Steve Winkel, FAIA CASp The PREVIEW Group, Inc. Architects providing regulatory solutions
Chapter 11A in the California Building Code (CBC) contains the accessibility requirements for privately funded multifamily housing, which is any residential building with three or more dwelling units (four or more condominiums). Trying to determine the door push/pull clearances for doors leading into the unit and for those inside the unit is very confusing since the requirements appear in several places with different application scopes. Chapter 11A is very badly organized and difficult to follow. It is important to understand the organization of the chapter. There are several “Divisions” in the chapter that contain provisions applicable to different parts of the building.
The requirements for doors associated with dwelling units appear in two places, in Division III “Building Features” and in Division IV, “Dwelling Unit Features.” We will discuss each section in order.
Division III, Section 1126A, Doors
The doors addressed in Section 1126A are the entry doors, “1126A.1 Width and height of doors. Doorways which provide access to common use areas or covered multifamily dwellings. This is meant to apply to the “Primary Entry” door into the unit. This door is required to be 36” wide.
The door needs 24” of pull side clearance at exterior doors and 18” at interior doors (with 24” being “preferred” at all such entry doors). There are several figures which apply to door clearance for these entry doors only. They are figures 11A-8 A, B, and C. 11A-8A as shown below. Note that for these entry doors only it is likely that 12” push side clearance will be required for these doors since they will certainly have a latch and will likely have a closer in many cases, especially interior doors opening from a fire rated corridor. It is important to understand that these door clearance requirements do not apply to other doors inside the unit.
Division IV, Section 1132A, Doors
This section applies to doors into and inside the dwelling units. There is one reference back to Section 1126A:
1132A.1 Primary entry doors and required exit doors. The width and height of primary entry doors and all required exit doors shall comply with Section 1126A.1.
The rules for entry doors DO NOT apply to other doors inside the unit. Door clearances inside the unit must be 32”, which could allow a door slightly less than 36” wide. Entry doors must be 36” wide, but interior door requirements are based on clearances. Note that the push/pull clearances in 11A-8 A, B or C are NOT referred to in Section 1132A. Thus there are no push/pull clearances for doors inside the unit, except that there are additional requirements for doors associated with toilet rooms. The toilet room door requirements are contained in both of the design options available in Section 1134A. The language in the two options is very difficult to follow, but the requirements contained in 1134A.2 boil down to requiring 18” of pull side clearance at ALL toilet room doors, whether the rest of the toilet room is resigned to be adaptable or not. Option 1 is clear since it applies to an adaptable toilet room:
8. A minimum 18-inch (457 mm) clear maneuvering space shall be provided on the swing side of the door at the strike edge of the door.
Option 2 is selected when the designer wants to apply adaptable toilet room requirements to only one toilet room in a dwelling unit that has multiple toilet rooms. The door pull side requirements in Option 2 are more convoluted, but end up in the same place:
10. A minimum 18-inch (457 mm) clear maneuvering space shall be provided on the swing side of the door at the strike edge of the door.
One would think that Item 10 applies only to the adaptable bathroom. But, read on to the end of the list! Buried there is a huge gotcha!
When Option 2 is used, all additional bathrooms must comply with Items 8 through 12 above.
The loop-back at the end of the item list in Option 2 includes Item 10. Thus the code requires pull side clearance at ALL toilet rooms, whether designed under Option 1 or Option 2.
Confused? Welcome to the group.
Kerwin Lee, AIA, CASp ICC-Certified Accessibility Inspector And Plan Examiner ICC-Certified Building Plan Examiner email@example.com
Section 1126A only applies to the “Primary Entrance” to an individual unit and all other doors within the building. The only exception is additional “required” exits from from a unit that can be used as an entry, but this is very rare.
To add to the confusion, a “Publicly Funded Housing Project”, which is covered under Chapter 11B has totally different door requirements. Because these types of housing is covered under the Americans with Disabilities Act (American with Disabilities Act (ADA) and not the Fair Housing Act (FHA), the requirements are totally different. The American with Disabilities Act (ADA) treats public housing like transient lodging (hotel), but this is another topic for another time.