BCAB 1962 - Requirement for power door operators in accessible floor areas

Requirement for power door operators in accessible floor areas

Project Description

The project is the design and construction of a new 6-storey building.  A large portion of the first storey contains commercial uses; the other large portion contains residential uses.  On the first storey, the residential portion contains multiple residential suites as well as an amenity area for use by residents of the residential portion of the building.  The residential suites and the amenity area have doors into a public corridor which connects to the main residential building entrance.  Within the amenity area are two other rooms; a co-work room and an accessible washroom.  Occupants of the commercial portion of the building do not have access to the residential public corridor or to the amenity area.

It is proposed that the door between the amenity area and the public corridor, as well as the doors to the co-work room and the washroom within the amenity area, will have self-closing devices and will not be provided with hold-open devices or with power door operators.

Applicable Code requirements (BCBC 2024)

Sentence 3.8.2.7., Division B, Power Door Operators

(1) Except as provided in Sentences (2) and (3), and except for doors provided with hold-open devices, doors equipped with a self-closing device shall be equipped with power door operators complying with Subsection 3.8.3. that allow persons to activate the opening of the doors in the intended direction of travel, where the doors are located

(a) in an entrance referred to in Article 3.8.2.2., including the interior doors of a vestibule where provided,

(b) in an accessible path of travel, between the entrance referred to in Clause (a) and the entrance doors to suites or rooms served by a public corridor or a corridor used by the public (see Note A-3.8.2.7.(1)(b)), and

(c) in an entrance to an accessible washroom.

Note A-3.8.2.7.(1)(b), Division B, Power Door Operators for Interior Doors.

It is not intended that all doors located in an accessible path of travel be equipped with a power door operator, but rather those that are located within public areas of the building, such as public corridors or corridors used by the public.  Doors of suites served by a public area do not need to be equipped with a power door operator.

Note A-3.8.3.6.(17), Division B, Public Area.

In the context of Sentence 3.8.3.6.(17), “public area” is intended to refer to a suite, room or area that is generally open to building occupants, such as a cafeteria, lounge room, washroom or office, but is not intended to include a space such as a janitor's room, service space or service room.

Decision being appealed (Local Authority’s position)

Note A-3.8.2.7.(1)(b), Division B, indicates that doors in public areas require power door operators and only doors to suites are excluded.

Note A.3.8.3.6.(17), Division B, effectively defines “public areas” as those areas which are generally open to building occupants.

The door between the public corridor and the amenity area, as well as doors within the amenity area, are in “public areas” of the building.  Power door operators are required on any of these doors that have self-closing devices if they do not have hold-open devices.

Appellant's position

Power door operators are required for any doors within the public corridor, between the building entrance vestibule door and the amenity area door, but this requirement does not include the door into the amenity area from the public corridor.

Also, for the purpose of this appeal, the two doors to rooms within the amenity room area will not be equipped with power door operators.

Appeal Board Decision #1962

The Board varies the decision of the local authority.

It is the determination of the Board that the door between the public corridor and amenity area, as well as the door to the co-work room, do not require power door operators.  The door to the accessible washroom requires a power door operator.

Reason for decision

Article 3.8.2.7., Division B, of the BC Building Code 2024 (the “Code”) is derived entirely from new language in the model National Building Code of Canada 2020 except that “barrier-free” in the model code is restated as “accessible” in the Code.

In reaching the decision, the Board relied on meeting minutes of the “Task Group on Accessibility” of the Canadian Commission on Building and Fire Codes, the group that developed the new wording.  In the minutes, it is clear that the use of the word “between” in Clause 3.8.2.7.(1)(b), Division B, was not intended to include the first door in the series (i.e., the entrance or vestibule door, which would be an unnecessary duplication of the requirement in Clause (1)(a)) or the last door (i.e., a suite or room door) in the series.  Rather, “between” was intended to mean any door in the accessible path of travel that one might encounter after the entrance door, and before the suite or room door.  In the case of the appeal, no doors fit that description.

(To illustrate the meaning of the word “between” as was used by the Task Group in this case, it could be said that only the numbers two through nine would qualify as possible picks if a person is asked to pick a number “between” one and ten.)

The Board observes that Note A-3.8.2.7.(1)(b), Division B, might appear to distinguish between “suite” doors and “room” doors, as was asserted by the Local Authority.  Despite the incomplete wording in the Note, it is understood that the requirements related to power door operators were intended to be the same for the suite and room doors described in Clause 3.8.2.7.(1)(b), Division B.

The Code (and the minutes) are clear that the accessible washroom door, which in this case has a self-closing device and does not have a hold-open device, requires a power door operator.  The door to the co-work room does not.

Don Pedde
Chair, Building Code Appeal Board

Dated:  May 1, 2025