Working with conflicting standards

In the 13 years since Congress signed the Americans with Disabilities Act of 1990 (ADA) into law, contractors have experienced confusion over exactly how the law affects fire alarm systems and what role they must play in complying with the law.

To properly administrate the provisions of the Act, the Department of Justice (DOJ) established a Code of Federal Regulations (28 CFR Part 36) that included the ADA Standards for Accessible Design (ADAAG).

Unfortunately, the DOJ did not write the guidelines using enforceable code language. To further complicate matters, most states also have accessibility codes. Some state codes match the federal regulation, and some do not.

For the most part, the ADA only affects manual fire alarm boxes and notification appliances.

The ADA maximum height for manual fire alarm boxes ranges from 48 inches where a disabled person will reach forward, to a maximum of 54 inches where a disabled person will reach the box from the side. In contrast, the installation height requirements of NFPA 72-2002, National Fire Alarm Code, range from 42 to 54 inches. In each case, a contractor would measure from the floor to the operable point of the box.

To comply with both ADA and NFPA 72, you can recommend that your electricians install all manual fire alarm boxes at a height of 48 inches to the box handle. ADA regulations require that controls and operating mechanisms be operable with one hand, and not require tight grasping, pinching or twisting of the wrist. The force required to activate controls cannot exceed 5 lbf (22.2 N). Most modern manual fire alarm boxes comply with these requirements.

Section 4.28 of the guidelines states, “At a minimum, visual signal appliances shall be provided in buildings and facilities in each of the following areas: restrooms and any other general usage areas (e.g., meeting rooms), hallways, lobbies, and any other area for common use.” And, “Visual alarm signal appliances shall be integrated into the building or facility alarm system. If single-station audible alarms are provided, then single-station visual alarm signals shall be provided.” Visual alarms must also consist of a clear xenon strobe, or equivalent, with a defined pulse duration and flash rate, and a 75-candela (cd) intensity. The manufacturers of visible fire alarm notification appliances have made available 15/75 candela appliances to comply with 75-candela intensity requirement.

Underwriters Laboratories Inc. has established a test standard for visible notification appliances for the hearing impaired, UL 1971. Unfortunately, the 75-candela rating of these combination appliances does not meet the UL 1971 requirements, as referenced in the National Fire Alarm Code. Contractors must use only the 15-candela rating of the appliances when complying with the visibility requirements of the NFAC.

ADA Guidelines also discuss the installation locations for these appliances, stating, “In general, no place in any room or space required to have a visual signal appliance shall be more than 50 feet (15 m) from the signal in the horizontal plane. In large rooms and spaces exceeding 100 feet (30 m) across, without obstructions 6 feet (2 m) above the finish floor, such as auditoriums, devices may be placed around the perimeter, spaced a maximum 100 feet (30 m) apart, in lieu of suspending appliances from the ceiling. No place in common corridors or hallways in which visual alarm signaling appliances are required shall be more than 50 feet (15 m) from the signal.”

Research has shown that the flashing strobe lamp needed to alert a hearing impaired person must deliver a minimum illumination of 0.4037 lumens/m2 (lux) [0.0375 lumens/ft2 ] to all occupiable spaces required to have such visible notification. This design equivalency meets the minimum light intensity requirements of both the ADA and NFPA 72. To help contractors select the proper size visible notification appliance, NFPA 72 has provided easy-to-use tables. When you review plans for estimating purposes, carefully observe the marked candela ratings of each of the appliances to ensure that your estimate will include the correct amount of appropriately rated appliances, and the appropriate amount of fire alarm system control unit power to operate them.

NFPA 72 and the ADA have essentially the same requirements for audible fire alarm notification appliances. However, NFPA 72 outlines these requirements in more detail, and provides measurement techniques to ensure compliance.

Fortunately, it looks like an end to the confusion is on the horizon. The soon-to-be-published and updated ADA Standards for Accessible Design will directly reference the NFPA 72-1996 requirements as the only means for compliance.