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If a door on an accessible route has a vision light or sidelight* that permits viewing, the accessibility standards require the bottom of at least one light to be no more than 43 inches above the floor. This ensures that someone using a wheelchair can see through the glass.
There is an exception for vision lights above 66 inches – like the small lights that are sometimes found at the top of residential doors. Because the lights are used for light transmission and not for viewing, these doors don’t have to comply with the requirement for at least one light to be at the 43-inch location.
Note that this section does not require a door to have a vision light (although there may be mandates in other codes). But if the door has a vision light, this section establishes the required location.
So the question is…
Does the vision light height requirement apply to automatic doors as well as manually-operated doors?
Interesting question – I had never thought about it (have you?). The accessibility standards include two sections related to doors – one called Manual Doors, Doorways, and Manual Gates, and the other called Automatic and Power-Assisted Doors and Gates. The paragraph addressing vision lights is found in the section that covers manual doors. In the section for automatic doors, the ADA standards address the following requirements:
- Clear Width
- Maneuvering Clearance
- Doors in Series and Gates in Series
- Break Out Opening
- Revolving Doors, Revolving Gates, and Turnstiles
The 2017 edition of ICC A117.1 has additional sections for public entrances, vestibules, and door and gate hardware on automatic doors, and does not include a section on revolving doors.
Neither of these standards includes a paragraph in the automatic door section regarding vision lights, so the requirement does not apply to automatic doors. With that said, for safety reasons I think it would make sense for an automatic door to have a vision light at the 43-inch location.
What do you think?
*Fun fact in case you’re searching the PDFs…the 2010 ADA standards call these “vision lights” and “side lights.” ICC A117.1 calls them “vision lites” and “sidelites.”