A few weeks ago I received a question about whether there is a limit on the number of operations required for access to a dwelling unit, in order to meet the accessibility standards. I knew that there was nothing about this stated in the accessibility standards, which require hardware that can be operated without tight grasping, pinching, or twisting of the wrist. Some accessibility standards also require hardware that is operable with one hand, with the releasing mechanism mounted in a certain reach range, and/or hardware that can be operated with a limited amount of force.
The building codes and fire codes include some of these same requirements, and limit most locking/latching hardware to one releasing operation for egress. In most cases, dwelling units are allowed to have an additional night latch, deadbolt, or security chain, which would result in additional releasing operations for egress. But there is nothing stated in the model codes and standards regarding the number of operations for access.
The situation (hundreds of locks already installed) made it crucial for me to procure SOMETHING stating that it was acceptable to have a lock that requires 3 releasing operations for access, as long as those operations are not required to be performed simultaneously, using both hands or an excessive amount of dexterity. The lock in question was a Schlage FE410 – a residential access control lock which is an interconnected lock requiring one operation for egress. To operate this lock from the outside, you present a fob or other access-control credential to unlock the deadbolt, use a thumbturn to retract the deadbolt, and use the lever to retract the latchbolt. Here’s a quick video of how it works:
It’s not always easy to prove something code-related when that requirement is not specifically addressed in the codes and standards. I spoke with about 20 organizations and AHJs, and all agreed that the codes and standards do not state a limit on the required number of operations for access. The problem was that many of the people I spoke to were not allowed to respond in writing. After receiving email responses from the US Access Board, the National Disability Rights Network, the ADA National Network, and an ADA consultant in California, I had the written confirmation needed to show that the lock meets the accessibility requirements. The ADA consultant’s letter stated, “I’m a C-5 Quadriplegic with very limited hand function and this hardware is easily used.”
One of the interesting things that came up during the time spent getting this clarification, is that the proposed alternative was to equip the accessible dwelling units with key-operated locks instead of access-control locks. Because keys are not a permanent part of the operable hardware, they are not addressed by the accessibility standards. So the idea behind using keyed locks on the accessible units was that they are technically acceptable even though they require the key to be grasped, inserted, twisted, removed, and sometimes repeated for the latching hardware in addition to the deadbolt. This operation is obviously much more difficult than the access-control lock.
Now that I have the documentation regarding the number of releasing operations for access, the lack of a prescriptive requirement in the model codes and standards should not create a problem in the future. If you need any help with this issue, just let me know.