At its regularly scheduled meeting held on October 16, 2006 the Architectural Access Board reviewed the application of 521 CMR 39.4 - the regulation concerning the location on controls - to the location of light switches at entry doors. 521 CMR 39.4 requires that "all such controls shall be located at least 18 inches (18" = 457mm) from an interior corner."
Typically at the entry door into residential units a light switch is installed within a few inches of the latch side of the door. Often, due to the design of the entryway, the door latch is itself eighteen inches from the interior corner. In such cases, in order to install a light switch at least eighteen inches from an interior corner one would have to install the light switch on the door jamb or the door itself.
Diagram 1: Example Entryway
The Americans with Disabilities Act Accessibility Guidelines (ADAAG) require in Section 4.27.2 that clear floor space complying with Section 4.2.4 be provided at controls. Section 18.104.22.168 of the ADAAG requires that "one full unobstructed side of the clear floor or ground space for a wheelchair shall adjoin or overlap an accessible route or adjoin another wheelchair clear floor space." If the control falls within the wheelchair clear floor space required at the door, then the location of the control complies with the ADAAG requirements.
Diagram 2: Clear Floor Space at Door
Based upon its review on October 16, 2006 with consideration given to the ADAAG, the Board has voted to allow the installation of light switches in the horizontal center of the wall space adjacent to the latch side of the door. The Board's Subcommittee on Regulation will review the matter further so that code language can be promulgated to align this portion of 521 CMR with ADAAG.
Diagram 3: Example Location of Light Switch