I know that many iDigHardware readers love Fixed-it Friday, but I especially love when I can use Fixed-it Friday to ask for help (there were so many helpful comments last week!). I have another question this week that I hope you will weigh in on.
In California, the building code requires automatic operators to have two actuators – one at the standard height and one near the floor for use by people who need to use their feet, crutches, wheelchair footpads, etc. to push the actuator. Here’s what the California Building Code (CBC) says about the required locations for the actuators (note that this requirement is specific to California, but insight/opinions from any state would be great):
At each location where push plates are provided, there shall be two push plates; the centerline of one push plate shall be 7 inches (178 mm) minimum, and 8 inches (203 mm) maximum above the floor or ground surface and the centerline of the second push plate shall be 30 inches (762 mm) minimum and 44 inches (1118 mm) maximum above the floor or ground surface. Each push plate shall be a minimum of 4 inches (102 mm) diameter or a minimum of 4 inches by 4 inches (102 mm x 102 mm) square and shall display the International Symbol of Accessibility complying with Section 11B-703.7.
In lieu of using two actuators, the CBC allows a vertical actuation bar:
At each location where vertical actuation bars are provided the operable portion shall be located so the bottom is 5 inches (127 mm) maximum above the floor or ground surface and the top is 35 inches (889 mm) minimum above the floor or ground surface. The operable portion of each vertical actuation bar shall be a minimum of 2 inches (51 mm) wide and shall display the International Symbol of Accessibility complying with Section 11B-703.7.
The CBC includes a little more information about the location of the actuators:
Where push plates, vertical actuation bars or other similar operating devices are provided, they shall be placed in a conspicuous location. A level and clear floor or ground space for forward or parallel approach complying with Section 11B-305 shall be provided, centered on the operating device. Doors shall not swing into the required clear floor or ground space.
Nathan Burkhardt of Opening Technologies sent me today’s Fixed-it Friday photo, which he received from a customer. The actuator in the photo will need to be moved down in order to comply with the CBC, but the question is this: Would/should the obstruction of the handrail be allowed if the actuator can still be operated in the locations (at the specified distance AFF) where the two actuators are required by the CBC? Would this meet the intent of the code? WWYD?
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This is what keeps lawyers (and regulators) employed. No law or regulation can cover all possible variations.
Assuming:
1. The actuator operates when pressed at any point, and
2. The top and bottom heights meet the Code requirement, and
3. The obstruction does not prevent actuation at the Code specified heights,
this installation should meet the intention of the Code. As a designer I would not recommend their solution.
Being this is coming from California I’m kind of surprised they don’t require Braille on the actuators as well…
Hi Larry –
I checked again and I don’t see a requirement for braille on the actuators.
– Lori
ADA be damned, the lowest point becomes an obstruction, similar to a less than a 10” bottom rail on a door.
Hmmm…the same limitation doesn’t apply to walls as far as I know. Have you seen a problem related to this, Bryan?
– Lori
How does this deal with hands free actuators Mount two at standard heights? What about activation size ? How do you measure this ?
Hi Blaine –
Someone else commented that with touchless sensors you only need the “high” one. I have not seen any documentation on that so if I receive something from him I will post it.
I think the activation size would be the area where you could push on the actuator and have it open the door – not including areas of the actuator that don’t perform that function.
– Lori
I disagree. The intent of a continuous vertical actuation bar is defeated by having an upper and lower region interrupted with an object such as the handrail.
Just a note about dual actuators vs kick plate…there is a third option, you can use a single proximity sensor (touchless sensor) in the “high” position. You only need a high/lo sensor when they are push plates.
That’s interesting! Do you have anything from California that says that about the touchless actuator?
– Lori
Lori, CBC section 11B-404.2.9 lists the requirements for push plates, vertical actuation bars, and other sensing devices in the exceptions of this section. Careful reading of the section reveals when it is describing a specific item, such as Push Plates and Vertical Actuators, leaving out key words such as Sensing Devices.
In this case, omission of “sensing devices” from the height and quantity requirements for push plates and vertical actuators provides the loophole allowing just one touchless sensor up high.
Exception 2.C says:
“Powered doors shall be controlled on both
the interior and exterior sides of the doors
by SENSING DEVICES, push plates, vertical
actuation bars or other similar operating
devices complying with Sections 11B-304,
11B-305 and 11B-308.
At each location where PUSH PLATES are
provided there shall be two push plates; ….
…At each location where VERTICAL ACTUATION bars are provided the operable portion shall be located so the bottom is ….
Where push plates, vertical actuation bars or OTHER SIMILAR OPERATING DEVICES are provided, they shall be placed in a conspicuous location. A level and clear floor or ground space for forward or parallel
approach complying with Section 11B-305
shall be provided, centered on the operating
device. Doors shall not swing into the
required clear floor or ground space.”
Interesting…I would not have noticed that loophole. I wonder if the AHJs do.
– Lori
OSHPD does. Never had a problem with just a single proximity sensor in OR’s and other areas
I don’t do work in California, however, there is no code requirement in the IBC that handrails and bumper rails are required in corridors. These are mainly put in for convenience for the infirmed and to protect the walls from cart and hospital bed traffic. It would seem to me that the push buttons might have been a modification after the handrails and bumper guard were installed.
Hi Chris –
Yes, the rail was there first. Back then, the door may not have even had an auto operator.
– Lori
Hi Lori,
Are there exceptions to the CBC rule requiring two push plates?
Hi Jonathan –
To me, the code section that has this requirement is kind of confusing. It is a section addressing automatic doors in a specific location, but from what I am hearing, most California AHJs are interpreting the high/low actuator rule as applying to all locations that have auto operators. So I don’t know of a specific exception, but there may be some inconsistencies in interpretation and enforcement.
– Lori
Coming in very late to this thread, but my read of this is that the dual push plates or single vertical actuation bar should only be required at exterior doors when used to replace one of every eight manual doors (Exception #2). All of the requirements beyond are lettered and therefore related specifically to exception #2. If we read 11B-404.3 for Automatic and Power-Assisted Doors and Gates, there is no similar requirement. 11B-404.3.5 for controls specifically sends us to 11B-309, which allows standard reach ranges from 11B-308.
If AHJs are enforcing this at every door, I believe they are wrong.
Thanks Steve! I agree that’s what the CBC says because of where the requirement is located within the code, but many are interpreting it as applicable in all locations where there is an automatic operator. It’s the wonderful world of codes! 🙂
– Lori