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


Jun 25 2013

Decoded: Tactile Warning (June 2013)

This post was printed in the June 2013 issue of Doors & Hardware

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

Question:  Am I required by code to provide a tactile warning on certain doors in my facility?  If tactile warning is required, are stair doors included?  What types of materials are allowed for tactile warning on doors?

Answer:  The 1986 edition of ICC A117.1 (which was then called Providing Accessibility and Usability for Physically Handicapped People – now called Accessible and Usable Buildings and Facilities) included a requirement for tactile warnings on doors leading to hazardous areas.  The intent was to provide a warning to a person who is blind that the door leads to a room where they could encounter something dangerous.  Examples of hazardous rooms included loading docks, boiler rooms, and stages – other standards include electrical and mechanical rooms on the list of examples.

While I have seen some state standards (including Massachusetts) which still contain a requirement for tactile warning on doors leading to hazardous areas, there has been no requirement for this in ICC/ANSI A117.1 since 1992.  The Uniform Federal Accessibility Standards (UFAS) does contain a requirement for tactile warning, but this standard has for the most part been replaced by the 2010 ADA Standards for Accessible Design.  The 1991, 1994, and 2010 ADA standards do not include a requirement for tactile warning on doors leading to hazardous areas – the section heading is “reserved” in the earlier editions and does not appear at all in the 2010 edition.  So the jurisdictions that require tactile warning on doors to hazardous areas are quite limited.

Where a tactile warning is required, typically either knurled levers or an abrasive material is acceptable.  I have often seen abrasive tape applied to the back of a lever to meet the requirements in my home state of Massachusetts.  Because the types of rooms considered hazardous are not specifically defined, it’s difficult to know where the Authority Having Jurisdiction will require a tactile warning, and abrasive tape can be a good solution in this case.

The question of whether or not to provide knurling or an abrasive coating on stair doors is an interesting one.  The thought behind this practice is that someone who is blind could fall down the stairs, but my concern would be that someone who is blind might not enter the exit stair because they believe that the door leads to a hazardous room.  This would be especially true if the stair door was equipped with a lever handle.  For stair doors with fire exit hardware, I have heard of some AHJs requiring abrasive tape as a tactile warning on the touchpad.  Again, I think this could discourage someone who is blind from using the exit.  I think a much better solution for those jurisdictions would be tactile lettering and/or braille on the touchpad of the exit device, indicating that the door leads to a stair.  The tactile signage now required for stair doors will also help to prevent someone from unknowingly entering a stair.

Some of the confusion about tactile warning on stair doors may come from sections from the standards addressing “Detectable Warnings.”  The original ADA guidelines include two reserved sections with the headings “Detectable Warnings at Stairs” and “Detectable Warnings on Doors to Hazardous Areas.”  This could lead to the belief that detectable warnings are the same (tactile hardware) for both applications.

Detectable warnings are defined by the 2009 edition of A117.1 and the 2010 edition of ADA-ABA as “A standardized surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.”  They are raised domes in the walking surface, and they’re typically only required at transportation platform edges and similar changes in level.  In standards that require detectable warnings for stairs, there is typically an exception for dwelling units as well as for enclosed stairs, so the raised domes in the flooring would typically apply to open stairs with no doors.

To summarize:

  • The prevalent accessibility standards currently used in the U.S. (ICC A117.1 and the ADA-ABA guidelines) do not require tactile warning on doors leading to hazardous areas.
  • The last time either of these standards did include this requirement was the 1986 edition of ICC A117.1.
  • These standards do not include a requirement for stair door hardware to have a tactile warning.
  • Applying a tactile warning to stair doors could prevent a person who is blind from accessing the exit.
  • “Detectable Warnings” required by some codes and standards are typically raised domes in the flooring.
  • Some state or local standards may require tactile warnings on certain doors.
  • Where tactile warnings are required, knurling or an abrasive tape/coating should be acceptable unless the requirements or the AHJ require a specific method of creating the tactile warning.

Here are excerpts from the standards regarding tactile warning:

1986 edition of A117.1 (this section was removed in the 1992 edition):

4.27.3* Tactile Warnings on Doors to Hazardous Areas. Doors that lead to areas that might prove dangerous to a blind person (for example, doors to loading platforms, boiler rooms, stages, and the like) shall be made identifiable to the  touch by a textured surface on the door handle, knob, pull, or other operating hardware. This textured surface may be made by knurling or roughening or by a material applied to the contact surface. Such textured surfaces shall not be provided for emergency exit doors or any doors other than those to hazardous areas.

4.27.4 Detectable Warnings at Stairs. All stairs, except those in dwelling units, in enclosed stair towers, or set to the side of the path of travel shall have a detectable warning at the top of stair runs (see Fig. 41).

1991 and 1994 Editions of the Americans With Disabilities Act (ADA) Guidelines:

4.29.3 Detectable Warnings on Doors To Hazardous Areas.  (Reserved).

4.29.4 Detectable Warnings at Stairs.  (Reserved).

Uniform Federal Accessibility Standard (UFAS):
Note: This standard has very limited usage currently, but the text is included for historical reference.

4.29.3* TACTILE WARNINGS ON DOORS TO HAZARDOUS AREAS. Doors that lead to areas that might prove dangerous to a blind person (for example, doors to loading platforms, boiler rooms, stages, and the like) shall be made identifiable to the touch by a textured surface on the door handle, knob, pull or other operating hardware. This textured surface may be made by knurling or roughing or by a material applied to the contact surface. Such textured surfaces shall not be provided for emergency exit doors or any doors other than those to hazardous areas.

A4.29.3 TACTILE WARNINGS ON DOORS TO HAZARDOUS AREAS. Tactile signals for hand reception are useful if it is certain that the signals will be touched.

4.29.4 TACTILE WARNINGS AT STAIRS. (Reserved).

This post was originally created on September 25, 2012, and printed in the June 2013 issue of Doors & Hardware magazine.

One Response to “Decoded: Tactile Warning (June 2013)”

  1. Jerry Austin says:

    I am always a bit amused by some requirements in terms of practicality and my observations of 35 years in three, large hospital complexes. I have yet to see a person with limited or no sight feel their way along the corridors, trying to find a tactile sign so they have some concept of where they are located in the structure. It just does not happen. A sighted person is either with them when they arrive or a staff member immediately goes to help them if they are dropped off say by a taxi. The stacked corridor and multipath nature of large hospital buildings makes the requirement non-functional. I suspect the basis for the requirement for tactile signs is well intentioned but it is really not useful due to the many parallel and intersecting corridors. The same is true for door handles and I totally agree that if somehow a sightless person were alone during a fire, you would want them to enter the stairwell. In that case the tactile sign next to the stair enclosure would be significant and the tactile surface on a stair enclosure door would be misleading.

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