Here’s my next Decoded article…let me know if there is anything I should add/change before it goes to print!

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This post will be published in the January 2018 issue of Doors & Hardware

The vision lights in these existing doors do not meet the current location requirements. If the sidelights were part of the frame, the opening would be compliant; it is unknown whether the AHJ would accept this design for new construction.

The International Building Code (IBC), requires almost all doors to meet the accessibility requirements, with the exception of the 14 areas that are specifically exempted in the code.  The International Fire Code (IFC) and NFPA 101 – The Life Safety Code also address accessibility for buildings that are required to comply with these codes.

Vision Lights

In the United States, the commonly-used accessibility standards are ICC A117.1 – Accessible and Usable Buildings and Facilities (referenced by all 3 of the model codes mentioned above) and the ADA Standards for Accessible Design (a federal law).  While some existing doors may pre-date the accessibility requirements that apply to vision lights, the required location has been part of ICC A117.1 since the 1998 edition.  It was added to the ADA standards in the 2010 edition.

These requirements are found in Section 404.2.10 of ICC A117.1 (recent editions) and Section 404.2.11 of the 2010 ADA standards, and the language in each standard is virtually identical.  This is the section from the 2010 ADA Standards for Accessible Design:

404.2.11 Vision Lights.  Doors, gates, and side lights adjacent to doors or gates, containing one or more glazing panels that permit viewing through the panels shall have the bottom of at least one glazed panel located 43 inches (1090 mm) maximum above the finish floor.

EXCEPTION:  Vision lights with the lowest part more than 66 inches (1675 mm) from the finish floor or ground shall not be required to comply with 404.2.11.

A vision light is not required in each door opening on an accessible route, but if vision lights are provided for viewing purposes in doors or sidelights, the bottom of at least one of these lights must be located no more than 43 inches above the floor.  Additional vision lights may be provided at other installation heights, as long as at least one light is mounted at the required height.  This ensures that the light permits viewing for all building occupants – including occupants using wheelchairs.  While the typical mounting height of hardware was taken into account when adding the light location to the standards, care must be taken to avoid light/lock conflicts.

There is an exception in this section that exempts lights installed with the bottom of the light more than 66 inches above the floor or ground.  These lights are acceptable because they are typically used for aesthetics or light transmission and are not used for viewing.  Doors with lights above 66 inches are sometimes used for residential dwelling units, to permit privacy while allowing light to enter the dwelling unit.  Transom lights above the door would also be exempt from these requirements.

When doors are discovered on-site which do not meet the location requirements for vision lights, one proposed solution has been to obscure the glazing so that the lights would no longer be considered vision lights.  It is actually not uncommon to find new doors with non-compliant vision lights, as there are many people who are not aware of the required location, and many of the standard light configurations used in the past are not code-compliant.  When the doors are fire-rated, it’s difficult or impossible to alter the light in the field.  While it’s best to supply code-compliant doors, the Authority Having Jurisdiction (AHJ) may allow the glazing to be modified or a film added to obscure the glazing (verify what is allowed by the manufacturer’s listings if the door is a fire door).  This would not be acceptable in locations where vision lights are required – like double-egress smoke-barrier doors in a health care facility.

Viewers

The 2010 ADA standards and ICC A117.1 include requirements pertaining to the primary entrance to certain types of dwelling units.  For these units, the main entrance door is required to have a means for visually identifying a visitor without opening the door, and the viewer must allow for a minimum 180-degree range of view.  An ADA advisory on this topic states that viewers with prisms can be placed at a standard height and permit a view from several feet away.  The Fair Housing Act Design Manual also refers to a “wide angle peep hole” in the dwelling unit entry door but includes no prescriptive requirements.

The mounting location of viewers is not specifically stated in the accessibility standards, however, some local codes do include required mounting heights.  For example, in Massachusetts, entrance doors to dwelling units are required to have a viewer (or sidelight or vision light) mounted 60 inches above the floor for some types of units, with an additional viewer/light at 42 inches above the floor for others types of units.  Often dwelling units will have two viewers at two different locations to accommodate all building occupants.  Be sure to check the state and local requirements for requirements pertaining to viewers.

For more information about the required locations of vision lights and viewers, refer to the applicable codes and accessibility standards, or contact the AHJ for assistance.

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