This post will be published in the June/July 2021 issue of Doors & Hardware

For most door openings, operable hardware that is used to release the latch must be mounted between 34 inches and 48 inches above the finished floor or ground (AFF).  This has not always been the required mounting height, and some state codes have further restricted the allowable range, so field conditions may vary.  In addition, there are some exceptions in the model codes and accessibility standards for existing hardware, hardware used only for security purposes, and hardware operated only by security personnel.

An exception in the International Building Code (IBC) addresses doors and gates serving swimming pools, spas, and hot tubs, stating:  Access doors or gates in barrier walls and fences protecting pools, spas and hot tubs shall be permitted to have operable parts of the latch release on self-latching devices at 54 inches (1370 mm) maximum above the finished floor or ground, provided that the self-latching devices are not also self-locking devices operated by means of a key, electronic opener or integral combination lock.

The terminology used in this exception has caused some confusion.  The intent is that the exception cannot be applied (and the hardware mounted at 54 inches above the floor) if the door or gate has self-latching hardware that prevents unauthorized access from the outside.  It would have been more easily interpreted if the exception stated that the 54-inch mounting height is not allowed or required when the hardware is self-latching and self-locking.

Operable hardware on pool doors and gates that is installed above the normal mounting height is intended to help prevent access to the pool by small children who are unaccompanied.  When the door or gate has a lock on the ingress side, the need for a key or access control credential provides the necessary level of child safety.  This allows the hardware to be installed at a height that meets the accessibility requirements.  If the door or gate is not always locked on the ingress side, the increased mounting height is allowed – and required.

The IBC requires the design and construction of swimming pools, spas and hot tubs to comply with the International Swimming Pool and Spa Code (ISPSC).  A swimming pool is defined by the IBC as:  Any structure intended for swimming, recreational bathing or wading that contains water over 24 inches (610 mm) deep. This includes in-ground, above-ground and on-ground pools; hot tubs; spas and fixed-in-place wading pools.

The requirements for doors and gates serving swimming pools have been clarified in the 2021 edition of the ISPSC.  Several changes were made to Section 305.3 – Doors and Gates, with some of the changes addressing the doors and gates themselves.  For example:

  • Doors and gates must be self-closing and outswinging (swinging away from the pool).
  • Self-latching doors and gates are required – pairs may have one leaf that is bolted or fixed and one self-latching leaf.
  • No openings of more than 1/2 inch are allowed within 18 inches of the latch – this helps to prevent children from retracting the latch from the outside.
  • Service doors in the pool area must be locked when the utility rooms are not in use.
  • Equipment room doors must have an “automatic closer” and an “automatic lock” (a door closer without a hold-open mechanism, and a storeroom function lockset).

With regard to the operable hardware, the Latch Release section has been modified for clarity.  The allowable mounting height for the hardware depends on a) whether the door or gate is always locked or can be left unlocked, and b) whether the door is serving a public pool, residential pool, or private pool.

A public pool is one that is operated by an owner, lessee, operator, licensee, or concessionaire – with or without a fee for use – and is intended to be used for swimming.  Public pools are further classified in the ISPSC, depending on how they are used.  For example, pools used for competitive diving events would be a different class from water slides or leisure rivers.  Residential pools are accessory to a residence, and available only to the household and its guests.

There is no definition in the ISPSC for a private pool, so this leaves some room for interpretation.  Merriam-Webster defines “private” as: intended for or restricted to the use of a particular person, group, or class, or belonging to or concerning an individual person, company, or interest.  Some state and local codes include very specific language defining private pools, but without a definition in the ISPSC it is left to the Authority Having Jurisdiction (AHJ) to determine whether a pool is private.

Self-locking doors and gates are those that have self-latching hardware that always requires a key or access control credential to enter.  The mounting height ranges below apply to both the latch-release mechanism and the “lock operation control” (ex. access control reader).  Non-self-locking doors and gates have hardware that is not lockable or may be left unlocked on the ingress side.  In the 2021 edition of the ISPSC, the allowable mounting heights for operable hardware are as follows:

  • Self-Locking Doors/Gates
    • Public Pools/Spas – 34-48 inches AFF
    • Residential Pools/Spas – not greater than 54 inches AFF
  • Non-Self-Locking Doors/Gates:
    • Public Pools/Spas – 52-54 inches AFF
    • Residential Pools/Spas – not less than 54 inches AFF
    • Private Pools/Spas – release mechanism at least 3 inches below top of gate on pool side

Along with addressing security and accessibility for swimming pools, egress is an important consideration.  The model codes require releasing hardware that will unlatch the door or gate with one motion, with no tight grasping, pinching, or twisting of the wrist, and with no key, tool, special knowledge, or effort.  Many public pools are considered assembly occupancies, based on the calculated occupant load of the pool and the pool deck within the enclosure.  When the occupant load is 50 people or more, the IBC requires the doors serving the pool area to have panic hardware.  For jurisdictions enforcing NFPA 101 – Life Safety Code, panic hardware is required when the occupant load of the pool area is more than 100 people.

Following the requirements if the International Swimming Pool and Spa Code, along with the adopted building codes, fire codes, and accessibility standards, will help to ensure that doors serving pool gates provide the necessary levels of safety and accessibility.  Be sure to check for local modifications to these requirements or contact the AHJ for assistance.

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