For most condominiums, apartments, skilled nursing facilities, hotels, and motels, operable windows in accessible and Type A dwelling and sleeping units must comply. It is important to keep in mind operable windows in hospital patient rooms are usually keyed, and intended solely for custodial or nursing staff operation, with emergency ventilation and egress addressed by mechanical systems and automatic smoke dampers. As yet, the special needs of staff members with physical disabilities have not been addressed relative to operable windows.
In most cases, windows are not required by code to be operable, because they are either:
- in a fully sprinklered building;
- in rooms directly opening into corridors leading to exits in two directions; or
- more than 22.86 m (75 ft) above the ground.
As such, they are not emergency escape and rescue openings (EEROs). So, if the designer prefers not to deal with operating window parts in Type A units, operable windows are not used. In some situations, this could be considered at odds with sound sustainable design practices, which would help ensure fresh air and a connection with the outdoors are made accessible to people with physical disabilities.
Most, but certainly not all, AHJs in the United States adopt IBC for new construction. For purposes of clarity, only the newest 2018 edition is addressed herein. Requirements for renovation and window replacement vary widely by jurisdiction and must be investigated on a project-specific basis.
IBC 2018 includes ICC/ANSI A117.1-2009 as a reference document, and cites its requirements as the basis for compliance. In a process spanning several years, A117.1 was updated by the ICC Accessibility Committee, and was approved for publication in January 2017, pending ANSI review. Although the updated 2017 version will not be referenced in the newest IBC, a number of significant changes to accessibility requirements for windows and doors will affect future code cycles.
The future: ICC/ANSI A117.1-2017
Most importantly, the updated ICC/ANSI A117.1-2017 standard references AAMA 513-14 to take the guesswork out of compliance determination. Other important additions and clarifications regarding windows and doors in the 2017 update include:
- maximum hardware operating forces for manually operated exterior doors along accessible routes were clearly defined—both a 67.7-N (15-lb) forward force in pushing or pulling hardware and
a 3.2 N-m (28 in-lb) rotational force to operate unlatching hardware; - to eliminate ambiguity regarding the forces and motions necessary to operate windows, it was clarified windows must open, close, lock
or latch, and unlock or unlatch, all within accessible limits (As Section 309 is titled simply “Operable Parts,” some confusion as to its applicability to both hardware operation and movement of the sash or vent has been evident in AHJ’s varied interpretations.); and - maximum operating force was increased to 37.7 N (8.5 lb.) for vertical and horizontal sliding windows, remaining at 22.2 N (5 lb.) for all other types. (It was deemed unrealistic to expect sliding-seal double-hung and horizontal rolling/sliding windows to meet the same maximum operating force as compression-sealed window types.)
(Some exceptions apply.)
