UL 325 & ASTM F2200 INFORMATION

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Introduction
Automatic vehicular gate operating systems provide convenience and security to the end user. The popularity of these systems has grown greatly over the past few years. With that growth has come increasing awareness of the inherent dangers of an improperly designed, installed, used or maintained system. In some applications, gate operators must use high level of force to move the gate. In others, pedestrians are mixed with vehicular traffic. In still others, inadequate safety features are specified or installed for the system. Persons coming into contact with a moving gate are in danger of “pinching” a portion of themselves or, even worse, becoming “entrapped” by the gate. A gate system is the gate operator, the gate panel, inherent entrapment protection device, external entrapment protection device, and any screening and physical barriers used to protect pedestrians in, around, and near and automated gate system.  If a system is not properly designed, specified, installed, used and maintained, serious injury or even death can result to someone in the vicinity of a moving gate. Over the past thirty months, the standard, UL 325 – Standard for Door, Drapery, Gate, Louver and Window Operators and Systems, has undergone substantial revision in response to growing concerns over the safety of automatic vehicular gate operating systems. This information is provided in an effort to help you understand the current automated gate-related contents of this standard and its impact on the gate and gate operator industry. It will also advise you of some of the possible changes pending for this standard. 
Underwriters Laboratories (UL) and its Standards
Underwriters Laboratories, Inc. (UL), 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” organization of this type, it is not the only one. There are several other testing laboratories and certification organizations in the United States but UL remains the one most people recognize and think of in this area. UL standards are voluntary standards that establish minimum requirements for many products on the market today. The term “voluntary” in this respect means that the standards are not initiated through any government or similar regulatory agency mandate. The term “minimum” also has specific meaning to this discussion in that the industry and those who developed the standard believe that all participants affected by the standard should meet the requirements and that some in the industry may adopt more stringent provisions. As you can see, these standards are developed via an open, non-exclusionary process involving UL scientists, industry members and other interested parties. In addition, a number of UL Standards have undergone a “canvass” or ballot process in order to obtain recognition by the American National Standards Institute (ANSI) as an American National Standard. This designation garners those standards a wider awareness and acceptance by the public. 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 have used this process to attain ANSI designation. 
What is the UL 325 Standard?
The first edition of UL 325 was released in 1973. That edition primarily focused on the electric operation of garage doors and did not contain any provisions related to gates or gate operators. After federal laws were enacted in the early 1990’s that cited the provisions of UL 325 as applicable to garage door operation, the gate operator industry initiated inclusion of electric gate operator provisions in UL 325. These provisions of the Standard were established, for all intents and purposes, in September of 1998. Some government agencies and other interested groups monitored the standard’s progress and provided input on the final format of the provisions of the standard that relate to gate operators as they were developed. As of March 1, 2000, all manufacturers that desired UL listing and labeling for their gate operator products were required to comply with the changes that UL identified as requiring “substantial redesign and retest” of the affected equipment. Additionally, March 1, 2000 was the operative date for compliance with the revised instructions governing installation. It is important to remember that continual compliance with the standard is a requirement of maintaining a listing and labeling program. 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 the products in accordance with the National Electric Code, which is maintained by the National Fire Protection Association and is in force nationwide (UL 325 is to be “harmonized” with this code) and
  4. Addresses safety concerning potential fire and electrical hazards as well as the safety of the general public.

Based on this, UL 325 is used as a basis to test products at a nationally recognized testing laboratory. Gate operator manufacturers that choose to participate in the listing and labeling program must submit their products for testing. If the laboratory finds them to be in compliance with the UL 325 standard, they are listed and receive a mark (label) indicating that compliance. It is very important to remember that there are laboratories other than UL that are capable of listing and labeling products; however, only products tested by UL can receive a UL label. Therefore, a UL label is not a generic term and should not be used in that manner. It is also important to understand that UL and the other laboratories do not “approve” products. Approval implies acceptance of responsibility for compliance with the standards when this responsibility ultimately lies with the applying manufacturer and not with the laboratory (the burden of proof of compliance always lies with the manufacturer). In general, UL 325 contains of the following highlights as regards gate operators:

  1. A glossary that defines each type of operator,
  2. A separation of gate operators into “classes;”
  3. Entrapment protection criteria for each class of operator;
  4. Entrapment alarm criteria;
  5. Requirements for gate construction and installation and
  6. Instructional requirements placing increased responsibility on the installers of gates and gate operators.

The term “entrapment,” as used in relation to gates and gate operators in UL 325, 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 the table that summarizes the entrapment device options for the different classes of gate operators of the various types of gate included in the standard.  We have listed the provisions in the following sections.

Gate Definition and Types according to UL 325
To begin with, we need to know what a “gate” is for purposes of this standard. UL 325 defines a gate as “a moving barrier such as a swinging, sliding, raising, lowering, rolling or 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.” Based on this, UL 325 addresses these main types of gate operators/systems: Vehicular Barrier (Arm) operator or system – an operator (or system) that controls a cantilever type device (or system), consisting of a mechanical or barrier that moves in a vertical arc, intended for vehicular traffic flow at entrances or exits to areas such as parking garages, lots or toll areas; Vehicular Vertical Pivot Gate operator or system – a vehicular gate operator (or system) that controls a gate that moves in a vertical plane that is intended for use for vehicular entrances or exits to a drive, parking lot or the like; Vehicular Horizontal Slide Gate operator or system – a vehicular gate operator (or system) that controls a gate which slides in a horizontal direction that is intended for use for vehicular entrances or exits to a drive, parking lot or the like; Vehicular Vertical Slide Gate operator or system – a vehicular gate operator (or system) that controls a gate which moves in the vertical direction and is intended for use for vehicular entrances and exits to a drive, parking lot or similar location and Vehicular Swing Gate operator or system – A vehicular gate operator (or system) that controls a gate which swings in an arc in a horizontal plane that is intended for use for vehicular entrances and exits to a drive, parking lot or the like. It is important to note that, after the initial definition of a gate, all gates and gate operator systems included in UL 325 are defined as vehicular gates and not pedestrian gates. A key provision of the design and installation of any gate system desiring UL 325 listing is the provision of a separate entrance gate for pedestrian access that is located outside the area used by the automatic gate operating system.
UL 325 Gate Operator Classifications
As mentioned above, UL 325 separates gate operators into “classes”. For purposes of the standard, there are four classes of gate operators as follows: Class I – Residential Vehicular Gate Operator – 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 – Commercial / General Access Vehicular Gate Operator – 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 – Industrial / Limited Access Vehicular Gate Operator – 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 – Restricted Access Vehicular Gate Operator – 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.
Entrapment Protection Devices Defined
 Some entrapment protection means are authorized only for certain types of gates as shown in the standard. A Type C device, for example, may only be used on a swing gate or barrier arm but not on a slide gate, vertical lift, or vertical pivot gate.  The UL325 standard defines the types of entrapment protection means in the following manner:

Table 32.1 of UL 325 – Protection Against Entrapment

Gate Operator Category

Horizontal Slide, Vertical Lift and Vertical Pivot                                         Swing and vehicular Barrier Arm

Entrapment protection types permitted:                                                     Entrapment protection types permitted:

A, B1, B2 or D (See definition below)                                                     A, B1, B2, C or D (See definition below)

Note: The same type of devices shall not be utilized for both entrapment protection means.  Use of a single device to cover both the opening and closing directions is in accordance with the requirement.

Entrapment protection types A, B1, B2, C, and D are:

Type A:  Inherent entrapment protection system.

Type B1:  Non-contact sensor (Photoelectric sensor or the equivalent).

Type B2:  Contact sensor (Edge or the equivalent).

Type C:  Inherent force limiting, inherent adjustable clutch or inherent pressure relief device. Note: UL 325 permits these only in swing gates and barrier arms.

Type D:  Actuating device requiring continuous pressure to maintain opening or closing motion of the gate, within line of sight of the gate.

Table 32.2 of UL 325 – Minimum Quantity of Entrapment Protection Means

Horizontal Slide Gate         2  for the Opening Cycle       2 for the Closing Cycle

Horizontal Swing Gate         2* for the Opening Cycle       2* for the Closing Cycle

Vertical Pivot Gate           2  for the Opening Cycle       2 for the Closing Cycle

Vertical Lift Gate            1  for the Opening Cycle       1 for the Closing Cycle

* For a horizontal swing gate operator, at least two independent entrapment protection means are required in each direction of travel. Except, if there is no entrapment zone in one direction of travel, only one means of entrapment protection is required in that direction of travel; however, the other direction must have two independent entrapment protection means.

Why UL 325
Why should I install UL 325 compliant operators? The answer is quite simple: Safety & Liability! In a climate that has made risk management paramount, we need to take every precaution to prevent potential injuries from occurring. UL 325 is a specific standard that addresses just that, prevention of personal injury from automatic security gates. The UL 325 standard addresses two basic areas:

  1. Gate operator manufacturers, and
  2. Gate operator installers

Gate operator manufacturers must follow strict guidelines in order to maintain their UL listing. Gate operator installers are key to completing the UL compliance process. Manufacturers issue specific instructions that must be followed by the installer to maintain UL compliance.   Installers are required to follow these instructions and identify entrapment areas and hazards that exist for their site.  Entrapment is preventable.  The additional cost of purchasing products, accessories, and installing per the UL 325 standard varies by gate operator type and brand. Slide and swing operators have a tendency to be more costly to install than a VPG due to the additional equipment requirements. No matter which system you decide to install, choose safety first. Choose a UL 325 Listed gate operator, identify all possible entrapment areas, and properly install entrapment protection devices.

What is ASTM F2200?
The previous sections provided an introduction to UL 325, which is the standard by which vehicular gate operators are manufactured and installed. ASTM F2200 also covers many of the same safety issues, but is related to the gate panel rather than the operator. ASTM F2200 is the standard by which vehicular gates intended to be automated are fabricated and installed.  ASTM F2200, which became effective on July 10, 2002, includes design and construction standards that fence fabricators and installers can reference to fill the void between operator and gate standards. ASTM F2200 applies only to the construction of gates that are intended to be automated. If a manual gate is later to be automated, the gate must conform to the current standards before it is automated.

UL 325 and ASTM F2200 are specifically intended to work together under a harmony principle.  Adhering to and understanding these standards can provide the owner with both the safety and security that a well installed automated gate system can provide.  Automated vehicular gates are, by design, intended to provide security and to limit access to property. This can result in a delicate balancing act between security and safety.  The need for security does not offset responsibility to prevent injuries due to entrapment, from protrusions or pinch points, or simple child’s play. Knowing, understanding and consistently following UL 325 and ASTM F2200 standards is a fundamental aspect of gate operator installer professionalism.

What some general requirement of ASTM F2200?
  ASTM F2200 standards are based on the type of gate and the applicable gate operator. The standard describes construction of the gate itself based on its operation. Gate types that are not specifically described within the standard are still subject to all applicable provisions. See the section above titled Gate Definitions & Types above in the UL 325 section.  There are provisions applicable for each type of gate. Some provisions, however, apply to all gates, regardless of type. The provisions include: Gate systems are to be provided with auxiliary supports to prevent a gate from falling over more than 45 degrees from its vertical plane when detached from supporting hardware.  There should be no protrusion greater than one-half inch on the bottom or vertical edge of the gate. No protrusion may have sharp edges regardless of length.  Allowable protrusions are top pickets and top decorative designs provided they are in a vertical plane with respect to the gate.  Barbed wire cannot be installed at a height lower than six feet, and barbed tape cannot be installed a height lower than eight feet for a gate panel intended to be automated.  The gate must be balanced so that it does not open or close on its own when disconnected from the operator.  These are just some general requirements applicable to all gates.  Additionally, there are many other requirements that apply to the specific gate types of Horizontal Swing, Horizontal Slide, Vertical Pivot, and Vertical Lift gate types.  It is the gate fabricator and the installers responsibility to know all details of ASTM F2200 and apply them to any gate that is intended to be automated.
Are UL 325 & ASTM F2200 laws?
No.  Like UL 325, ASTM F2200 is a voluntary standard. This is a legal distinction only and does not mean compliance is optional for the installer. All that is meant by the term voluntary standard is that the provisions do not carry the force of law. Such standards are created by industries rather than government and set forth best practices. While these standards are designed to create a consensus on critical safety measures related to the associated products, a practical consequence is that they can be used as the basis for determining liability in the event of death or injury.
Is UL 325 applicable to Canada?
Yes.  The Seventh Edition of the UL 325 Standard for Safety for Door, Drapery, Gate, Louver, and Window Operators and Systems has been issued to reflect the adoption of ANSI/CAN/UL 325 as a National Standard of Canada.  The most recent designation of ANSI/UL 325 as an American National Standard (ANSI) occurred on May 19, 2017.  This standard has been approved as a National Standard of Canada (NSC) by the Standards Council of Canada (SCC).