Is a surface-mounted automatic door bottom compliant with the accessibility standards?
Both the ADA Standards for Accessible Design and ICC A117.1 Accessible and Usable Buildings and Facilities require manually-operated doors to have a flush smooth surface on the push side, measured 10 inches up from the floor. There are a few exceptions for sliding doors, some all-glass doors, and doors that don’t extend to within 10 inches of the floor or ground (see this Decoded article for more info). Note that this requirement does not apply to automatic doors.
Where there are horizontal or vertical joints in the surfaces of the door in this area, each of the surfaces must be within 1/16 inch of the same plane. The intent is to prevent a wheelchair footpad, crutch, or cane from being caught on protruding hardware, glass bead, a recessed panel, etc. With a flush, smooth surface, these mobility aids will slide along the face of the door as the building occupant is opening the door manually.
When a pair of doors has panic hardware, a surface-mounted vertical rod and latch at the bottom of the door will not comply with the accessibility requirement for a flush, smooth surface. Therefore, these doors may be equipped with concealed vertical rod panic hardware if a removable mullion is not desired. If the doors are also equipped with automatic door bottoms, a concealed unit will conflict with the concealed vertical rod panic hardware (or flush bolts). Using a surface-mounted automatic door bottom might seem like a good way to avoid this conflict, but the door bottom would mount on the push side of the door, in the area that is required to be flush and smooth.
I spoke to a staff member from the US Access Board, to discuss whether a surface-mounted automatic door bottom – which runs along the entire door width – would create a potential catch-point for a crutch, cane, or wheelchair footpad. The interpretation of the US Access Board was that the surface-mounted automatic door bottom would not comply with the requirement of the accessibility standards because it would create a surface that is not within 1/16 inch of the other surface – the face of the door.