Fire-protection-rated glazing used in fire doors shall comply with the size limitations of NFPA80.
      Exceptions:
      1. Fire-protection-rated glazing in fire doors located in fire walls shall be prohibited except where serving in a fire door in a horizontal exit, a self-closing swinging door shall be permitted to have a vision panel of not more than 100 square inches (0.065 m2) without a dimension exceeding 10 inches (254 mm).
      2. Fire-protection-rated glazing shall not be installed in fire doors having a 11/2-hour fire protection rating intended for installation in fire barriers, unless the glazing is not more than 100 square inches (0.065 m2) in area.

      Exception 1 does create a conflict with A117.1 and the ADA, but it only applies to fire doors in fire walls which divide a building into separate buildings. The requirement would not apply to doors in fire barriers. This section was changed in the 2012 edition of IBC…the 10″ requirement creating the conflict is still there, but it only applies to fire protection rated glazing, not fire resistance rated glazing.

      716.5.8.1 Size limitations. Fire-protection-rated glazing shall comply with the size limitations of NFPA 80, and as provided in Sections 716.5.8.1.1 and 716.5.8.1.2. 716.5.8.1.1 Fire-resistance-rated glazing in door assemblies in fire walls and fire barriers rated greater than 1 hour. Fire-resistance-rated glazing tested to ASTM E 119 or UL 263 and NFPA 252, UL 10B or UL 10C shall be permitted in fire door assemblies located in fire walls and in fire barriers in accordance with Table 716.5 to the maximum size tested and in accordance with their listings.
      716.5.8.1.2 Fire-protection-rated glazing in door assemblies in fire walls and fire barriers rated greater than 1 hour. Fire-protection-rated glazing shall be prohibited in fire walls and fire barriers except as provided in Sections 716.5.8.1.2.1 and 716.5.8.1.2.2.
      716.5.8.1.2.1 Horizontal exits. Fire-protection rated glazing shall be permitted as vision panels in self-closing swinging fire door assemblies
      serving as horizontal exits in fire walls where limited to 100 square inches (0.065 m2) with no dimension exceeding 10 inches (0.3 mm).
      716.5.8.1.2.2 Fire barriers. Fire-protection-rated glazing shall be permitted in fire doors having a 1 1/2-hour fire protection rating intended for installation in fire barriers, where limited to 100 square inches (0.065 m2).

      • Stephen says:

        Thanks for a quick reply.

        However, as a complication, we have local codes in many cities where we do work that are still on 2006 or 2009 IBC, so we have multiple versions of building code out there still in effect. Therefore, and although admittedly I haven’t checked this recently, I believe both cases of doors in fire barriers and fire walls could apply depending on the model code we are under. But there is only one ADA (or equivalent adopted state versions) now in effect, which doesn’t care what version of IBC we are under.

        I don’t know a solution to either case that is functional while simultaneously meeting both the IBC for 100 sq in vision lights (per various year model codes) and ADA? Unless of course if IBC can be interpreted to allow 100 sq in of vision light in TWO small vision panels, perhaps totaling less than 100 sq in (one for someone standing and one lower for wheel-chair bound)? The problem is, IBC says “permitted to have A vision panel…”, not “permitted to have one or more vision panels…” or something to that effect?

        So by combination of IBC and ADA, are we forced into fire protection glazing for lower rated doors, and doing away with vision lights altogether for higher rated doors?

        The only other “solution” is a vision light at 66″ or higher (as an exception allowed by ADA not to have a vision light at 43″). However that is too high (for the standing height of 95%+ of Americans) to serve the intended purpose to see through and not open the door in someone’s face…

        • Stephen says:

          Or excuse me, I think I mean fire resistance rated glazing above.

        • Lori says:

          This is from the 2006 IBC:

          715.4.6 Glazing material. Fire-protection-rated glazing conforming to the opening protection requirements in Section 715.4 shall be permitted in fire door assemblies. 
          715.4.6.1 Size limitations.Wired glass used in fire doors shall comply with Table 715.5.3. Other fire-protection-rated glazing shall comply with the size limitations of NFPA 80.
          Exceptions:
          1. Fire-protection-rated glazing in fire doors located in fire walls shall be prohibited except that where serving as a horizontal exit, a self-closing swinging door shall be permitted to have a vision panel of not more than 100 square inches (0.065 m2) without a dimension
          exceeding 10 inches (254 mm).
          2. Fire-protection-rated glazing shall not be installed in fire doors having a 1 1/2-hour fire protection rating intended for installation in fire barriers, unless the glazing is not more than 100 square inches (0.065 m2) in area.

          The 10″ limitation applies to glazing in fire doors in fire walls – not typical fire doors.

          NFPA 80 limits glazing in 3-hour fire doors to 100 square inches, but does not limit any dimension to 10 inches. A 3″ x 33″ lite could meet both the NFPA 80 and A117.1/ADA requirements. For the other door ratings, NFPA 80 limits glazing to the maximum area tested, and does not limit a dimension to 10″.

          The reason the lite above 66″ doesn’t have to comply with the ADA and A117.1 mounting height requirements is because it is not meant as a vision lite – but as a way to provide light transmission through the door.

  6. Austen says:

    Is the 43″ requirement still relevant on a full vision door with a midrail? Does the top of the midrail have to be positioned in manner allowing the top lite of glass to meet the 43″ height if there is also a lite of glass below the midrail?

    • Lori says:

      Hi Austen –

      One lite has to have the bottom of the lite located no more than 43″ above the floor, so if there is a lower lite there is no requirement for the upper lite to be at any particular height.

      – Lori

  7. Perrilyn says:

    In my situation, with vision lite at 43″, the top of the panic exit device obscures the bottom of the vision lite (single door, Corbin-Russwin ED5600). Was the hardware installed incorrectly? If not, how can I prevent this obstruction while still complying with ADA requirements?

    • Lori says:

      Hi Perrilyn –

      Your question brings up a good point. If the bottom of the lite is at 43″ AFF, but there’s hardware running across it which raises the visible glass to say – 45″ AFF, I don’t think that application meets the intent of the standard.

      To avoid this, you would have to coordinate the mounting height of the panic hardware to make sure it runs below the lite location. The IBC requires operable hardware to be between 34″ and 48″ AFF so there should be enough space in the area between 34″ and 43″ AFF.

      – Lori

  8. Perrilyn says:

    That is what I thought.

    The hardware installer is claiming that the door was prepped in such a way as to prevent lowering the panic hardware. I guess I will have to be more vigilant in reviewing submittals and request that the mounting heights be shown on a sketch of the door.

    Thank you for the quick response.

  9. Jarom says:

    So is the 43″ AFF to the visible of the vision kit or to the cutout of the vision kit? I have been searching for this but can’t find an answer.

    • Lori says:

      The standard isn’t specific, but I would say the 43″ is to the visible glass because that’s what would be relevant to the person using the door.

      – Lori

  10. bill andrus says:

    A possible work around would be to put a 10″x10″ lite in the wall next to the strike side of the door. There’s no requirement for fixed window mounting height in the ADA and it would meet the 100 square inch fire code limit.

  11. Brian Zirbes says:

    We have set our default as a distributor to always recommend the use of a 3″ x 31″ visible glass with a 10″ nominal top rail on a 7′-0″ door height and side stile as well for narrow lites, this typically will cover any fire rated wood door core limits and avoids lite and lock or warranty conflicts. It is something we have in all our submittals recommending to avoid a project with inconsistent lite sizes due to different door cores throughout and those core specific limits in conjunction with specific hardware. This location also looks much better than centering a narrow lite in a door but there is still way too many plans by default that call for 4″ x 25″ or 5″ x 20″ with far too small of stiles and rails. Half and full lites we do the same top rail and at times can do a 8″ side stile to get more lite in the door but again depending on core and hardware combinations we at times need side stiles to be 10″.

  12. David Barbaree says:

    Lori is there any code requirement or standard for having to have a vision lite? It makes good sense for avoid traffic collision at the corridor but I’m not sure if there are other reasons for them.

    • Lori says:

      Hi David –

      Some of the occupancy chapters in NFPA 101 do require vision panels in each door located in a horizontal exit, and each cross-corridor swinging door and cross-corridor sliding door in a smoke barrier. I found the cross-corridor door requirement in the chapters for new health care, new ambulatory health care, and new residential board and care. I think the horizontal exit vision panel requirement was only in the chapter for new healthcare. There is also a requirement for vision panels in smoke barrier doors in the chapters for detention and correctional occupancies.

      – Lori

  13. Elle says:

    Does this standard apply to sliding glass doors? For example, if a door is a combination of opaque and clear glass, does the clear portion still have to comply with the 43″/66″ rules?

  14. Kory Beck says:

    Lori

    I am currently tasked with replacing a back door for a restaurant that has a 12×12 lite kit in it. When trying to order a new door with that lite kit I’m getting the kick back saying it’s not ADA compliant, which is keeping me from being able to do a like for like change out. Issue is, this is the same set up everywhere. All of our customers have back doors with this same set up. It leads me to ask two questions.
    1. Is there an exception I don’t know about that allows these doors to be installed? OR
    2. Does every customer I deal with just not care about what the actual requirement is?

    They don’t want a larger window on the back door due to security concerns.

    What are your thoughts?

    • Lori says:

      Hi Kory –

      That is correct – this type of light is not compliant with the accessibility standards. If a door has a vision light or sidelight, the bottom of at least one light has to be no more than 43 inches above the floor. I don’t see a lot of people replacing the existing doors solely to bring them into compliance with the accessibility requirements, but when replacing the door it should be compliant. I would use a 3″ x 33″ light so the bottom can be at the appropriate height and they will still have the security they are looking for. Another option is for the door to have no light, but that doesn’t work for every situation.

      I don’t think it’s a matter of people not caring about the requirements, I think most people aren’t aware of them.

      – Lori

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