When Doors Are Required to Have Kick Plates: Understanding ADA and CBC 11B Requirements

The short answer: Neither the ADA 2010 Standards nor the California Building Code (CBC) Chapter 11B actually require kick plates on doors.

What they require is a smooth bottom surface on certain doors, and kick plates are simply one way to achieve or protect that smooth surface.

Understanding the Smooth Surface Requirement

What the Codes Actually Require

Both the 2010 ADA Standards (Section 404.2.10) and CBC Chapter 11B-404.2.10 contain identical requirements for door surfaces.

Swinging doors and gates must have:

• A smooth surface on the push side only

• Extending the full width of the door

• Within 10 inches of the finish floor or ground (measured vertically)

• Parts creating horizontal or vertical joints must be within 1/16 inch of the same plane

• Any cavities created by added kick plates must be capped

Why This Requirement Exists

This smooth surface prevents canes, wheelchairs, wheelchair footrests, and walkers from getting caught on projections, joints, or hardware on the door's lower surface. It's a safety and accessibility feature, not an aesthetic

When Doors Are EXEMPT from Smooth Surface Requirements

Both codes provide four specific exceptions where the smooth surface requirement does not apply:

Exception 1: Sliding Doors

Sliding doors are completely exempt from the 10-inch smooth surface requirement because they operate differently and don't present the same snagging hazards.

Exception 2: Tempered Glass Doors Without Stiles

These doors are exempt when they have a bottom rail or shoe with the top leading edge tapered at 60 degrees minimum from the horizontal. This tapered design prevents snagging without requiring a full 10-inch smooth surface.

Exception 3: Doors That Don't Extend to the Floor

If a door or gate doesn't extend to within 10 inches of the finish floor or ground, the smooth surface requirement doesn't apply. Examples include:

• Dutch doors (upper portion only)

• Doors with large bottom clearances

• Gates with significant ground clearance

Exception 4: Existing Doors in Alterations

This is the most nuanced exception. Existing doors and gates without smooth surfaces within 10 inches of the floor are not required to have smooth surfaces added during alterations.

However, there's an important qualifier: If kick plates are installed on these existing doors during an alteration, any cavities created by those kick plates must be capped.

Understanding the Difference Between ADA and CBC 11B

The Codes Are Harmonized

When it comes to kick plate and smooth surface requirements, the ADA 2010 Standards and CBC Chapter 11B are identical. There are no differences in

• The 10-inch height requirement

• Which doors must comply

• The exceptions that apply

• Technical specifications for joints and surfaces

California adopted these requirements to align with federal standards, making compliance simpler for building owners and designers.

When You Might Choose to Install Kick Plates

While kick plates aren't required by code, they serve important practical purposes:

Protection Benefits

• Prevent damage from normal wear and tear on the lower part of doors

• Absorb impact from footfall, carts, wheelchairs, and other objects

• Extend door lifespan by protecting the door surface from dents, scuffs, and scratches

• Improve hygiene by keeping dirt, debris, and moisture from accumulating

When Kick Plates Make Sense

Property owners commonly install kick plates on:

• High-traffic doors (retail entrances, office building lobbies)

• Healthcare facilities where hygiene is critical

• Doors with narrow bottom rails that need protection

• Glass doors where the bottom rail is less than 10 inches

Common Compliance Issues

Violations of the Smooth Surface Requirement

The following items violate the 10-inch smooth surface requirement when located on the push side of a door:

Hardware and Fixtures:

• Surface-mounted vertical rod panic hardware with bottom rods and latches

• Patch fittings at the bottom of glass doors

• Full-height door pulls mounted on the push side

• Bottom-mounted locking hardware or flush bolts

Door Construction:

• Paneled doors where panels create more than 1/16" variation in plane

• Decorative surfaces with raised elements exceeding 1/16"

• Bottom rails less than 10 inches high (on standard swinging doors)

• Surface-mounted automatic door bottoms

• Kick-down door stops

Installing Kick Plates Correctly

If you choose to install kick plates to achieve or maintain compliance:

1. Height: Extend to 10 inches above the floor

2. Width: Extend to within 1 inch of the sides and bottom of the door

3. Surface: Must be smooth with no projections

4. Joints: Keep within 1/16 inch of the door plane

5. Cavities: Cap any space between the kick plate and glazing

6. Fasteners: Countersink all fasteners flush with the surfaces

Practical Application Scenarios

New Construction

All swinging doors along accessible routes must have either:

• A bottom rail at least 10 inches high, OR

• A kick plate installed to create a 10-inch smooth surface

Alterations to Existing Buildings

Existing doors may retain non-compliant bottom rails unless:

• The door itself is being replaced or altered

• Kick plates are being added (then cavities must be capped)

Different Door Types

Aluminum storefront doors: Must have 10-inch bottom rail or kick plate

Framed interior doors: Can use 4-inch bottom rail if top edge is tapered to 60° slope

All-glass patch-fitted doors: Meet requirements with clear, uninterrupted surface

Residential dwelling unit doors: Must comply if the unit must meet accessibility standards

Key Takeaways

1. Kick plates are NOT required by either ADA or CBC 11B—smooth surfaces are required

2. The requirement applies to swinging doors and gates on accessible routes (push side only)

3. Four exceptions exist: sliding doors, certain tempered glass doors, doors not extending to the floor, and existing doors in alterations

4. ADA and CBC 11B requirements are identical for smooth door surfaces

5. If you install kick plates, cavities must be capped and surfaces must be within 1/16" of the same plane

6. Protection value: While optional, kick plates protect doors in high-traffic areas and extend door lifespan

Understanding these requirements helps building owners, architects, and accessibility specialists make informed decisions about door design and alteration projects. The goal is accessibility and safety, not mandating specific products like kick plates—the codes give you flexibility in how you achieve the required smooth surface.

DISCLAIMER: The information provided in this post is for informational purposes only and does not constitute legal advice. Please consult a qualified attorney or consultant for advice tailored to your situation.