The Issue

In accessibility design, even small details like the location of a door control button—can have a significant impact on usability. For power-operated hinged doors, conflicting requirements between the National Construction Code (NCC) and AS 1428.1:2021 have created uncertainty for designers, certifiers, and builders.

What the Codes Say

The discrepancy lies in how each legislation defines the acceptable placement of manual controls:

• NCC (Clause D3D26(2)(a)(ii), 2022 Amendment 2)
  Requires controls to be located between 1 m and 2 m from any position the door leaf may occupy.
• AS 1428.1:2021
  Requires controls to be positioned between 500 mm and 1 m from the arc of the hinged door leaf.

At face value, these requirements conflict: one pushes controls further away, while the other brings them closer to the door swing.

 Why This Matters

The placement of manual controls is critical for:

• Wheelchair users, who need to avoid the door swing path
• Users with limited reach or mobility, who rely on predictable and safe positioning
• General accessibility compliance, particularly in public buildings and SDA projects

Incorrect placement can create safety risks or make a compliant-looking design practically unusable.

Which Requirement Takes Precedence?

This is where legislative hierarchy becomes important.

The Access Code for Buildings is made under Commonwealth law (Disability Discrimination Act 1992). Because of this, it overrides conflicting provisions in the NCC where inconsistencies arise.

As a result:

• AS 1428.1:2021 requirement (500 mm – 1 m from the door arc) is the governing provision.

This effectively means that NCC Clause D3D26(2)(a)(ii) does not apply where it conflicts with AS 1428.1:2021 and Access Code.

Practical Application

In practice, this means:

• Manual controls must be installed within 500 mm to 1 m of the door arc
• Controls should be positioned:
  • Clear of the door swing path
  • Within accessible reach ranges
  • In a location that allows safe approach and operation