Gate-a1I know that much of the US is beyond swimming pool season, but this question just came up again so I’ll leave it right here for you to find when you need it.

A few years ago I saw a pretty ingenious application for swimming pool gates, where the access hardware was required to be mounted at 54 inches to prevent small children from entering the pool enclosure, but the egress hardware had to be mounted between 34 inches and 48 inches above the floor.  The photos and description of that application are here.

Many of these swimming pool applications require access control, so one question is – what is the best access control application?  Electric strike?  Electromagnetic lock?  Electrified lever trim?  Please feel free to leave a comment if you have a preferred solution.

While I was looking into the access control situation, I asked the ICC for help with interpreting the 2015 IBC section that addresses the height of hardware on pool gates:

1010.1.9.2 Hardware height. Door handles, pulls, latches, locks and other operating devices shall be installed 34 inches (864 mm) minimum and 48 inches (1219 mm) maximum above the finished floor. Locks used only for security purposes and not used for normal operation are permitted at any height.

Exception: Access doors or gates in barrier walls and fences protecting pools, spas and hot tubs shall be permitted to have operable parts of the release of latch on self-latching devices at 54 inches (1370 mm) maximum above the finished floor or ground, provided the self-latching devices are not also self locking devices operated by means of a key, electronic opener or integral combination lock.

This section requires hardware (all operable hardware – not just on pool gates) to be mounted between 34 inches and 48 inches above the floor.  The exception allows hardware on pool gates to be mounted above this height, at 54 inches maximum above the floor or ground.  The part that confused me was this:  “provided the self-latching devices are not also self locking devices operated by means of a key, electronic opener or integral combination lock.“

What does this mean?  In code language it’s saying that you can’t apply the exception and mount the hardware at 54 inches above the floor if the gate has self-latching hardware that prevents unauthorized access from the outside.  It would have been more easily interpreted if the exception stated that the 54-inch mounting height is not required when that hardware is used.

Given the potential for confusion, the ICC gave me permission to post their response to my question:

ICC Staff Response:  There are two aspects to consider with locks on doors or gates providing access to a pool area – pool safety and accessibility.  Where the gate has a latch only and no lock controlling ingress, then placing that hardware at 54” above the floor decreases access to the pool by small children. Where the gate hardware also had a locking function and a key or fob would be needed to unlock the hardware to allow unlatching the latch, then the hardware can be within the accessible reach range. Access to the pool would be limited to those with a key or fob so child safety is addressed that way.

It’s pretty clear that the intent of the code was to allow the hardware on the outside of the gate to be mounted between 34 inches and 48 inches if access to the pool area is restricted to those with a key, code, or other credential.  This will likely be addressed in a future edition of the IBC and/or in the Commentary, but until then it will be up to each AHJ to interpret whether the hardware on the access side of the gate needs to be mounted at 54 inches.

Using the pool gate that I originally posted about as an example…as this pool was part of a resort and the gate was left unlocked during the day, the access-side hardware would have to be mounted at 54 inches.  If the gate required resort customers to use their room card to access the pool and the gate closed, latched, and locked each time it was opened, the access-side hardware could have been mounted between 34 and 48 inches.  Make sense?

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