For most types of buildings, lever-handle locksets are standard equipment, but some existing buildings may be equipped with knobs.  Are knobs acceptable by code in existing health care facilities?

The answer to this “quick question” is multifaceted, so I’ll break it down.  Here goes…

There are two accessibility standards that are widely used in the US – ICC A117.1-Accessible and Usable Buildings and Facilities and the 2010 ADA Standards for Accessible Design.  According to these standards, operable hardware installed on doors that are part of an accessible route is required to be operable without tight grasping, pinching, or twisting of the wrist.  Knobs typically require tight grasping, pinching, and/or twisting of the wrist, and therefore they do not meet these requirements.  The next question is…are health care facilities required to comply with the requirements of these accessibility standards?

The International Building Code (IBC) includes the no-tight-grasping/pinching/twisting requirement for doors that are required by to be accessible per Chapter 11.  The 2015 edition of the IBC requires almost all types of buildings and facilities to meet the requirements of ICC A117.1, with 14 exceptions.*  Although some of these exceptions could apply to a specific area within a hospital (for example, a walk-in cooler), the exceptions do not exempt health care facilities in general.  Therefore, a building that was built in accordance with the requirements of the IBC would require hardware that can be operated without tight grasping/pinching/twisting (and would not have knobs).  But what about existing buildings that were built prior to the IBC, or in jurisdictions where the IBC has not been adopted?

For questions related to existing health care facilities, I would typically turn to the 2012 edition of NFPA 101 – Life Safety Code, because that is the code currently adopted by CMS** and used by accrediting organizations like the Joint Commission.  NFPA 101 references ICC A117.1 in Chapter 2 – Referenced Publications, so at first glance it may appear that NFPA 101 requires door hardware to comply with ICC A117.1.  BUT…it’s important to note that the inclusion of a particular standard in a model code’s list of referenced standards does not necessarily mean that every part of the standard applies.

For example, NFPA 101 references ICC A117.1 in several locations, but almost all of the references are related to signage, with a couple of references to two-way communication systems and stair nosings – these would have to comply with ICC A117.1.  The code does define an accessible route as “a continuous unobstructed path that complies with this Code and ICC/ANSI A117.1,” but then exempts fully-sprinklered health care occupancies from the requirements for an accessible means of egress (“ Accessible means of egress shall not be required in health care occupancies protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 9.7.”).  Although NFPA 101 does include a reference in Annex A to hardware that is operable without tight grasping/pinching/twisting (“The operating devices should be capable of being operated with one hand and should not require tight grasping, tight pinching, or twisting of the wrist to operate”), I don’t see a mandatory requirement in NFPA 101 that would prevent the use of knobs on existing health care facilities that are protected throughout by a sprinkler system.

BUT (another “but”)…what about the Americans with Disabilities Act (ADA)?  This federal law does apply to most health care facilities, and the 2010 ADA Standards for Accessible Design do require operable hardware that requires no tight grasping/pinching/twisting.  So my answer to this QQ is – if a health care facility is required to comply with the 2010 ADA Standards for Accessible Design, knobs would not be compliant.  While the Joint Commission may not be addressing existing knobs and there may not be a team of “ADA inspectors” checking existing health care facilities for compliance, it’s possible that a facility could be cited for non-compliance with the ADA based on a complaint.  Some existing knobs may pre-date the ADA requirements, but these facilities may be required to remove the barrier of non-compliant hardware if doing so is feasible, or to accommodate people with disabilities by alternative means.

Agree?  Disagree?  Had experience with this issue?  Tell us!

* If you want more information on these 14 exceptions, I will write a separate post about that.

** CMS is the Center for Medicare and Medicaid Services.

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