I really enjoyed reading everyone’s input on my post about emergency exit seals, and since I’m currently in a 3-day class for the NFPA Certified Fire Plan Examiner program and don’t have a lot of time for blogging, here’s another question for which I have no concrete answer but would love your insight…
The national accessibility standards don’t directly address keys. I have been told that this is because keys are not a permanent part of a door opening. But my theory is that keys are not addressed because they’re an accessibility problem that is not easy to overcome, due to the hundreds of millions of existing locks with keys and the comparable cost of an electrified replacement. It may be feasible to replace a lock here and there, but when you consider the issue of keyed locks as a whole, removal of this barrier is not “readily achievable.”
Keys require tight grasping, tight pinching, and twisting of the wrist – all actions that are not allowed by the accessibility standards for the operation of door hardware. While it’s true that the actual key is not a permanent part of the door hardware, the bottom line is that hardware which requires a key for access is difficult or impossible for people with certain types of disabilities to operate.
I recently talked to a code official about this, with regard to accessible units of multi-family housing in his jurisdiction. His preference was for all of the accessible units (typically a small percentage of the total units) to have electrified locks with proximity readers. In his opinion, locks which required keys, a keypad/code, or the insertion of a card, should not be used on dwelling units that were required to be accessible. Although the national standards do not yet require electrified locks with proximity readers, I have heard the same preferences from other AHJs. Some questions for you to ponder (and comment on!)…
- Have you seen a preference for electrified locks with proximity readers on accessible units in your jurisdiction?
- Has a facility asked you for help to retrofit existing locks for a new building occupant who was unable to operate keyed locks?
- Should proximity readers replace key-operated locks in locations beyond accessible multi-family dwelling units?
- Is there another type of lock credential that you would consider accessible?
- If you were proposing a change to the national accessibility standards, what would that proposal look like?
Now, talk amongst yourselves while I study. 🙂