UL 325 & ASTM F2200

---

UL 325 is a standard for safety that addresses the automatic operation of garage doors, vehicular gates, louvers, and windows.  New UL 325 standards went into effect on January 12, 2016, requiring that each entrapment point must have two Monitored Safety Entrapment devices.  Gate Operators must now monitor for fault conditions of external entrapment protection devices. The 2009 International Building Code (IBC) requires compliance with UL 325 Safety Standards.   

ASTM  stands for American Society for Testing and Materials. ASTM describes itself as "A globally recognized leader in the development and delivery of international voluntary consensus standards". Today, some 12,000 ASTM  standards are used around the world to improve product quality, enhance safety, facilitate market access and trade, and build consumer confidence." http://www.astm.org They are a product safety group similar to Underwriters Laboratory (UL).

F2200 is the standard that pertains to automated vehicular gates.  F2200 recognizes five gate classifications:  horizontal slide, horizontal swing, vertical lift, vertical pivot, and overhead pivot. This standard pertains mostly to the construction of the gate itself. It also describes other parts of the gate systems, such as rollers, positive stops, guides, and hinges. ASTM F2200 assumes that  gates will be installed with UL325 compliant gate operators, so its  standards are harmonized with UL325.

UL 325 provides methods for testing, installing, and operating automated gate and door systems, primarily related to safety performance.  UL 325 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.  It also addresses safety concerning potential fire and electrical hazards, as well as the safety of the general public.  

For end users and property owners, there is a liability and responsibility to ensure your sites and systems are up to date, safe, and user friendly.  In most states, it's the LAW!

We work directly with you to inspect, review, discuss, upgrade, and maintain your systems to meet the highest possible level of saftey to protect your customers, employees, and your company.

Every site and location is different, and all of them have special needs and considerations.  The different classifications of sites are broken down like so:

• Class I: "A vehicular gate operator (or system) intended for use in garages or parking areas associated with a residence of one-to four single families." 
• Class II: "A vehicular gate operator (or system) intended for use in a commercial location or building such as a multi-family housing unit (five or more single family units), hotel, garages, retail store, or other buildings accessible by or servicing the general public." 
• Class III: "A vehicular gate operator (or system) intended for use in an industrial location or building such as a factory or loading dock area or other locations not accessible by or intended to service the general public."
• Class IV: "A vehicular gate operator (or system) intended for use in a guarded industrial location or building such as an airport security area or other restricted access locations not servicing the general public, in which unauthorized access is prevented via supervision by security personnel."

Manufacturers, system designers, and installers use these classifications to determine the requirements for each system type, and ensure the design meets the saftey and security needs of your site.
 

Q:   Is compliance with UL 325 a national law? 

A:   No.  However, most states have adopted some level of enforcement regarding the standard.  For example, in the state of Alabama, UL 325 requirements are governed by Fire Code 2009 of Alabama.  In addition, after August 2016/2018, ALL new construction must meet or exceed UL 325 and ASTM F2200 standard to comply with electrical, building, and fire codes.  This means you will likely be inspected or checked to meet codes in order to occupy your new construction facilities.

Q:   Who is going to check the gate system to determine if it is in compliance with the new standard? 

A:   If you're a current or new customer of Anchor Parking & Perimeter Security, we will!  However, keep in mind,  building code officials will be inspecting gate systems for compliance with the IBC and enforced.  And more importantly there is the HUGE potential for liability if a gate system is not installed in compliance with UL 325.  More on that below.

Q:   Am I required to upgrade existing installed operators to the new UL 325 standard? 

A:   No. There is no retroactivity with respect to UL 325.  In other words, you can be "grandfathered" on a system that was installed prior to 2016.  However, you still leave yourself open to liability, insurance claims, customer damage issues, and death/dismemberment risk.  You may also have issues with your local insurance requirements or legal representative if your site poses a risk of injury or death due to an unsafe automated system.

Q:   Can older operators that do not meet the standard, still be repaired?  

A:   Yes, but at the discretion of the service provider. At any time the technicians or sales team feel the site is so unsafe that serious risks are imminent or likely, they may/will refuse to provide service to your site/equipment.  In some cases service can be provided, but a disclaimer will be done in the form of the customer signing a copy of the saftey checklist done by the technician on site.  This is done to show proof that the site representative was shown the deficiencies, and currently was not ready to make the needed changes at that time.  

We at Anchor Parking are EXTREMELY serious about saftey and security.  If our technicians feel someone could get hurt, and an owner or operator have ignored good judgement, they may choose to discontinue service at any time.  You may wish to contact your attorney or your trade association legal counsel regarding liability issues in repairing older operators that have no entrapment sensing provisions or have design/installation flaws.

It's also important to note, that if a system requires changing an internal control board, most manufacturer's are not keeping old Non-UL boards indefinitely.  At some time, you will be required to install a UL 325 compliant control board.  Some manufacturer's (like Liftmaster), REQUIRE external entrapment devices be connected to those boards in order to operate.  If you do not have monitored entrapment protection devices installed, they may be required in order to complete the board replacement and return the unit to service.  

Q:   Can I upgrade to the new operators to stay compliant?  

A:   Absolutely!  There are no requirements to upgrade existing serviceable operators. However, upgrading is highly recommended for older systems that do not have inherent saftey features, inherent motor auto-reversing or systems that do not have any/correct entrapment protection options.  You are only asking for trouble if you know something is wrong and don't say anything!

Q:   What is the difference between a primary and secondary entrapment protection device? 

A:   The secondary entrapment protection device is intended as a backup feature should the primary device fail or not work properly.

Q:   Do photoelectric cells or electric edges have to be installed on all gates?  

A:   Not necessarily; these two options are among several acceptable options. Contact Anchor Parking & Perimeter Security for acceptable protection devices to be installed on a particular gate/site.

Q:   Do I have to install both photoelectric cells and reversing edges as secondary devices to be in compliance with the standard?  

A:   No; you do not have to put both on the gate. Either a non-contact sensor, a contact sensor or a combination thereof can be used as secondary devices.

Q:   Do gate operators manufactured prior to August 1st, 2018 require Monitored Entrapment Protection Sensors?

A:   Yes and No. Monitoring of external entrapment protection sensors is only required when the automatic gate
operator is manufactured after January 11, 2016. There is no requirement to update a pre-2016 operator to
comply with the newer standard.     

Q:   Will an operator function if a photoelectric cell or reversing edge is not connected? 

A:   This is dependent on the operator design.  Anchor chooses to prioritize saftey over security for Classes I & II sites.  Classes III & IV are situational based on the specific site.

Q:   If a reset switch is to be installed, where does it have to be installed?  

A:   UL 325 requires that "Controls intended to be used to reset an operator after two sequential activations of the entrapment protection device or devices must be located in the line-of-sight of the gate."

Q:   How far away from the gate should an access device (push button, card reader, etc.) be installed?  

A:   The last sentence of Section 51.8.4 f) reads, "Controls must be far  enough from the gate so that the user is prevented from coming in contact with the gate while operating the controls."  For vehicular access of standard vehicles, 12 feet is our standard ideal minimum.  Larger vehicles range from 16-20 feet.

Q:   Do I have to install a separate pedestrian gate? 

A:   UL 325 states that if the operator is for a vehicular gate, pedestrians must use a separate entrance.  In addition, the same rule as above applies here.  The pedestrian gate must be far  enough from the gate so that the user is prevented from coming in contact with the vehicular gate to avoid entrapment possibilities when operating the pedestrian gate.  We recommend pedestrian gates whenever possible to try and deter people from using the automotive gate as a pedestrian gate.

Q:   Do the new UL 325 requirements apply to both new and existing gates?  

A:   UL 325 requirements apply to all new construction gate systems and existing gate systems (installed after January 2016) that could be motorized. Older non-motorized gates may need to be altered to meet the new requirements.

Any system installed after August 2018 MUST BE COMPLIANT!

Q:   Do I have to install guarding or screening on a gate?  

A:   Yes. However, this applies only to horizontal sliding gates. The important fact to remember is that if a horizontal gate system is not  guarded or screened in accordance with the manufacturer's instructions, it cannot be claimed to be in compliance with UL 325.  The maximum gap allowed is 2-1/4".  Any gaps larger than that require mesh, screen, or other covering to prevent hands, arms, legs, and feet from being pinched while the gate is moving.  We also use mesh on other gaps on other gate designs in entrapment areas.

Q:   Does the 2-1/4 inch sphere test start at the bottom of the gate or is it measured from the ground up to 4 feet? 

A:   UL 325 requires that "All openings of a horizontal slide gate are guarded or screened from the bottom of the gate" (underline added...)

Q:   If a slide gate is on wheels/castors and there is a 4 inch gap between the ground and the bottom of the gate, is this OK?  

A:   The UL325 standard does not include provisions governing the gap between the bottom of the gate and the ground.  However, the American Fence  Association (AFA), DASMA and the National Ornamental & Miscellaneous  Metals Association (NOMMA) are working on a joint gate construction and  installation standard that will address this matter.  Other standards, like Mil-Spec, have exceptions to this due to security or encroachment restriction.

Q:   Do swing gates need to be guarded or screened so that a 2-1/4 inch sphere will not pass through it?

A:   No.

Q:   Is there a difference between a UL listed product, an ETL listed product, or a product listed by anyone else?  

A:   Any listing by a nationally recognized testing laboratory (NRTL) that  tests to the UL 325 standard is acceptable. The test laboratories are  expected to use the same standard.

Q:   What is the minimum number of external  entrapment protection sensors (combination of photo eyes and edge  sensors) required in a typical automated gate installation?

A:   The correct answer depends on the type of operator, the type of gate, and the number of entrapment zones that must be protected.  Generally speaking, there needs to be 2 forms of entrapment protection in each direction of movement (opening and closing).

Q:   So what else changed in the 7th Edition UL 325, effective 8/1/2018?

A:   There are several noteworthy wording clarifications and additions, as noted below: 

1. Entrapment zones have now been defined for each type of gate.  
2. An important clarification stated that every external entrapment protection sensor installed must be monitored.
3. Common work around techniques to bypass monitoring have been specifically prohibited: It shall not be possible to make simple modifications in the field by adding, suppressing, or changing either on the operator or external entrapment protection device(s), to bypass,  interfere with, or otherwise defeat the monitoring function, via a) The connection of wires; b) Terminals; c) Switches; d) Jumpers; or e) Components supplied with the operator or external entrapment protection device. 
4. Manuals shall not provide instructions for which the stated  purpose is to reprogram, reconfigure, or reset the monitored outputs  such that they do not comply with the minimum entrapment protection  requirements, except to revert to original factory settings.
5. The operator shall not be provided with resistors installed or intended for installation across the terminals that are intended for monitored external entrapment protection devices and the manufacturer shall not recommend the use or installation of such resistors.
6. A component, such as a resistor, capacitor, etc. required for monitoring shall be permanently installed at the factory by the manufacturer of the entrapment protection device. 
7. UL 325 - 7th Edition of is now the National Standard in Canada for Door & Gate Operators.

We understand this is a lot to take in.  It all seems like a lot of jargon, and most of it feels like it is just another hoop to jump through.  We can assure you, it's not!  As with most rules, they are in place to help prevent something bad from happening, or because something bad has already happened.  These gates are heavy, made of metal, move at a fast rate of speed, and can/do injure, hurt, and kill!  We strive on providing you systems that do their job, but also keep you, your employees, your customers, children, pets, and everyone else safe!  Nothing is worth risking the life of the people near you, please don't risk it!  

All Anchor Parking & Perimeter Security technicians and sales staff are factory trained and certified by our manufacturers to ensure the highest level of knowledge and saftey possible!

Call right away if you feel your system may not be safe or compliant.  We hate hearing after a vehicle was damaged, an insurance claim was made, or forbid, a person was hurt when it could have been prevented!  

Contact us today to schedule an inspection of your site and system!