36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

Section 404.2.10 requires that swinging doors and gates have a smooth surface on the push side that extends their full width. This provision derives from the ANSI A117.1‒1992 standard and is intended to permit wheelchair footrests to be used in pushing open doors without risking entrapment on the stile. This provision requires that parts creating joints in the smooth surface are to be within 1/16 inch of the same plane as the other. Also, cavities created by added kick plates must be capped. Exceptions from this requirement are recognized for sliding doors (Exception 1), certain tempered glass doors without stiles (Exception 2), doors and gates that do not extend to within 10 inches of the floor or ground (Exception 3), and existing doors and gates (Exception 4).

Comment. Exception 2 exempts tempered glass doors without stiles that have a bottom rail or shoe with the top leading edge tapered at 60 degrees minimum from the horizontal. Comments indicated that these types of doors should be exempt from the requirement for the smooth surface area on the push side, but should be subject to other portions of the provision covering surface joints and added kick plates.

Response. In the final rule, section 404.2.10, Exception 2 has been revised to exempt the type of tempered glass doors described only from the requirement for a smooth surface on the push side that extends the full width of the door. Such doors remain subject to specifications for parts creating joints in the surface and for provided kick plates.

In finalizing the rule, the Board determined that the cost of making existing doors or gates comply with the smooth surface requirement in alterations can be significant. An exception from this requirement for existing doors and gates is provided in the final rule (404.2.9, Exception 4). Under this exception, such doors or gates do not have to comply with the surface requirements, provided that cavities created by added kick plates are capped.