Can extended latch guards be installed to bring doors with surface vertical rods into compliance with the accessibility standards?
First, a reminder of the accessibility requirement this question is in reference to (more info here)…
The 2010 ADA Standards for Accessible Design and ICC A117.1 – Accessible and Usable Buildings and Facilities require manually-operated doors (not automatic doors) to have a flush, smooth surface on the bottom of the push side, measured from the floor to 10 inches up the face of the door. There are a few exceptions – some all-glass doors, sliding doors, and doors that do not extend to within 10 inches of the floor, but this requirement means that most doors must have at least a 10-inch (nominal) bottom rail with no protruding hardware in that area.
When hardware projects off the face of the door on the push side, in the 10-inch area at the bottom, it could catch the crutch, cane, or wheelchair footpad of someone attempting to use the door. Hardware that would be non-compliant includes kick-down holders, full-height door pulls (mounted on the push side), and surface vertical rod panic hardware with the bottom rod and latch installed.
Back in 2011, I asked ICC staff and several AHJs whether extended rod guards creating a sloped surface across the door width and over the bottom latch would meet the intent of the accessibility standards, and their answer was that it would meet the intent. Technically, the door would not be compliant because the difference between the plane of the door face and the plane of the extended latch guard would be more than 1/16-inch. (That post is here.)
So why am I writing a follow-up post? The other day I noticed something new in the 2017 edition of the ICC A117.1 Commentary. In the section discussing the requirements and exceptions for the flush, smooth surface, the Commentary now states:
In addition to the door stop indicated in the commentary figure, common errors are hardware that extends the full height of the door or panic hardware with the vertical rod below the hardware on the outside face of the door. Hardware must stop at least 10 inches (255 mm) above the floor. A plate covering the rod in accordance with Exception 4 could possibly resolve some issues.
Exception 4 (referenced above) states:
The installation of kick plates on existing doors and gates without a smooth surface within 10 inches (255mm) of the floor shall be permitted. The kick plates shall extend to 10 inches (255 mm) above the floor and no more than 1 inch (25 mm) from the sides and bottom of the door. Cavities created by such kickplates shall be capped.
My interpretation of this added information in the Commentary is that if an extended latch guard (“plate”) is installed to slope up to and over the bottom rod/latch of the surface vertical rod panic hardware, it could be acceptable if a) the top of the plate is at least 10 inches above the floor, b) the plate extends to within 1 inch of each side and the bottom of the door, and c) the plate is capped. Although the AHJ might have a different opinion, this seems to me like it would meet the intent of the accessibility standards.
What do you think?
Thanks to Wayne Ficklin for the photos!