This post will be published in the January 2019 issue of Door Security + Safety
One of the most common questions I receive is whether automatic operators are mandated by the model codes or by the accessibility standards. Currently, automatic doors are not required by the national codes or standards used in the US, although automatic doors can be an alternative when doors do not meet the accessibility requirements for manual doors. There have been several states and local jurisdictions that require automatic doors in certain situations, and now there is a model-code change proposal in progress that is worth keeping an eye on.
The code development cycle for the 2021 International Building Code (IBC) is well under way. Proposal E115, submitted by a representative of the American Association of Automatic Door Manufacturers, calls for some public entrances to have automatic doors. To understand the scope of the proposal, we first need to define which doors are public entrances that are required to be accessible. Currently, the IBC requires at least 60 percent of all public entrances to be accessible, in addition to the following:
- Parking Structures: Where direct pedestrian access is provided from a parking garage to a building or facility, the entrances must be accessible.
- Tunnels and Elevated Walkways: Where direct pedestrian access is provided from a pedestrian tunnel or elevated walkway to a building or facility, at least one entrance from each tunnel or walkway must be accessible.
- Restricted Entrances: Where restricted entrances are provided to a building or facility, at least one restricted entrance must be accessible.
- Entrances for Inmates or Detainees: At judicial facilities, detention facilities, and correctional facilities, where entrances are used only by inmates or detainees and security personnel, at least one such entrances must be accessible.
- Service Entrances: When a service entrance is the only entrance to a building or tenant space, that entrance must be accessible. When a service entrance is not the only entrance to a tenant space, the service entrance is not required to be accessible.
- Tenant Spaces: At least one accessible entrance must be provided to each tenant space, except for self-storage facilities that are not required to be accessible.
- Dwelling Units and Sleeping Units: Each dwelling unit and sleeping unit in a facility must have at least one accessible entrance, except that an accessible entrance is not required for units that are not required to be Accessible units, Type A units, or Type B units.
Note: If an area is not required to be accessible, an accessible entrance is typically not required. This means that areas that are exempt from the accessibility requirements are usually also exempt from the requirements for an accessible entrance. Refer to the applicable building code or accessibility standard to learn more about these exceptions.
IBC proposal E115 would require at least one accessible exterior public entrance to have an automatic operator, for buildings in specified use groups with occupant loads over a certain threshold. If the current proposal is approved, the requirement would apply to assembly occupancies (Group A-1, A-2, A-3, and A-4) with an occupant load greater than 300 people. It would also apply to business, mercantile, and Group R-1 residential occupancies with an occupant load greater than 500 people (Group R-1 facilities are typically hotels, motels, boarding houses and other transient living facilities with more than 10 occupants). The proposal requires the automatic operators at these entrances to be full-power-operated doors or low-energy automatic doors. Power-assist operators that reduce the opening force but still require manual operation would not meet the requirements.
Although the proposal was approved by the technical committee, there were 3 public comments submitted which could modify the proposal. The public comments could increase the number of doors which require automatic operators – none of the public comments proposed disapproval of the proposal, although there’s a slight chance that the proposal could be disapproved. It’s too soon to know for sure what the final outcome and exact code language will be, but this will be clarified as the code development cycle continues.
One of the issues addressed by public comment is related to a change made in the 2017 edition of ICC A117.1 – Accessible and Usable Buildings and Facilities. Although this edition of the standard is not yet referenced by the model codes, it requires public entrances with automatic operators to have full-powered automatic doors or low-energy automatic doors. This edition of the standard also requires the corresponding vestibule door(s) to have the same type of operator as the exterior door. The A117.1 requirement for public entrances is intended to establish that when an automatic operator is required because of a project specification, owner preference, code or other mandate, an automatic operator (full-powered or low-energy) must be used rather than a power-assist operator.
While these changes have not yet been officially added to the model codes, I think it’s safe to say that the requirements for automatic operators will increase in the coming years. If the 2021 IBC requires automatic operators for some public entrances, this would become enforceable when a jurisdiction adopts that edition of the code. It’s likely that the requirement would only apply to new buildings and renovations, and that existing buildings would not have to be modified. However, given the preference toward automating doors at public entrances, facility managers and architects may want to consider providing this accessibility improvement sooner rather than later.