Quite a few questions came up during my webinar on touchless door openings, and here’s one of them:
Do the requirements of NFPA 80 “trump” the ADA requirements? Is fire protection more important than accessibility?
The short answer: No.
Here’s the long(er) answer…
The ADA is a federal civil rights law and it applies nationwide – the ADA Standards for Accessible Design establish the criteria for accessible buildings. ICC A117.1 is the accessibility standard referenced by the International Building Code (IBC) and other model codes. These two publications are very similar, but states or local jurisdictions may also have their own accessibility requirements. It’s important to be aware of all of the applicable standards.
Thirty years ago, buildings typically had designated accessible routes, and the doors on those routes were required to comply with the accessibility standards; that philosophy has changed. There’s a lot of great background information on this in the IBC Commentary. Here’s an excerpt:
The fundamental philosophy of the code on the subject of accessibility is that everything is required to be accessible. This is reflected in the basic applicability requirement (see Section 1103.1). The code’s scoping requirements then address the conditions under which accessibility is not required in terms of exceptions to this general mandate. In the early 1990s, building codes tended to describe where accessibility was required in each occupancy, and any circumstance not specifically identified was excluded. The more recent codes represent a fundamental change in approach. Now one must think of accessibility in terms of “if it is not specifically exempted, it must be accessible.”
There are some locations that are exempt from the accessibility requirements, but they are very limited. For example, employee work areas are exempt, BUT – the entrances and exits to those areas must comply, AND – corridors, toilet rooms, kitchenettes, and break rooms are not considered employee work areas. There is more information about the exempted areas in this post, and employee work areas are covered here.
Back to fire doors…
Fire doors are not exempt from the accessibility standards. However, there is at least one compromise that I can think of. The ADA Standards and ICC A117.1 require interior doors to be opened with no more than 5 pounds of opening force. Fire doors and exterior doors are not required to comply with this limitation, because they may not close and latch properly given the amount of closing force generated by a closer that opens with 5 pounds of force. Although exempt from the opening force requirement, fire doors (and exterior doors) would still have to comply with other accessibility requirements, like closing speed, clear opening width, and hardware operation.
Fire doors and exterior doors are not allowed to have unlimited opening force – the maximum opening force for these doors is addressed by the IBC. Fire doors and exterior doors must not require more than 15 pounds to release the latch, 30 pounds to set the door in motion, and 15 pounds to open the door to the fully-open position. There are additional egress requirements that also apply to the vast majority of doors.
The bottom line is that most fire doors have to comply with requirements for egress, fire protection, and accessibility, and there may be multiple codes and standards that apply to a particular project. All of those requirements must be considered in order to ensure that the door in question will provide free egress, be operable by all building occupants, and if it’s a fire door – help to compartmentalize the building and protect the means of egress.