This used to be a very common application but I haven’t seen it much lately. Do you know what the potential issue is?
(Spoiler alert…I posted the answer below the photos.)
I’m sure most of you are familiar with the concept of maneuvering clearances. For manual doors (and per the 2010 ADA standards – automatic doors without battery backup), clear floor space must be provided adjacent to the door to allow someone in a wheelchair to maneuver as needed to open the door. The dimensions for this clearance vary depending on the direction of the approach as well as the type of hardware that is installed – for example, if the door has both a closer and latch vs. just one or the other.
When a door is mounted in an alcove that is more than 8″ deep (6″ in Massachusetts per 521 CMR), maneuvering clearance for a forward approach must be provided. A frame with a large jamb depth (approximately 10″ or more, or 8″ in Massachusetts) can create the same situation.
If the deep reveal is on the pull side of the door, the maneuvering clearance must extend 18″ past the latch edge of the door (see graphics below). If the deep reveal is on the push side of the door and the door is equipped with both a closer and a latch, the maneuvering clearance must extend 12″ past the latch edge of the door. If the deep reveal is on the push side of the door and there is either a closer or a latch but not both, the maneuvering clearance is not required to extend past the latch edge of the door, so if the door above doesn’t have a closer it may be code-compliant.
Here is the section from the 2010 ADA Standards for Accessible Design, which went into effect March 15th, 2012.
404.2.4.3 Recessed Doors and Gates. Maneuvering clearances for forward approach shall be provided when any obstruction within 18 inches (455 mm) of the latch side of a doorway projects more than 8 inches (205 mm) beyond the face of the door, measured perpendicular to the face of the door or gate.
Advisory 404.2.4.3 Recessed Doors and Gates. A door can be recessed due to wall thickness or because of the placement of casework and other fixed elements adjacent to the doorway. This provision must be applied wherever doors are recessed.
The section from the 2009 edition of ICC A117.1 is very similar:
404.2.3.5 Recessed Doors. Where any obstruction within 18 inches (455 mm) of the latch side of a doorway projects more than 8 inches (205 mm) beyond the face of the door, measured perpendicular to the face of the door, maneuvering clearances for a forward approach shall be provided.
Here is a graphic from the 2010 ADA guidelines, which shows the maneuvering clearance requirements for a recessed door. You can find more information about maneuvering clearances by downloading (free!) the 2010 ADA Standards for Accessible Design.