Just when I think I’ve run out of questions and potential pitfalls, one shows up in my inbox. A while back I wrote an article for Doors & Hardware, addressing the required mounting height for operable hardware. The model codes and accessibility standards require operable hardware to be mounted between 34 inches and 48 inches above the floor. I noted in the article that some states have adopted different requirements for hardware mounting heights.
One of those states is California. Here’s the applicable section from the 2013 California Building Code:
11B-404.2.7 Door and gate hardware. Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with Section 11B-309.4. Operable parts of such hardware shall be 34 inches (864 mm) minimum and 44 inches (1118 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides. (Refer to the code for exceptions addressing existing locks on certain types of doors, and operable hardware on pool gates.)
As you can see, California has reduced the acceptable range for operable hardware to between 34 inches and 44 inches, instead of 34 inches to 48 inches as required by the model codes and accessibility standards. The problem I ran into recently was with a keypad lock, where the lever was well within the 34- to 44-inch range specified in the California code, but the keypad buttons in the top row were above 44 inches. While the installation was compliant with the model codes because the keypad was below the 48-inch mark, the project was in California and the code official noted that the mounting height was not in compliance with the state code. A slight change in the mounting height would have ensured that both the lever and the buttons were within the allowable range, but that’s obviously a lot harder to address after the door and frame have been prepped.
Some may question whether the keypad is considered operable hardware, and whether it complies with the accessibility standards (the thought being that if it’s not accessible, it doesn’t matter if it’s not mounted in the allowable range). The standards are not specific about keypads, and although it may be difficult or impossible for someone with a disability to press the keys, technically keypads comply with the accessibility standards because they do not require tight grasping, tight pinching, or twisting of the wrist to operate.
I usually try to comply with the most stringent interpretation of the codes and standards in order to avoid problems – especially for issues that are not specifically addressed in the adopted publications. For a keypad lock, or other type of lock with operable components located one above the other, it’s important to ensure that all of these operable components will be located within the allowable range when the lock is installed. Check your local codes and standards to verify the allowable mounting height for operable hardware in your project’s jurisdiction.