On a multi-family building, are the dwelling unit doors required to have a 10-inch bottom rail?
If you’re not familiar with the requirement for a 10-inch flush surface at the bottom of the door, there is a Decoded article about it here. Basically, the current accessibility standards require a flush, smooth area with no protruding hardware on the push side of manual doors, from the floor to 10 inches up the face of the door.
The answer is a qualified “yes” – IF the doors are required to comply with Section 404 of the 2010 ADA Standards for Accessible Design or ICC A117.1 – Accessible and Usable Buildings and Facilities (any edition since the 1990’s). Whether or not the doors need to comply with these standards – and this section of the standards – is where the confusion comes in.
Most multi-family buildings are required to comply with the Fair Housing Act, which accepts several sets of standards for compliance. Some of these standards do include the requirement for a flush area at the bottom of the door – some do not. So it’s possible to meet the Fair Housing Act guidelines with a narrow bottom rail.
BUT – most multi-family buildings are also required to comply with the International Building Code (IBC), which references ICC A117.1 – which includes the 10-inch requirement.* Most manually-operated doors (not automatic doors) are required to have the smooth surface at the bottom on the push side. BUT – for dwelling units the IBC and ICC A117.1 include different requirements for Accessible units, Type A units, and Type B units.
- Accessible (fully accessible) and Type A (easily adaptable) units are required to have doors and hardware that meet the requirements of Section 404, at the primary entrance door and all other doors intended for user passage. This includes the flush bottom rail requirement, which is addressed in Section 404.
- Type B (partially adaptable) units are required to have doors and hardware that meet the requirements of section 404 on the primary entrance door. For these units, only the primary entrance door is required by the IBC and ICC A117.1 to have the flush bottom rail.
Under limited circumstances, some dwelling units are not required by the IBC to be Accessible, Type A, or Type B units and would not typically be required to have the flush bottom rail. ICC A117.1 includes another type of unit that is not currently addressed in the IBC:
- Type C (visitable) units are not required to have an entrance door that meets A117.1 section 404, but ICC A117.1 includes requirements for clear width and threshold height at these doors.
In order to determine whether multi-family doors need to have a 10-inch smooth surface at the bottom, the questions to ask are:
- Which code or standard are the doors required to meet?
- What type of units are the doors serving?
- Are the doors primary entrance doors, doors intended for user passage, or other doors?
* When the requirement for a flush bottom rail was first introduced in ICC A117.1, the height of the smooth surface was 12 inches. It has since been changed to 10 inches.