Doorways in paths of travel to exits “Differences of Interpretation”

By Beau Zaia, Development Consultant, Senior Building Surveyor

I recently was requested by a client to provide advice on an interpretation that was made by the certifier on a project regarding a sliding door non-compliance within a new pub.

The certifier raised that the new sliding doorway within in the pubs VIP Room (aka) Pokie Room triggered a non-compliance with NCC D2.19 due to the following:

Certifiers Comment:

“My interpretation of Clause D2.19 of the BCA is that a sliding door is not permitted to be installed in a path of travel to an exit:

D2.19 Doorways and doors

(a)A doorway in a resident use area of a Class 9c building must not be fitted with—

(i)a sliding fire door; or

(ii)a sliding smoke door; or

(iii)a revolving door; or

(iv)a roller shutter door; or

(v)a tilt-up door.

(b)A doorway serving as a required exit or forming part of a required exit, or a doorway in a patient care area of a Class 9a health-care building

(i)must not be fitted with a revolving door; and

(ii)must not be fitted with a roller shutter or tilt-up door unless—

(A)it serves a Class 6, 7 or 8 building or part with a floor area not more than 200 m2; and

(B)the doorway is the only required exit from the building or part; and

(C)it is held in the open position while the building or part is lawfully occupied; and

(iii)must not be fitted with a sliding door unless—

(A)it leads directly to a road or open space; and

(B)the door is able to be opened manually under a force of not more than 110 N; and

(iv)if fitted with a door which is power-operated—

(A)it must be able to be opened manually under a force of not more than 110 N if there is a malfunction or failure of the power source; and

(B)if it leads directly to a road or open space it must open automatically if there is a power failure to the door or on the activation of a fire or smoke alarm anywhere in the fire compartment served by the door.

The sliding door has the potential to obstruct people evacuating and can pose problems if the door fails during an emergency”

The above interpretation made by the certifier was subsequently disagreed with by myself with the following response being made to the client:

Clause D2.19 (b) applies to doorways that “serve as a required exit or form part of a required exit”

Examples include= doorways leading to fire isolated stairs and exit doors egressing direct to open space.

Clause D2.19 (b) does not apply to “doorways in the path of travel to a required exit”. In this instance the sliding door is deemed a “doorway in the path of travel to a required exit” and as such it can remain in its proposed location on the provision it complies with NCC Clause D2.19 (c) which requires the following:

A power operated door in the path of travel to a required exit, must be openable manually under a force of not more than 110N if there is a malfunction or failure of the power source.

Furthermore, Clause D2.21 also talks about “doorways in the path of travel to a required exit”. This Clause will require that the sliding door be fitted with manual controls that are 25mm wide, proud of the surrounding surface and located for the sliding , within 2mof the doorway and clear of surface mounted door in the open position.

To put it simply, think of a Westfield shopping centre. Almost every bank in the centre has a sliding as the entrance. As long as the sliding doors complies with the provisions above there is no problem.

In summary, my interpretation of the sliding door was accepted by the certifier and the client was satisfied with Credwell’s consultancy services.

The moral of the story is that doorways that serve as a required exit or form part of a required exit and doorways in the path of travel to a required exit are very different things that need close attention when making an assessment.

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