UL 325

Introduction

The standard that addresses the automatic operation of garage doors also contains provisions related to the automatic operation of gates. Over the past two years, the standard, UL 325, Standard for Door, Drapery, Gate, Louver and Window Operators and Systems, has undergone substantial revision. In this article we will provide you with some background information about UL and UL standards, update you on the current gate-related contents of UL 325, and advise you of some possible changes in UL 325 that may greatly affect the automatic gate industry.

What is UL?

Underwriters Laboratories, Inc., a not-for profit organization established in 1894, is self described as “the leading third-party certification organization in the United States and the largest in North America.” UL’s primary stated mission is “to evaluate products in the interest of public safety.” Note that while UL declares it is the “leading” third-party certification organization, it is not the only one. There are other testing laboratories and certification organizations in the United States.

What is a UL Standard?

UL standards are voluntary standards that establish minimum requirementsand are developed via an open, non-exclusionary process. “Voluntary” means that the standard has not been initiated through any government or similar regulatory agency mandate. “Minimum” means that the industry and those who developed the standard believe that the requirements should be met by all participants affected by the standard, and that more stringent provisions may be adopted by some in the industry. Finally, an “open, non-exclusionary process” indicates that any interested party can participate in the development of a UL standard. In addition, a number of UL standards have undergone a “canvass” (ballot) process in order to obtain recognition as American National Standards. The purpose of this process is to gain a wider acceptance of a specific standard. The canvass process typically includes interested individuals and organizations that may have direct or material interest in a particular standard. UL 325 is one of the standards that has attained the ANSI (American National Standards Institute) designation.

What is the UL 325 Standard?

For products within the scope of the standard, UL 325:

1. Contains the basic qualifying factors that products must meet in order to be documented (listed) and marked (labeled) as complying with the requirements of the UL 325 voluntary Listing and Labeling program.
2. Provides methods for testing products, primarily related to safety performance.
3. Covers installation of products in accordance with the National Electrical Code, which is maintained by the National Fire Protection Association (NFPA) and is in force nationwide. UL 325 is to be harmonized with this Code.
4. Addresses safety concerning potential fire and electrical hazards, as well as the safety of the general public.

How is UL 325 Used?

UL 325 is used as a basis to test products at a nationally recognized testing laboratory. Gate operators that choose to participate in a listing and labeling program submit their products for testing. If they are found to be in compliance with the UL 325 standard, they are “Listed” and receive a “Mark.” It is very important to remember two facts:

· There are laboratories other than UL that are capable of listing and labeling products. A “UL label” is not a generic term. People may use “Kleenex” or “Band-Aids” as generic terms, but the UL label must not be used that way.
· Products are not approved by UL or other laboratories. Approval implies acceptance of responsibility for compliance with standards. This responsibility lies with the listing and labeling applicant and not with the laboratory. The burden of proof regarding data always lies with the manufacturer.

Development of UL 325

The first edition of UL 325 was released in 1973. That edition was primarily focused on the electric operation of garage doors and did not contain provisions for gates. After federal laws were enacted in the early 1990’s, citing the provisions of UL 325 as applicable to garage door operation, the gate operator industry initiated the inclusion of electric gate operator provisions in UL 325. Some government agencies and other interested groups have monitored the standard’s progress and have provided input on the final format of the provisions of the standard that relate to gate operators.

UL 325 Important Dates

The UL 325 standard has two prominent dates. The first, September 18, 1998, is the date after which there will be no foreseeable substantive changes made to the standard. The second noteworthy date is March 1, 2000, the effective deadline for compliance with changes which have been identified by UL as requiring “substantial redesign and retest” of affected equipment. Additionally, March 1, 2000 is the operative date for compliance with revised instructions governing installation. It is important to remember that continual compliance is a requirement of maintaining a listing and labeling program.

Overview of UL 325 and Gates

Highlights of UL 325 include the following:

· A glossary which defines each type of operator
· Different “classes” of gate operators
· Entrapment* protection criteria for each “class” of operator
· Entrapment* alarm criteria
· Requirements for gate construction and installation
· Instructional requirements placing increased responsibility on installers

*In the document, “entrapment” is defined as “the condition when an object is caught or held in a position that increases the risk of injury.”

A key part of the UL 325 standard is a table that summarizes the entrapment device options for different classes of operators of the various types of gates included in the standard. The table, labeled “Table 30A.1,” is reproduced here from the 4th edition of the Standard for Safety for Door, Drapery, Gate, Louver, and Window Operators

and Systems, UL 325. It is reprinted with the permission of Underwriters

Laboratories, Inc. Refer to the table as you read about the provisions that are described in the following sections.

Gate Definition and Types

UL 325 defines a gate as “a moving barrier such as a swinging, sliding, raising, lowering, rolling, or the like, barrier that is a stand-alone passage barrier or is that portion of a wall or fence system that controls entrance and/or egress by persons or vehicles and completes the perimeter of a defined area.” The main types of gate operators/systems addressed in UL 325 are barrier, vertical pivot gate, horizontal slide gate, swing gate and vertical slide gate. It is important to note that all gates included in UL 325 are defined as vehicular gates and NOT PEDESTRIAN GATES. Property owners are expected to provide a separate entrance for pedestrian access.

Gate Operator Classifications

Four distinct types of classifications have been established:

Class I: Residential usage, covering one to four single family dwellings.

Class II: Commercial usage where general public access is expected; a common application would be a public parking lot entrance or gated community.

Class III: Industrial usage where limited access is expected; one example is a warehouse property entrance not intended to serve the general public.

Class IV: Restricted access; this includes a prison entrance that is monitored either in person or via closed circuitry.

The classes are defined by the entrapment protection requirements included in UL 325. These requirements are that: 1) each class must have primary and secondary entrapment provisions; 2) each class must have different types of protection for the different classes of operators as well as for the different categories of operators; and 3) the same type of device cannot be used for both primary and secondary protection.

An exception to compliance with the provisions of Table 30A.1 has also been noted in the standard. An operator considered exempt would require all of the following: 1) operates a vehicular barrier (arm) that is not intended to move toward a rigid object closer than 2 feet; 2) does not have a pinch point between moving parts by virtue of the operator’s design or complying installation; and 3) is not required to be provided with means to protect against entrapment.

Provisions of Note Regarding Gate Operators

We have identified nine notable provisions recently included in UL 325 that affect gate operators and related safety devices.

1. Class I and Class II operators must have an audio alarm which shall function if 2 sequential activations of the entrapment protection device occur. The “2 sequential activations” is noteworthy in that it is hoped that “nuisance” alarms will be kept to a minimum while still enhancing safe operation.
2. Class I and Class II slide gate operators shall not exceed a speed of 1 foot per second. Since both classes listed involve general public usage, the maximum established speed strikes a balance between any perceived security issue (a person immediately following the party controlling the gate) and any danger from a person being struck by a gate.
3. A Type B1 or B2 device serving as a Primary Safety Device shall be monitored for the presence and correct operation of the device, including the wiring to it, at least once during each open and close cycle. This requirement is included because these types of safety devices are often used as backup safety devices.
4. Manufacturers will be required to specify a brand and model number of external sensors compatible for connection to an operator. This provision arose from concern over the gate operator external devices acting in tandem as a system, with a fault rate of 6 failures in 1 million hours of use (which equates to 115 years of continuous operation).
5. After sensing an obstruction, reversing must begin within 2 seconds. This requirement is intended to keep a person from being entrapped in a stationary position by the gate system. After the first contact the gate must reverse and travel a minimum of 2 inches. If there is a second contact, the gate must stop, and requires a wired device to reset the operator.
6. After any obstruction reversal by either an A or B2 device, the timer-to-close is disabled until reset. Both A and B2 devices sense direct gate contact with an obstruction, and the devices must perform their intended function without interference from a timer-to-close action.
7. Stop the gate upon sensing a second sequential obstruction, and then not operate until an intended hard wired input is received. A person within the line of sight of the gate must see what has caused the second sequential obstruction and must resolve this obstruction before operating the gate.
8. If a Type C device is chosen, swing gates must not exert more than 40 pounds of force after initial start-up. The reasoning here is similar to the reasoning given for the speed limitation for horizontal slide gates.
9. Edges on swing gates are not permitted. Many interested parties, including DASMA, do not agree with this provision. It may be modified in the future.

Effect on Installations

The new provisions will have several effects on gate and fence dealers:

1. Gate and fence dealers should look for an indication of the Class of each operator, which will be specified by the gate operator manufacturer.
2. Fence dealer sales personnel must match the site application with the Class of operator. The gate operator manufacturer should be contacted if there is any question about the site application.
3. Both primary and secondary safety devices must be provided and matched to both the operator and site conditions. Although the gate operator manufacturer will either provide or specify these devices, the gate/fence dealer should insure that they are installed and correctly matched. Any questions should again be directed to the gate operator manufacturer.
4. Warning signs must be permanently affixed to the gate panel. UL 325 includes specific requirements on the format, content and placement of these signs.

FACTORS RELATED TO GATE CONSTRUCTION AND INSTALLATION

· Vehicular gate operators should ONLY be used on vehicular gates and never pedestrian gates.
· Adequate clearance should be provided between a swinging gate and adjacent structures to reduce risk of entrapment.
· A sliding gate should work smoothly with easy rolling/movement in both directions, prior to the installation of the operator.
· Controls should be as far away from the gate as possible to prevent “reach-through” occurrences.
· Warning signs and placards must be installed and be visible in the area of the gate.

Device-Specific Installation Instructions

There are also specific installation requirements for certain types of entrapment protection devices. These specific requirements emphasize the care and attention that each device must be given prior to and during installation.

For gate operators utilizing non-contact sensor devices (Type B1), instructions should be consulted for placement for each application, care should be exercised to reduce the risk of nuisance tripping, and one or more of these devices must be installed where the risk of entrapment or obstruction exists.

For gate operators utilizing contact sensor devices (Type B2), several requirements are spelled out in UL 325. One or more contact sensors shall be located:

· at the leading edge, the trailing edge, and also postmounted both inside and outside of, a vehicular horizontal slide gate;
· at the bottom edge of a vehicular vertical slide gate; and
· at the entrapment point of a vehicular vertical pivot gate.

A wired contact sensor shall be located, and its wiring arranged, so that communication between sensor and gate operator is not subjected to mechanical damage. A wireless contact sensor shall be located where the transmission of the signals is not obstructed or impeded by building structures, natural landscaping or similar obstructions, and shall function under the intended end use conditions.

For gate operators utilizing a continuous pressure activating device (Type D), controls must be placed so that user has full view of the gate area when the gate is moving. A placard must be placed adjacent to the controls and no other activation device shall be connected. Most importantly, an automatic closing device shall not be employed.

Statements in Manufacturer’s Instructions Concerning Installation

Gate and fence dealers can expect to see in gate operator instructions the following statements:

1. The operator must be appropriate for the construction of the gate and the usage class of the gate. The appropriate primary and secondary safety devices to be used are a major consideration to support this requirement.
2. All openings of a horizontal slide gate, and the portion of the fence where the slide gate passes, must be guarded or screened. These specific requirements in UL 325 that govern this provision were developed to address “reach-through” occurrences. For example, slide gates must have a protective cover 48 inches in height extending from the bottom of the gate/fence panel.
3. All exposed entrapment points must be eliminated or guarded. It is up to individual gate and fence dealers to identify these points on a product-by-product basis, or on a job-by-job basis.
4. Guarding must be supplied for exposed rollers. Exposed rollers are regarded as potential pinch points.

NEW CODE PROVISIONS
The below article was published in World Fence News in the November 2011 issue.

New code provisions address automated vehicular gate systems safety
BY JOE HETZEL, P.E., TECHNICAL DIRECTOR
DOOR & ACCESS SYSTEMS MANUFACTURERS ASSOCIATION (DASMA)

During the past two development cycles, four International Code Council(ICC) model codes have incorporated provisions to address automated vehicular gate systems safety. These provisions alert code authorities of the need for a safety inspection of automated gate systems to help reduce the number of injuries and deaths associated with these gates.
Until recently, no code authority has required a permit and safety inspection for an automated gate system. Consequently, the industry seeks to address this significant gap in public safety.

Potential injuries and death
Automated vehicular gate systems provide convenience and security. However, these machines also produce high levels of force, which can result in pinching injuries, impalements, broken bones, and, most seriously, asphyxiation and death. Therefore, proper site design, installation, maintenance and inspection are essential to reduce hazards.

Aggressive industry activity
The gate and gate operator industry has worked diligently to address automated gate system safety by creating standards and requirements to be included in job specifications. While such specifications would be best based on requirements found in ICC model codes, significant updates to standards needed to occur before success in the code development process could be achieved. Up until the mid-1990s, vehicular gate systems installed without adequate concern for pedestrians resulted in numerous injuries and deaths. The Consumer Product Safety Commission
(CPSC) collected data on these accidents and concluded that the existing standards needed strengthening. Thus, UL 325 – a gate and door operator standard that had been in existence since the early 1970s – was substantially revised in the late 1990s. UL 325 changes that became effective in March 2000 brought significant changes, requiring two levels of entrapment protection. Meanwhile, representatives of the American Fence Association (AFA), the National Ornamental & Miscellaneous Metals Association (NOMMA) and the Door & Access Systems Manufacturers Association (DASMA) first envisioned the inclusion of requirements in the Code Council model codes in 1998. They believed that codes should reference not only UL 325, but also additional standards that would govern gate design and installation. These groups formed an ad hoc committee to develop and maintain the content of a gate construction standard, known as ASTM F2200, which was first published in 2002.

A quick checklist for code officials
The contents of the UL 325 and ASTM F2200 standards are best summed up in the following checklist that code officials can use to perform a fast visual inspection of an automated gate system.
1. Listed/labeled operator: Automatic gate operators for vehicular gates must bear a “listed” label from a Nationally Recognized Testing Laboratory (NRTL) such as UL or ETL which indicates that the unit complies with the requirements of UL 325.
2. Warning signs: Warning signs instructing pedestrians to stay clear of the gate must be placed on both sides of the gate in clear view.
3. Separate pedestrian gate: Where pedestrians are likely to be present, a pedestrian walk gate must be provided in the vicinity of an automated vehicular gate. The walk gate must not be within the vehicular gate frame or the area where that gate travels.
4. Reversing sensors: All automated gates must have external sensors (typically edge sensors or photo eyes) properly installed. When triggered, the sensors will stop or reverse a gate in both the open and close directions of travel.
5. External operator controls: To avoid entrapment at the time of activation, all gate-operating controls must be mounted farther than 6 feet from the gate.
6. Openings in gate: All openings in a sliding gate up to a 6-foot height must be guarded or screened. (Editor’s note: This was recently changed from “up to a 4-foot height.”) Openings must be less than 2¼ inches.
7. Gaps around gate: Fences, posts or other stationary objects must be closer than 2¼ inches or farther than 16 inches away from all gates for their full travel length.
8. Travel stops: Permanent stops must be installed to prevent a sliding gate from traveling past the designed maximum open and close positions.
9. Fall-over protection: Braces or guards must be installed to prevent a sliding gate from falling should it somehow become disconnected from its supporting rollers.
10. Roller/wheel covers: To avoid the risk of crushing fingers or toes, all rollers and wheels that are mounted less than 8 feet above grade must be covered.
11. Gate protrusion limits: Pickets or other protrusions on the bottom or sides of all automated gates must not protrude more than ½ inch.
12. Independent gate motion: A swing or slide gate must not be installed on a slope, thus allowing motion to occur by the force of gravity alone, if disconnected from the operator.

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