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Compliance

 

Rubek Automatic Doors and where we fit regarding compliance

 

 

Rubek and Compliance

 

Overview

 

The only legal compliance requirement in Australia for an automatic door is the BCA or NCC.

 

All automatic sliding door operators manufactured by Rubek Automatic Doors fully complies to all relevant sections of the BCA. Always have and always will. In fact we exceed safety requirements.

 

The Australian Standards that refer to automatic doors are AS5007 and AS1428.

 

AS1428 is a mandator Standard referenced in the BCA that deals with door clearance and openings with regard to disabled access. Rubek always assists to make sure designs meet these minimum requirements.

 

AS5007 is a guideline and not a mandatory Standard as it is not referenced in the BCA or legislation. Rubek manufactures automatic sliding door operators that exceed the safety, endurance and power fail requirements of AS5007.

 

Rubek sliding door operators all comply fully to the fire code.

 

DIN18650 is included here to raise awareness of its irrelevance in Australia's market. This is the adopted European Standard for automatic doors and would appear to be the basis AS5007 was created from, as opposed to what we believe are just claims that AS5007 is solely the amalgamation of AS4085 and AS4290. Important to note that in Europe DIN18650 is compulsory and in Australia AS5007 is not.

 

As compulsory requirements in their own countries the main difference between the DIN18650 and Australia's BCA however is that door operators that are imported into Australia, usually from Europe or China, with a DIN18650 compliance certificate are highly likely to not pass our BCA particularly Section D2.19(b)(iv)(A) for 110N of manual force. This is because in Europe they allow up to 150N of force. The reason for this is that in Australia we typically have bigger heavier doors whilst door operators designed in Europe and China are built to drive small light doors and therefore are in themselves small and lightweight with very small housings. Small housings always mean smaller internal parts including smaller motors which have to be highly geared, the result of which is that the doors cannot possible be manually moved with 110N of force as our BCA calls for.

 

The same technical problems apply to sliding door operators built in Australia that are also small or lightweight, forcing the use of small highly geared drive systems that may also not comply with the BCA. And, as we have already mentioned above, no NATA Laboratory in Australia conducts any BCA or AS5007 safety testing whatsoever; meaning you have no idea if it complies to the BCA or not. When an automatic door is installed, acording to the Building Commission, the responsibility of BCA compliance and safety falls with the local shire council office. Trouble is the local council only tests to make sure the doors open on a fire signal when doing a fire test and its the fire testing company that actually does that test. The local council officials do no other testing and in our experience, don't know how to.

 

The responsibility of safety and automatic doors is a complex one. But in summary we have the following situation:-

 

  • there is no proper testing for automatic door safety available in Australia,
  • a guideline in AS5007-2007 which is non-sensical in calling for full certification, among other things, when that is simply not possible and has not been possible since its approval 8 years ago,
  • a Building Code that states a minimum requirement of safety by looking at competitive effects, cost of compliance and net benefits
  • local councils that are responsible for BCA compliance by the States Building Commissions but don't and can't test all aspects of automatic door safety,
  • European Standards marketed in Australia that are not in line with our BCA,
  • which all aids greatly some manufacturers and service companys in misleading architects, specifiers, builders, fabricators and end users by twisting the BCA and AS5007 wording to suit their own design and sales agendas to the detriment of end user safety.

The only way any specifier or buildng owner can safeguard themselves and can be assured that they have an automatic door that is safe and complies with the BCA is by getting it in writing from the manufacturer before purchase (at specification stage) and after commissioning in the form of a manufacturers compliance certificate. Rubek will always be compliant and will always issue a full compliance certificate.

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Building Code of Australia and National Construction Code

The Building Code of Australia (BCA) is Volumes One and Two of the National Construction Code (NCC). The BCA is produced and maintained by the Australian Building Codes Board (ABCB) on behalf of the Australian Government and State and Territory Governments. The BCA has been given the status of building regulation by all States and Territories.

The goal of the BCA is to enable the achievement of nationally consistent, minimum necessary standards of relevant safety (including structural safety and safety from fire), health, amenity and sustainability objectives efficiently. This goal is applied so—

  • there is a rigorously tested rationale for the regulation;
  • the regulation generates benefits to society greater than the costs (that is, net benefits);
  • the competitive effects of the regulation have been considered and the regulation is no more restrictive than necessary in the public interest; and
  • there is no regulatory or non-regulatory alternative that would generate higher net benefits.

The BCA contains technical provisions for the design and construction of buildings and other structures, covering such matters as structure, fire resistance, access and egress, services and equipment, and energy efficiency as well as certain aspects of health and amenity.

The BCA is the ONLY legal entity that an automatic door must comply with which includes any relevant Australian Standards referenced from within it.

 

The main sections of the BCA applicable to automatic doors are D1.6, D2.19 and D2.21

 

The BCA (Building Code of Australia) is still the ONLY legal requirement that ALL automatic doors must fully comply with and that includes Section D2.19(b)(iv)(A) below that states a door  “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”.  It is NOT acceptable for a door to be driven open in the event of a malfunction. AND the term malfunction applies to the whole operator and not just the power supply as some companies portray it.

 

Main BCA sections useful for automatic doors in detail:

D1.6 Dimensions of exits and paths of travel to exits 

In a required exit or path of travel to an exit— 

    (a)  the unobstructed height throughout must be not less than 2 m, except the unobstructed height of any doorway may be reduced to not less than 1980 mm; and 

    (b)  the unobstructed width of each exit or path of travel to an exit, except for doorways, must be not less than—

      (i)  1 m; or 
      (ii)  1.8 m in a passageway, corridor or ramp normally used for the transportation of patients in beds within a treatment area or ward area; and 
      (iii)  in a public corridor in a Class 9c aged care building, notwithstanding (c) and (d)— 

        (A)  1.5 m; and 
        (B)  1.8 m for the full width of the doorway, providing access into a sole-occupancy unit or communal bathroom; and 

    (c)  if the storey or mezzanine accommodates more than 100 persons but not more than 200 persons, the aggregate unobstructed width, except for doorways, must be not less than— 

      (i)  1 m plus 250 mm for each 25 persons (or part) in excess of 100; or 
      (ii)  1.8 m in a passageway, corridor or ramp normally used for the transportation of patients in beds within a treatment area or ward area; and 

    (d)  if the storey or mezzanine accommodates more than 200 persons, the aggregate unobstructed width, except for doorways, must be increased to— 

      (i)  2 m plus 500 mm for every 60 persons (or part) in excess of 200 persons if egress involves a change in floor level by a stairway or ramp with a gradient steeper than 1 in 12; or 
      (ii)  in any other case, 2 m plus 500 mm for every 75 persons (or part) in excess of 200; and 

    (e)  in an open spectator stand which accommodates more than 2000 persons, the aggregate unobstructed width, except for doorways, must be increased to 17 m plus a width (in metres) equal to the number in excess of 2000 divided by 600; and 
    (f)  the unobstructed width of a doorway must be not less than— 

      (i)  in patient care areas through which patients would normally be transported in beds, if the doorway provides access to, or from, a corridor of width— 

        (A)  less than 2.2 m — 1200 mm; or 
        (B)  2.2 m or greater — 1070 mm; and 
        where the doorway is fitted with two leaves and one leaf is secured in the closed position in accordance with D2.21(a)(v), the other leaf must permit an unobstructed opening not less than 800 mm wide; or 

      (ii)  in patient care areas in a horizontal exit — 1250 mm; or 
      (iii)  the unobstructed width of each exit provided to comply with (b), (c), (d) or (e), minus 250 mm; or 
      (iv)  in a Class 9c aged care building— 

D2.19 Doorways and doors 

    (a)  A doorway in a resident use area of a Class 9c aged care 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—
       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. 

D2.21 Operation of latch 

    (a)  Except as required by (b), a door in a required exit, forming part of a required exit or in the path of travel to a required exit must be readily openable without a key from the side that faces a person seeking egress, by a single hand downward action or pushing action on a single device which is located between 900 mm and 1.1 m from the floor, except if it— 

      (i)  serves a vault, strong-room, sanitary compartment, or the like; or 
      (ii)  serves only, or is within— 

        (A)  a sole-occupancy unit in a Class 2 or 3 building or a Class 4 part; or 
        (B)  a sole-occupancy unit with a floor area not more than 200 m2 in a Class 5, 6, 7 or 8 building; or 
        (C)  a space which is otherwise inaccessible to persons at all times when the door is locked; or 

      (iii)  serves the secure parts of a bank, detention centre, mental health facility, early childhood centre or the like and it can be immediately unlocked— 

        (A)  by operating a fail-safe control switch, not contained within a protective enclosure, to actuate a device to unlock the door; or 
        (B)  by hand by a person or persons, specifically nominated by the owner, properly instructed as to the duties and responsibilities involved and available at all times when the building is lawfully occupied so that persons in the building or part may immediately escape if there is a fire; or 

      (iv)  is fitted with a fail-safe device which automatically unlocks the door upon the activation of any sprinkler system complying with Specification E1.5 or smoke, or any other detector system deemed suitable in accordance with AS 1670.1 installed throughout the building; or 
      (v)  is in a Class 9a or 9c building and— 

        (A)  is one leaf of a two-leaf door complying with D1.6(f)(i) or D1.6(f)(iv) provided that it is not held closed by a locking mechanism and is readily openable; and 
        (B)  the door is not required to be a fire door or smoke door. 

    (b)  The requirements of (a) do not apply in a Class 9b building (other than a school, an early childhood centre or a building used for religious purposes) to a door in a required exit, forming part of a required exit or in the path of travel to a required exit serving a storey or room accommodating more than 100 persons, determined in accordance with D1.13, in which case it must be readily openable— 

      (i)  without a key from the side that faces a person seeking egress; and 
      (ii)  by a single hand pushing action on a single device such as a panic bar located between 900 mm and 1.1 m from the floor; and 
      (iii)  where a two-leaf door is fitted, the provisions of (i) and (ii) need only apply to one door leaf if the appropriate requirements of D1.6 are satisfied by the opening of that one leaf. 

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Australia Standard AS5007-2007 : Powered Doors for Pedestrian Access and Egress Abstract

Proposes requirements for the design, and test methods for, drive units, leaves and components of powered pedestrian doors, including constructions that are operated electro-mechanically, electro-hydraulically or pneumatically.

This Standard sets out the requirements for design and test methods for drive units, leaves and components of powered pedestrian doors. Such door constructions may be operated electro-mechanically, electro-hydraulically or pneumatically.

This Standard also provides requirements for design of the installation, verification/testing, marking and commissioning of the complete powered pedestrian door installation.
This Standard does not apply to the following:

    (a) Powered doors where the door leaves move vertically.
    (b) Powered doors mainly intended for vehicular traffic or access for goods.
    (c) Powered pedestrian gates or barriers.
    (d) Powered pedestrian turnstiles.
    (e) Powered doors used on lifts.
    (f) Power operated in environments where there is risk of explosion.

Application

This Standard applies to all powered pedestrian doors used in all types of buildings as classified in the BCA and other building legislation as appropriate. Doors can be of sliding, folding, swing and revolving type with a horizontally moved leaf.

Powered pedestrian doors can be used in all types of entrances including escape or rescue routes and emergency exits, as well as on smoke and fire doors.

Powered pedestrian doors with specific security needs to override the requirements of this Standard. Refer to Clause 3.3.4 for specialized operations.

Compliance with this Standard does not in any way preclude the use of any alternative solution which can be shown to satisfy the requirements.

IMPORTANT NOTE : Contrary to the implication made above in Paragraph 1 of Application (from Section 1.2 of same Standard), this Standard is NOT referenced in Legislation or the BCA and is therefore deemed a guideline and NOT a mandatory requiremment for any automatic door in Australia.

AS5007 in detail

At present there is NO NATA accredited test laboratory in Australia set up to test and certify to the full scope of AS5007-2007. Therefore FULL NATA certification to AS5007-2007 is not possible and does NOT EXIST.
Exova Warringtonfire in Victoria and ALS Global in Queensland and Victoria are the only NATA laboratorys with partial accreditation to test a small part of AS5007-2007. This partial testing is for Sections 4.4.1 Endurance and 4.4.2 Power Fail. To date they CANNOT and DO NOT conduct any testing for safety (Section 4.4.3, Table 4.1) which is most (~85%) of the standard and we believe is the most important part.

Exova : “At this stage we do not conduct the full scope of Table 4.1. We established a service which catered for the endurance testing, particularly at temperature extremes, which was not otherwise available in the Australian market.” Source, Patrick Motteram (Laboratory Manager), Exova Warringtonfire

Further-more this same standard (compiled by the Australian Auto-Door Industry Forum, among others) calls for, in Section 4.6, full compliance and therefore full NATA Certification which given the above is non-sensical and not possible. Section 4.6 reads as follows:
4.6 Verification of Compliance – All powered pedestrian door operators shall be subject to a type test by a NATA recognised testing authority, verifying compliance with this standard.

Rubek Automatic Doors accepts and believes in the spirit in which the standard is written and can state that all current Rubek automatic door operators fully comply or exceed all relevant sections of the standard with the only exception being section 4.6 (see above) relating to full NATA compliance testing for the reason above. FULL CERTIFICATION IS NOT POSSIBLE AS THERE IS NO LAB SET UP TO DO IT.
There is presently NO automatic sliding door operator in Australia tested as fully compliant with FULL certification to AS5007-2007.
After 8 years AS5007-2007 is still not referred to in Government legislation or building code regulations and is therefore a guideline and NOT a legal requirement.

Any automatic door company reporting to have FULL compliance certificates for AS5007-2007 we would recommend highly that you gain copies of these certificates and verify their content.

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Australian Standard AS4085

Superceeded by AS5007-2007 in 2007

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Australian Standard AS4290

Superceeded by AS5007-2007 in 2007

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Australian Standard AS1248 : Design for Access and Mobility

Sets out minimum design requirements for new building work, as required by the Building Code of Australia (BCA), to enable access for people with disabilities. It covers aspects of access to and within a building.
This publication is available in our OnTheGo format.

This Standard specifies the design requirements for new building work, as required by the Building Code of Australia (BCA) and the Disability (Access to Premises - Buildings) Standards (Premises Standards), to provide access for people with disabilities. Particular attention is given to -

    (a) continuous accessible paths of travel and circulation spaces for people who use wheelchairs;
    (b) access and facilities for people with ambulatory disabilities; and
    (c) access for people with sensory disabilies

NOTE: The BCA and Premises Standards set out requirements for other features of the accessible built environment not covered in this Standard, such as lifts, hearing augmentation, tactile ground surface indicators, signage, glazing, lighting, car parking and toilet numbers, and distribution.
This Standard does not include requirements for -

    (i) wheelchairs that have dimensions exceeding those shown in Figure 1; or
    (ii) motorized scooters.

Application

This Standard is referenced by the BCA and the Premises Standards for the provision of access for people with disabilities. As a BCA and Premises Standards referenced document, it is applicable to buildings as and when specified in the BCA and Premises Standards.

NOTE: Compliance with this Standard may also be required by other regulatory authorities.

This Standard provides the technical detail required to achieve the level of access for a deemed-to-satisfy solution.
The requirements specified in this Standard are intended to permit general use of buildings and facilities by people with disabilities acting independently, or where a person’s usual method of operation is with an assistant, in the company of that assistant.

NOTE: The Standard is based on data resulting from empirical testing of persons aged between 18 and 60 years and may not be appropriate when applied to persons outside this age range.
The dimensions stated in this Standard, relevant to the use of wheelchairs, relate to the 80th percentile wheelchair size and user (see Figure 1), except at the following locations where the 90th percentile dimensions are required:

    (a) On an accessway, at the location of a turn greater than 60°.
    (b) New accessible sanitary facilities.
    (c) At doorways, including door width and circulation space.

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European adopted German Standard DIN18650 : Powered Pedestrian Doors


This standard specifies requirements for the design of, and the relevant test methods for, drive systems, door leaves and fittings of powered pedestrian doors. Powered pedestrian doors may be operated electro-mechanically, electro-hydraulically or pneumatically.

This standard covers powered pedestrian doors used in escape routes, as fire-resisting and/or smoke control doors and those for all other applications.

The types of door dealt with here include powered pedestrian sliding, swing, revolving, sliding swing (balanced) doors and powered pedestrian folding doors with horizontally moving leaves.

This standard does not apply to powered room partitions, powered doors with vertically moving door leaves, powered doors mainly intended for vehicular traffic or access for goods, powered doors within industrial premises, powered pedestrian gates or barriers, powered pedestrian turnstiles, powered lift doors, or doors operating in environments where there is a risk of explosion.

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European Standard EN16005 : Powered Pedestrian Doors

These new regulations cover safety in use of power operated pedestrian door sets used for normal access, in escape routes and as fire resistance and/or smoke control door sets. Power operated pedestrian doors including sliding, swing, revolving door sets, balanced and folding door sets with a horizontally moving leaf, hence forward need to comply to the EN 16005 as well as already existing legislation.

Starting April 10th, 2013, all new installations must comply with the EN 16005. However, this does not apply to power operated door sets put in use before the official CEN document was published on October 10th 2012.

The EN 16005 forms a workable bridging document between the existing requirements of DIN18650, Risk Assessmant from BS7036:1996 and the European Machinery Directive in that it compels manufactures to produce safer products and enables installers to provide safer completed installations.

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