I am doing an ADA upgrade or a 40+ year old community center.  About 40 doors require upgrades.  There are about 7 doors that would be required by current code to have panic hardware and swing in the direction of egress travel, but which currently open opposite to egress travel and have only round door knobs.  Presumably, these doors met code when the building was built.


Can I just replace the round knobs with lever hardware, or must I do the much more expensive upgrade to change the door swing and provide panic hardware?  My project is for ADA improvements only, and there are no upgrades or modifications to program spaces other than restrooms and a locker room which must be reconfigured for accessibility.  In some cases changing the door swing will require construction of new walls to recess the door away from the corridor.


Is there anything in the IBC or CBC that exempts accessibility upgrades from triggering requirements to upgrade the path of egress?  Specifically, which of the following would trigger requirements for egress upgrades of the doors?

  1. Adjustment of closer force, work on the threshold, addition of a bottom push plate.
  2. Change of hardware on an existing door.
  3. New door in existing frame, for the purpose of providing ADA compliant vision panel in the door.  The new door requires new hardware as well.
  4. New, wider door and frame to provide 32" clear width.
  5. Relocated door and frame in existing or new wall as needed to provide ADA required push and pull side clearances.
  6. How about upgrades to hardware on a sliding door used for a second egress of an atrium space with 160 occupants, where current code requires swing doors?
Original Post

Presuming the building is publicly owned (City or County) and the upgrade is for an ADA Transition Plan and there is an actual transition plan with architectural barriers identified to be mitigated:


11B-202.4 Path of travel requirements in alterations, additions and structural repairs. When alterations or additions are made to existing buildings or facilities, an accessible path of travel to the specific area of alteration or addition shall be provided. The primary accessible path of travel shall include: ...


4. Alterations solely for the purpose of barrier removal undertaken pursuant to the requirements of the Americans with Disabilities Act (Public Law 101-336, 28 C.F.R., Section 36.304) or the accessibility requirements of this code as those requirements or regulations now exist or are hereafter amended consisting of one or more of the following items shall be limited to the actual scope of work of the project and shall not be required to comply with Section 11B-202.4:
1. Installing ramps.
2. Making curb cuts in sidewalks and entrance.
3. Repositioning shelves.
4. Rearranging tables, chairs, vending machines, display racks, and other furniture.
5. Repositioning telephones.
6. Adding raised markings on elevator control buttons.
7. Installing flashing alarm lights.
8. Widening doors.
9. Installing offset hinges to widen doorways.
10. Eliminating a turnstile or providing an alternative accessible route.
11. Installing accessible door hardware.
12. Installing grab bars in toilet stalls.
13. Rearranging toilet partitions to increase maneuvering space.
14. Insulating lavatory pipes under sinks to prevent burns.
15. Installing a raised toilet seat.
16. Installing a full-length bathroom mirror.
17. Repositioning the paper towel dispenser in a bathroom.
18. Creating designated accessible parking spaces.
19. Removing high-pile, low-density carpeting.

Now the difficult issues:

Unless you do complete forensics on the building for code of the day when constructed and whether the construction as it exists is actually compliant to code of the day, then what doesn't comply is subject to correction.


The alterations may not trigger full access compliance if there is a valid & up to date transit plan. However there are a couple of considerations for fire/life safety that can be enforced (and most likely will be) by Fire Marshal and Building Official. If you have existing doors that open counter to egress direction and today's code requires in egress direction, then most likely the doors are in violation of the codes 40 yrs ago. (I have been around that long) Door and exit requirements in the 1973 UBC result in a very similar egress system compared to 2013 CBC. There is a high probability that the building has been altered over time and may not have been given proper plan review and inspection.


There is a general obligation in the ADA architectural standards that exits must be accessible. This is a retroactive requirement and the City or County was supposed to have surveyed the facility, determined compliance, and had any corrective work completed by 1993. From your description of the problems, it appears the exits are not compliant.


Your question #6 is troubling: a sliding door has never been allowed by code for a second required exit.



Jim, thanks for your reply.  I feel lucky to have a copy of the original plans, but of course there are no code notes, so I have no idea how the occupancy of the atrium was originally calculated.  It has one swing door egress (with door swing opposite to egress travel) and two sliding glass doors.  Maybe they didn't consider it an assembly space (although it has 1200 SF of paving) and so it only needed one exit door. 


But the real issue for me is how much of my client's limited construction budget, which comes from Federal grant funds for accessibility improvements, must be spent on fixing existing life safety code violations.  We may be able to upgrade only two of the four restrooms, for example, because the budget may not be sufficient to do all of them.  It's the opposite of the usual "how much accessibility must I provide in conjunction with this renovation".

Take a look at the transition plan (if there is one) and see if there are any priorities for what should be done first, second, etc. It is generally accepted in prioritizing access corrective work to ensure fire/life safety first. 


I have attached a criteria document used many times for public agency transition plans.


Jim, thank you for the document.  It's very useful.  Also, your perspective on the relative importance of life safety upgrades.

Sounds like it was never to code to begin with. Doors swinging in the direction of egress at a particular occupant load has been around for as long as I can remember.   Does the sliding door have a breakaway feature for emergency egress?   That would be the only way I could see that being allowed.


The lawsuits for a loss of life due to non code complying egress would be significantly more than an ADA infraction lawsuit.  Now that they are fully aware of the exiting deficiencies I think they should address those issues.

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