I worked on several GSA projects back when I was writing hardware specifications, and I don’t remember ever seeing the facilities standards that have been published by the GSA, addressing certain types of federal projects.  They would have been helpful to have access to!  This article summarizes some of the door-related requirements of the P100 standards.

This post will be published in Door Security + Safety

When working on a federal project that is owned or leased by the US General Services Administration (GSA), there is sometimes the perception that the building is exempt from the model code requirements that must be followed for other types of buildings.  Thankfully, this is incorrect.  With very few exceptions, GSA properties must comply with the nationally-recognized model codes and standards; when it comes to egress, NFPA 101 – Life Safety Code typically applies.  Although many GSA facilities require a high level of security, the safety of building occupants must also be considered.

The GSA Facilities Standards for the Public Buildings Service (P100) were last updated in October of 2021.  These standards apply to federal civilian buildings which provide workspace to 1.1 million federal employees, ranking the GSA as one of the largest holders of real estate in the US.  Most of these buildings are federal courthouses, land points of entry, child care centers, and federal office buildings.  The detailed requirements for each of these building types can be found in the design guides and manuals specific to these facilities.

The current edition of the GSA Facilities Standards includes 316 pages of requirements pertaining to anything from acoustic control to zinc coatings, and just about everything in between.  Four levels of performance are used throughout the P100 standard – Baseline, Tier 1, Tier 2, and Tier 3.  This article will summarize some of the door-related requirements, but for complete information it’s best to refer to the standards, which are available for download from GSA.gov.

Adopted Codes

The technical requirements of the I-Codes published by the International Code Council (ICC) have been adopted by the GSA.  However, the technical egress requirements of NFPA 101 – Life Safety Code have been adopted in lieu of the technical egress requirements of the International Building Code (IBC).  For technical electrical requirements, NFPA 70 – National Electrical Code has been adopted.  The latest editions of the codes and standards adopted by the GSA that are in effect at the time of design contract solicitation must be used throughout the project’s design and construction period.  The GSA also requires compliance with the International Green Construction Code (IgCC) for certain aspects of building design; the P100 standards currently refer to the 2018 edition of this code.

It’s important to note that all door openings in a means of egress are required to meet the criteria listed in NFPA 101.  This includes the requirements for doors to unlatch with one releasing motion, with operable hardware mounted between 34 inches and 48 inches above the floor or ground, and with no key, tool, special knowledge, or effort.  The special locking arrangements sections of the Life Safety Code, such as those addressing delayed egress locks and electromagnetic locks, also apply to these GSA facilities.

State and Local Codes

When a facility is built on federal property, it is exempt from state and local building codes.  However, state and local modifications to the model codes often address important regional interests and conditions.  The GSA’s policy is to comply with state and local building codes when possible, but the GSA has the final authority to accept or reject any recommendation from state or local government officials.

During the design phase, the GSA project manager must allow state and local officials to review the design for compliance with the building codes.  State and local officials may also conduct inspections during the construction phase to assist the GSA in achieving code compliance.  However, these state and local government officials do not have the authority to reject, accept, or make changes to the work.

When there is a conflict between the codes or standards adopted by the GSA and the GSA requirements for the project, the GSA requirements take precedence.  Equivalency clauses of the codes and standards may allow alternative products or methods to be used even if they are not specifically allowed by the adopted codes.  Conflicts between the codes or standards and the GSA requirements must be resolved by the GSA project manager.


All federal buildings are required by GSA policy to be accessible without the use of special facilities for people with disabilities.  Compliance with the Architectural Barriers Act Accessibility Standards (ABAAS) is mandatory for all GSA projects, but if there are local accessibility standards that apply in the project’s jurisdiction, the most stringent requirements must be followed.  The accessibility requirements of the I-Codes may apply if they are more stringent than the ABAAS.

Note that the requirements for automatic operators at accessible public entrances have been incorporated into the P100 standards; this change was incorporated into the 2021 edition of the IBC.  Public entrances (as defined by the ABAAS standards) that are required to be accessible must have at least one door with an automatic operator.  If the entrance has a vestibule, at least one exterior and one interior vestibule door must be equipped with automatic operators.

For detailed information about their policies on accessibility, the US GSA has published a document called National Accessibility Program – Standards, Policies, and Procedures.  The GSA’s National Accessibility Program is managed by the GSA’s Regional Accessibility Officers, who oversee facility design, construction, alteration, leasing, and operation.  This desk guide is used by these officers to support the GSA’s efforts in implementing the Architectural Barriers Act of 1968.  Regarding the GSA’s commitment to this implementation, the guide states: “To do so, the agency constructs new facilities that are accessible to persons with disabilities and incorporates the most current accessible-design requirements into its alterations of existing buildings. It also leases accessible facilities. GSA takes pride in accommodating all Americans.”

Historic Preservation

According to the National Historic Preservation Act (NHPA) of 1966, federal agencies must use historic properties to the greatest extent possible and must strive to rehabilitate these buildings in a way that preserves their architectural character.  GSA policies state that in order to maintain the original appearance of a historic building, entrance doors must be retained and upgraded with care, or replicas should be installed where the original doors are missing.

The P100 standards recommend that the design of cross-corridor doors should provide maximum height and width clearance and avoid visually truncating the corridor.  In many cases, oversized doors that are normally held open are used to meet this requirement.  According to the standards, historic doors modified to receive rated glass or new doors with rated glass are recommended in locations where the doors can not be held open.  If new fire rated doors are required in preservation zones, the panel detailing and finish should resemble historic doors.


For these GSA projects, product specifications must be organized in accordance with the Construction Specifications Institute (CSI) MasterFormat.  Specifications must be provided in both electronic and hard-copy formats and must be carefully coordinated with the drawings.  Division One specifications are provided by the GSA, but the architect (or engineer) is responsible for editing all specification sections – including the sections provided by the GSA – to reflect the design intent, GSA policy requirements, and federal law.  For construction contracts performed in the US, only domestic construction materials must be specified, except when a waiver to the Buy American Act is granted per the requirements in Federal Acquisition Regulation (FAR) 25.2.


The GSA’s standards cover sustainable design in Chapter 1 – General Requirements.  All GSA projects are required to include applicable strategies and opportunities to improve sustainable performance, and some   .  The P100 standards include information related to LEED Certification for federal buildings, net zero waste requirements, and Green credentialed construction personnel.  In addition, the standards reference GSA’s Proving Ground, a program evaluates next generation building technologies in real-world operational settings and recommends the most promising for use within GSA’s projects.  Detailed requirements for sustainability are found in the GSA document: Council on Environmental Quality – Guiding Principles for Sustainable Federal Buildings.  New construction projects, major repairs and alterations, and applicable work in existing GSA buildings, is required to comply with this publication.


In the P110 standards, requirements for acoustic performance are addressed in Chapter 3 – Architecture and Design.  The standards reference different levels of Noise Isolation Class (NIC) required for various types of spaces, ranging from an NIC of 53 for teleconference rooms to NIC 31 for certain types of private offices.  The four key concepts that govern the quality of office acoustics are speech privacy, background sound, absorption, and noise isolation.  The GSA standards include requirements related to the acoustic performance of GSA buildings, and additional information about office acoustics is covered in a publication called GSA Sound Matters.  The acoustical performance of the installed assemblies is verified during the commissioning of the building, which is outlined in the GSA Building Commissioning Guide.

Entrance Doors

For the GSA buildings addressed by the P100 standard, entrance doors may be heavy duty aluminum and/or glass doors.  Exterior doors and frames with glazing must be steel and comply with Steel Door Institute (SDI) Grade III with a G-90 galvanized zinc coating.  Entrances should have vestibules to control air infiltration and reduce stack effect, and automatic sliding doors are preferred in these locations over automatic swinging doors.  To actuate automatic doors, motion sensors and wall-mounted actuators are preferred over control mats.

In high wind zones and windborne debris regions as defined by the IBC, protection against windborne missile impact and cyclic pressure loading is required.  The P100 standard references three tiers of protection (1, 2, and 3) addressing provisions related to windborne debris impact, tornado windborne debris, and wind-induced loads.

Exit Stair Path Markings

For new high-rise buildings, the P100 standards require exit enclosures to have exit stair path markings that comply with NFPA 101.  For the door openings that swing out of these exit enclosures in the direction of egress, the required markings must self-luminous, photoluminescent, or other material (including paint), as long as an electrical charge is not required to maintain the luminescence of the marking.  The markings must include a stripe at the top and sides of the door frame and an outline around the latch-releasing hardware or a stripe on the panic hardware touchpad (if panic hardware is installed).  Doors must also be marked with an emergency exit symbol with a luminescent background, near the bottom of the door.  Consult the Life Safety Code for detailed requirements.

Construction Products and Materials

Finally, Chapter 3 – Architecture and Design, addresses the performance attributes of construction products and materials – including door openings.  This section references industry standards from the Builders Hardware Manufacturers Association (BHMA), Steel Door Institute (SDI), as well as the Window and Door Manufacturers Association (WDMA) to establish acceptable criteria for the products installed in GSA facilities.

In addition to partitions, millwork, cabinetry, and countertops, this section includes criteria for wood doors, hollow metal doors, aluminum doors, all-glass doors, door frames, and borrowed lights.  The Interior Performance Table in the P100 standard includes more detailed information about the acceptable types of doors, frames, and hardware to be used on these GSA projects.


Remember, the P100 Facilities Standards generally cover US GSA projects like federal courthouses, land points of entry, child care centers, and federal office buildings.  The standards contain a wealth of information about the requirements for these facilities, and they refer to additional publications with more detailed criteria.  The GSA has established these requirements and published them in the standards and the referenced publications, to support the administration’s goals for these facilities.  Familiarity with the standards can help to ensure that the correct products are specified, supplied, and installed on these GSA projects.

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