This post was published in Doors & Hardware
The 2010 ADA Standards for Accessible Design (available for download at www.ada.gov) 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; 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.
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, vs. 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 installed in this area of the door 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 higher 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. The 2017 edition of ICC A117.1 clarifies that a kick plate applied for the purpose of increasing an existing bottom rail must extend to 10 inches above the floor and to within 1 inch of the sides and bottom of the door.
Sliding doors and doors that do not extend to within 10 inches of the floor are exempt from the flush bottom rail requirement. Tempered glass doors with no vertical stiles and a tapered bottom rail do not have to meet the requirement for a 10-inch bottom rail, although they are still subject to the prohibition on projections. I am often asked about patch fittings for bottom pivots on glass doors. Because they are not continuous across the bottom of the door, and the difference between the plane of the glass and the face of the patch fittings would likely be more than 1/16-inch, I think most AHJs would find patch fittings non-compliant.
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!