# Vision panel in door?



## JPohling (Aug 20, 2015)

I am completing an accessibility checklist from the State of California for State Leased Facilities.  The previous checklist from 2011 does not have this requirement.  The current checklist for 2013 has a requirement that if there is a vision panel within the door then the lower edge must be at a maximum of 43" AFF. All of these fire rated doors have narrow vision lites with the bottom edge at +48".  Clearly not complying.

I am trying to anticipate a solution.  Does anyone think that installing a peephole at an elevation less than 43" will be compliant, and or meet the intent of the code?  Lots and lots of rated doors so I cannot just cut in a larger/lower vision panel and maintain the rating easily/inexpensively.  These are all entries into hearing rooms.  If a peephole is to be used............which direction should it view?  going into the room?  going out of the room?  Install two, one in each direction?   Accept it as complying with CBC when the facility was constructed in 2010?  2010 ADA required the 43" max.

Also I am having a difficult time understanding the language regarding "edge protection" on a ramp.  "A curb, 2 inches high minimum, or barrier shall be provided that prevents the passage of a 4" diameter sphere, where any portion of the sphere is within 4" of the finish floor or ground surface.   CBC 2013 11B-405.9.2

I have a 3.5"H continuous curb with handrail above.  I have always interpreted this to be complying.  My 3.5" curb is taller then the 2" curb specified, but, lets say that my 4" sphere is 3.75" above the floor, it would just pass right over the curb.    Perhaps there needs to be another horizontal tube between handrail supports?   Or is it a curb *OR* barrier?  and the 3.5" curb is sufficient?

What say you?


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## mtlogcabin (Aug 20, 2015)

*EXCEPTION: *Vision lights with the lowest          part more than 66 inches (1675 mm) from the finish floor or ground          shall not be required to comply with 404.2.11.

Install a solid panel cover or paint the vision panel to a height of 67 inches AFF.


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## JPohling (Aug 20, 2015)

Sneaky!  Unfortunately with opaque film or paint the lowest part of the "glazing panel" would still be below 66", you just wouldn't be able to see through it.  Not sure I can hang my hat on that?


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## ADAguy (Aug 20, 2015)

Modification of a fire door in the field is a "no-no".

Given the year in which the building was built the 48" may be allowed.

As to the curb, your 3.5 is fine but I can't visualize the handrail relationship, is there a drop-off greater than 30" next to the ramp?


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## mtlogcabin (Aug 20, 2015)

> Modification of a fire door in the field is a "no-no".


Taping a piece of paper over the glass or painting a fire door is not a modification


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## JPohling (Aug 20, 2015)

ADAguy said:
			
		

> Modification of a fire door in the field is a "no-no". Given the year in which the building was built the 48" may be allowed.
> 
> As to the curb, your 3.5 is fine but I can't visualize the handrail relationship, is there a drop-off greater than 30" next to the ramp?


ADAGuy,  build out was 2010.  ADA required the 43" max at that time.   No drop offs greater than a few inches from ramp.

I believe there is an exception to allow field installation of a peephole into a 20 minute rated door.  Or I could be wishing I remember there was one?


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## Msradell (Aug 20, 2015)

I don't believe the peephole would meet the intent of the regulation.  Somebody who's disabled and most likely in a wheelchair to be that low is going to have an extremely difficult time getting close enough to the door to use the peephole.  I do agree that the curb is fine, I read and interpretation someplace that as long as the curb was higher than the centerline of the 4" sphere it was fine and that makes sense because at that point the momentum of the ball would not carry it over the curb.


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## north star (Aug 20, 2015)

*$ : $ : $*



On the Peep-holes thingy, ...IMO, the peephole should be on the

inside [ of the Hearing Room ] looking out, to check for any type

of fire & smoke \ other type of event before exiting the Hearing

Rooms........That being the case, this would have to be a "side

approach" type of action......Are there sufficient enough

clearances;  in each of the Hearing Rooms,  for a peephole

[ viewing device ] to be installed at a max. height of 43 inches ?

FWIW, ...I  do not believe that installing a peephole device

would meet the intent or the Letter of the viewing requirements.

Too small to be realistically functional.



*$ : $ : $*


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## JPohling (Aug 21, 2015)

Thanks for the confirmation on the curb issue.    All public visitors are escorted back to the hearing rooms and the rooms are card key access only.  Not that that makes any difference at all.  Need a periscope device!

What the heck is the rational for the exception to allow a vision panel above +66" AFF without a lower vision panel?  It's above the average eye level?

Does anyone believe that the peephole *would* meet the intent of the code?  It certainly doesn't seem to be equivalent, but allows vision into the space.


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## Francis Vineyard (Aug 21, 2015)

I think the intent for peepholes are for residential applications.  Is there enough room to install a fire rated sidelight panel next to the door opening or contact a manufacturer for a transparent glass block design in the wall?


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## JPohling (Aug 21, 2015)

I think it would be more cost effective to get new doors with proper vision lites.  card readers and light switches would need relocation as well.


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## ADAguy (Aug 21, 2015)

AS to residential, hotels, motels and multi family require peeps but the peeps have 180 degree viewability (for the benefit of the occupant).

Point made however that doing a perpendicular approach by some is not possible and must/should be considered.

Also note that unlike a vision panel, you must get up close and personal with a peep vs a VP which benefits people on both sides of the door, a peep does not allow for two-way viewing.


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## mark handler (Aug 21, 2015)

IMHO

The peep hole does not provide equal access.

Peep holes are used in commercial/retail for security of rear doors

Changing out the door is the best option.

The curb 2 inch is a CA thing. The intent is not just for wheels on chairs, but for walkers, canes. The intent is to keep them on the ramp

I do not see a conflict between the two


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## mark handler (Aug 21, 2015)

2" Edge Protection
	

	
	
		
		

		
			





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