By Howard Moutrie
In NSW, the Building Commissioner oversees the standard of construction. This role was originally limited to Class 2 buildings but is being expanded to other classes of buildings.
In recent times, the Commissioner has ordered corrective work to the provision of the lift call button on lift door jambs, as per the example to the right, on the basis that the button is within 500mm of an internal corner. Initially, certifiers were requesting a performance solution to address this issue, but more recently, the use of a performance solution has been rejected by the Commissioner.
ACA has approached the Commissioner, explaining that their interpretation is incorrect and that the installation is compliant. Although we have had a positive response from a member of the Commissioner’s office, as yet we have no formal acknowledgment of their acceptance of our explanation. The basis of our submission follows.
The submission was signed by Howard Moutrie, Farah Madon and Eric Martin, all of whom participate in the Standards Committee for AS 1428, with Eric Martin also sitting on the Lift Standard Committee.
The issue relates specifically to the positioning of lift call buttons on the lift door frame, which are being rejected on the basis that they do not comply with Clause 7.3.3 of AS 1735.12-1999. This clause requires that the call buttons be located “not closer than 500mm from an internal corner or fixed obstruction”. The reason for this requirement relates solely to the ability of a person in a wheelchair being able to access the button and directly relates to Clauses 13.5.3 and 14.1 in AS1428.1, which provide the same requirement to access door opening controls and switches, power points, etc. all of which need to be operated by hand. To clarify, where the return wall creates a recess less than 300mm, as is the case in this example, this is not considered as an internal corner but a recess or reveal in the wall.
Firstly, some background. The version of AS1735.12 which is currently referenced in the NCC Vol 1 (BCA) was published in 1999. At that time, lift call buttons were not located on the lift door jamb and the current situation was not envisaged. The Standard was revised in 2020, although at this stage it has not been referenced in the NCC. This revision addressed the new design incorporating the call button on the jamb and quite clearly shows that the recess is not considered as an internal corner, where the recess is less than 250mm. See below, an extract from the Standard.
On the basis that the newer Standard can be considered as being representative of current thinking, it would seem logical that this would be sufficient verification that the installation is compliant, as it clarifies the requirement of 500mm from an internal corner. Out of interest, this is consistent with the International Access Standard ISO 21542.2021, which actually states that the lift call button can be located in a recess “limited to 250mm” deep.
So what is the criteria which determines the distance of 500mm? The 500mm from an internal corner relates to the positioning of a wheelchair to allow the button to be reached by the occupant. With the wheelchair positioned with a frontal approach, depending on whether the occupant can use either their left or right hand, the wheelchair may be positioned directly in front of the lift door or to the side of the door. The 500m is to allow the positioning of the wheelchair to the side of the door. If the wheelchair is positioned with a side approach, allowing for the person to reach the button, the wheelchair would extend past the call button and again, the 500mm is to accommodate this. It is exactly the same as operating a light switch or similar control or even accessing a door handle, although with the latter, additional space is required to operate the door and manoeuvre through it. This is explained in AS 1428.1 Supplement 1-1993.
The following diagrams, based on Figure C2 of AS 1428.1 Supplement-1993, show the reach ranges of a person in a wheelchair and indicates how the buttons are accessed from a frontal approach and a side approach. This is the basis of the design requirements. The frontal approach shows the space required when the wheelchair is positioned to the side of the door.
It can be seen from these diagrams that the location of the call button as indicated in AS1735.12- 2020 is functional. The Frontal Approach shows the situation where the wheelchair is positioned to the side of the door.
To draw a comparison, a standard door handle can be recessed from the plane of the wall and this is not considered an internal corner. See photo to the right.
AS1428.1 allows the door plane to be recessed up to 300mm from the wall plane. If this was not the case, basically every door would be non-compliant, as the handle, on one side at least, would be normally recessed from the wall plane.
With respect to this issue of the call button on the door jamb, we have been contacted by the Australian Elevator Association for advice and have provided some assistance to them in arguing this case. They have also advised us that the following comments by the Commissioner’s office have been made:
- The location of the button so close to the corner results in there being an obstruction to the button for persons with a visual impairment.
- Clause 7.3.3 indicates that it is intended to assist persons with a visual disability by referencing clause 7.1 which requires that where the up and down control buttons at landings are not located vertically within 200 mm of each other a tactile symbol and Braille equivalent shall be provided.
- The note below clause 7.3.3 also indicates the requirement to locate the buttons more than 500mm from corners is intended to prevent the button being obstructed for visually impaired persons sliding their hands on the wall.
These statements are incorrect. The requirement is solely based on the reach ranges of a person seated in a wheelchair. If locating the button no closer than 500mm to an internal corner was important for people with vision impairment then the requirements for Braille and tactile signs would have a similar requirement. With respect to Item 3, the note purely relates to wall texture and its effect on a person touching the surface; there is no relationship to the 500mm requirement.
The submission was made by the Access Consultants Association (ACA) with two aims. Firstly, to improve the understanding of those applying the building codes. Secondly, to raise the profile of ACA within the construction industry. As a member of ACA, please feel free to use it to support any situation of a similar nature you may have.