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Resolving Code Questions in a Less-Than-Perfect World

Meeting positive pressure, ADA and other requirements isn’t always a cut-and-dried proposition. Look to the application for guidance when it comes time to make a tough decision or resolve an apparent conflict of regulations.

By Kurt Roeper, Fire & Life Safety Program Manager and Ron Ratell, ADA Program Manager
Exits, Closers & Doors Category
Carmel, IN 46032
Ingersoll Rand Security Technologies
Carmel, Indiana

What do you do when two code requirements seem to be in conflict? Or when two different regulations influence the design of an opening? A case in point is when the Americans with Disabilities Act (ADA) Title III, not a building code but a federal civil rights law, calls for accessibility, but life safety and building codes require closed doors if a fire occurs. When must a door and its hardware meet positive pressure requirements or when are they not an issue? This article will look at a few of these apparent conflicts that specifiers and suppliers face in the decision-making process. In the end, the requirements of each specific application will help point toward a conclusion that is unique to that case.

Door Closers, Power Operators and the ADA

Title III of the Americans with Disabilities Act (ADA) requires public accommodations to provide goods and services to people with disabilities on an equal basis with the rest of the general public. Its goal is to afford every individual the opportunity to benefit from our country’s businesses and services, and to allow each to benefit from the patronage of all Americans. For existing buildings, the regulations require that architectural and communication barriers that are structural must be removed in public areas when their removal is readily achievable—in other words, easily accomplished and able to be carried out with out much difficulty or expense. All new and altered buildings also must meet the prescribed accessibility requirements.

The ADA (Title III) defines an "accessible" opening as one that provides a door with a minimum clear opening of 32", easily manipulated handles, a maximum opening force, a minimum closing time, and the capability of being opened to 90°.

Although all entrances or openings in a building need not be ADA-compliant, designated entrances must meet ADA requirements. In cases where the NFPA 101 Life Safety Code applies, it may take precedence over ADA when a choice must be made (check with local authority having jurisdiction). For example, the hardware on a fire-rated door would not have to meet all accessibility requirements if doing so would compromise its ability to meet life safety codes.

When faced with this situation, the specifier must decide what multiple functions an opening has and how to prioritize them. Whether on a new building or a renovation, the questions may include:

Must the opening be ADA accessible (compliant)?
Can this be achieved with a standard mechanical door closer?
Do door conditions, usage, or convenience call for a power operator?
What security requirements apply, and will they require card readers, biometrics, electric strikes and other electrical or electronic interfaces?

There are several ways to make an opening ADA compliant when it comes to specifying a door closer. For interior doors, the least costly is to use a standard mechanical closer but specify the size with the lowest power (size 1), which requires a force of less than five pounds to open the door as required by ADA code. A closer with adjustable spring power also can be used if it is set at the same maximum required opening force. If the door is in a corridor where the HVAC system creates a high pressure differential, this light force may not be enough to close and latch the door properly. In such cases, a power operator probably will be needed to meet ADA requirements. It also is likely to provide greater convenience for all users, depending on how the opening will be used and the type of operator that is selected. For 3' interior fire doors, NFPA 80 recommends a size 3 closer, which underscores the fact that fire doors need not comply with the 5-pound ADA requirement.

Exterior doors are another case. Neither ADA nor ICC/ANSI A 117.1 give an opening force limit for exterior doors. Because they may be subject to high wind conditions or other external influences, a power operator may be the best way to ensure both ADA compliance and effective operation.

For power operators in particular, it may be necessary to consider product design and its effect on the application. Some power operator designs are driven by a motor and gears and sometimes separated by a clutch. Even when the doors are being operated manually, the motor and gears are being turned, and this could shorten their life on a high-usage opening. Unless the door will be operated automatically most or all of the time, it may be better for these applications to select a power operator that is built around a standard mechanical hydraulic door closer with the addition of a motor and clutch. Then it will function as any other mechanical closer most of the time, with a pushbutton-operated power assist available when needed.

Power operator features and options make it possible to meet a variety of application situations. Power operators that are designed for primarily automatic opening can be opened manually when needed. Even fully automatic sliding doors (high-energy doors) can be pushed open manually in an emergency (called full break out feature). Many power operators can be tied into a building’s fire alarm system so they will fail-safe and automatically close if the alarm is activated; thus maintaining the fire wall or fire barrier integrity. However, they can be opened manually under these conditions to allow safe egress.

Building Codes and Positive Pressure Requirements

The push for positive pressure began under the jurisdiction of the International Congress of Building Officials (ICBO), which had produced the Uniform Building Code, in the early '90s and was adopted in 1996. During this same period, a move developed to combine the three model building codes into a single, national code, by a model code group known as the International Code Council (ICC). The ICC would combine model codes produced by the BOCA (Building Officials and Code Administrators), SBCCI (Southern Building Code Congress International), and ICBO into a single model code. The working draft of the International Building Code was published in May, 1997, with a statement allowing the test protocol to be determined by the local authority having jurisdiction.

Further impetus was added with the recent publication of NFPA 5000, the first building code developed through the American National Standards Institute (ANSI) –accredited process. NFPA 5000 is an integral part of the Comprehensive Consensus Codes™ (C3) set, which currently is being developed by NFPA and several partner organizations. This model code recognizes positive pressure testing for fire doors and provides yet another option for municipalities and states looking to update their building codes. An online review of NFPA 5000 is available at www.nfpa.org

Since positive pressure requirements first were introduced, the initial concerns have been answered, and gaps in information have largely been filled. As more jurisdictions have begun to adopt UL10C standards for UBC 7-2, earlier concerns about how to meet them have been replaced by an awareness of where and when they apply. UL 10C is a positive pressure fire test that is designed to replicate more closely what happens to a door in an actual fire and to verify that the door and hardware are in compliance with the positive pressure requirements set forth in the Uniform Building Code under UBC 7-2. In the test, door hardware over 40" high is affected more than in the previous test, and the intent is to improve its ability to provide fire and life safety in the event of a fire.

Under the previous fire test, no internal pressure was applied to the door opening. Instead, air was pulled from the non-fire side of the door into the chamber on the fire side of the door. If there were small gaps between the door and frame, the air flowing through them, from the non-fire side to the fire side and out the exhaust, would prevent most flame transfer to the non-fire side. The positive pressure test reverses this flow, drawing the air in through the sill and forcing it out through the operating clearances between the door and door frame. This makes it much more likely that there could be some flame transfer through any gaps between the door and the frame, especially at the top of the door where most closers are mounted.

Higher temperature levels from the test may cause the closer’s hydraulic fluid to expand and escape from the closer or the closer cover to melt. Although the closer is often mounted on the non-fire side of the door, the test determines whether the hydraulic fluid could leak enough or the cover to melt enough to support combustion and cause the fire to spread to the non-fire side of the door. It is useful to know that some manufacturers supply UL10C approved product as standard, while other manufacturers upcharge for the UL10C approved product. If compliance with UL10C is required, this should be considered when comparing alternatives.

Architects and specifiers should check the following points to ensure compliance with UL10C:

Check current projects to determine whether UL10C compliance is required.
Make sure that UL10C compliance is written into the master specification.
Get a letter of certification from the manufacturer to ensure that products specified are in compliance.
Make sure the products submitted and installed are in compliance. Look for the compliance label "Conforms to Standards UBC 7-2 (1997) and UL 10C."

Although they are far from universal, building codes that include positive pressure compliance gradually are being adopted as the standard by more and more state and local municipalities. Most manufacturers have revised their fire labels to show that specific products have been approved by Underwriters Laboratory (UL) or Warnock Hersey and comply with positive pressure tests under UBC 7.2 (1997) and UL 10 C, making it easy to select the right door, frame and hardware.

Getting the Information and Support You Need

Today more than ever, it is imperative to provide every facility with the highest applicable levels of safety and security. At the same time, it is necessary to comply with an ever-growing list of building codes and other regulations, including ADA, the NFPA 101 Life Safety Code, NFPA 80 Standards for Doors and Windows, and other federal, state and local building codes. With this in mind, it can be helpful to partner with manufacturers that follow these changing requirements closely and can provide guidance in resolving seemingly conflicting demands. As you look to develop such partnerships, consider whether the manufacturer has the ability to work with you in creating a multi-level, layered approach to key management, access control and security. Such an approach begins with mechanical access and egress, including doors and their hardware, mechanical locks, keying systems and portable security; it progresses through electronic access control and key management, including standalone and hard-wired systems; networked access control and biometrics are added to manage perimeter and controlled public openings; and a final layer of facility integration encompasses management of both assets and people, including access control, time and attendance, and personnel scheduling. This foundation will enable a facility’s security to grow with its needs, with a broad-based resource for solving safety and security dilemmas.

Note: A brochure on meeting ADA accessibility requirements is available through Ingersoll Rand distributors or from Ingersoll Rand Security Technologies, 877-840-3621.