Are the vision lights in double-acting traffic doors / impact doors required to comply with the accessibility standards?
For most doors – if a vision light or sidelight is present – the bottom of at least one light must be located no more than 43 inches above the floor. This allows all building occupants – including people using wheelchairs – to use the vision lights. There is an exception for doors with vision lights more than 66 inches above the floor because those lights are for light transmission and not for viewing.
The model codes and accessibility standards do not specifically exempt double-acting traffic doors from these requirements, BUT – this type of door is often used in an employee work area. The International Building Code (IBC) includes 14 locations that are exempt from the accessibility standards of the IBC, and employee work areas are included in that list of exemptions (read on). The ADA Standards also include some exceptions related to employee work areas.
The IBC and the ADA Standards define employee work areas the same way:
Employee Work Area. All or any portion of a space used only by employees and used only for work. Corridors, toilet rooms, kitchenettes and break rooms are not employee work areas.
Although the IBC and the ADA Standards exempt some spaces and elements within employee work areas from certain requirements, both require employee work areas to be designed and constructed so that individuals with disabilities can approach, enter and exit the work area. The common interpretation of this requirement is that the entrance and egress doors serving the employee work area would have to comply with the requirements of the codes and standards – including the location of the vision lights.
In addition to an accessible entrance to the employee work area, both the IBC and ADA require common use circulation paths within employee work areas to be accessible routes – with a few exceptions. The exceptions include:
- common use circulation paths within employee work areas with an area of less than 1,000 square feet and defined by permanently installed partitions, counters, casework or furnishings,
- common use circulation paths located within employee work areas, that are an integral component
of equipment, and
- common use circulation paths located within exterior employee work areas that are fully exposed to the weather.
An ADA advisory states: Although areas used exclusively by employees for work are not required to be fully accessible, consider designing such areas to include non-required turning spaces, and provide accessible elements whenever possible. Under the ADA, employees with disabilities are entitled to reasonable accommodations in the workplace; accommodations can include alterations to spaces within the facility. Designing employee work areas to be more accessible at the outset will avoid more costly retrofits when current employees become temporarily or permanently disabled, or when new employees with disabilities are hired. Contact the Equal Employment Opportunity Commission (EEOC) at www.eeoc.gov for information about title I of the ADA prohibiting discrimination against people with disabilities in the workplace.
If the traffic/impact door is within an area that is exempt from the accessibility requirements, the vision light would not typically have to be at the location mandated by the accessibility standards. With that said, AHJ interpretations may vary and the ADA advisory recommends incorporating accessible elements wherever possible. Mounting the vision light at the 43-inch location could avoid expensive and time-consuming problems in the field.