Frequently Asked Questions
UL 325 Standards
Many of the following FAQ’s were published by DASMA in January of 2000. While
we believe the information contained in them is still accurate, you may wish to
visit their website for more current information.
Is there a difference between a UL listed product, an ETL listed product or a
product listed by anyone else?
Any listing by a Nationally Recognized Testing Laboratory (NRTL) that tests to
the UL 325 standard is acceptable (but not the same as a UL Listing). The
test laboratories are expected to use the same standard.
What is a “Certified” or “Approved” product?
There is no such thing as a NRTL “Approved” or “Certified” product. The
proper term is “Listed” since the NRTL labs list a product that meets
their minimum safety requirements. Once listed, the manufacturer receives
“Authorization to Mark” the product from the testing lab, which allows the
manufacturer to place the testing lab’s mark on their product. This process
also requires the manufacturer to comply with the testing lab’s follow-up
program to insure continued compliance.
Is compliance with UL 325 a national law?
Yes and No. While there is no specific national law requiring compliance with
UL 325, it can be inferred that Federal Law 29 CFR 1910.399 places UL 325
compliance under OSHA (Occupational Safety and Health Administration)
jurisdiction. Additionally, it is the state law in Nevada (effective 3/1/00)
and other states may follow suit. DASMA is continuing to monitor other states
for potential legislation in this area.
How does UL 325 relate to OSHA regulations?
Under federal law, OSHA requires that all electrical equipment that is used in
an employee workplace be listed and labeled by a NRTL to the applicable public
safety standards. For vehicular gate operators, this standard is UL 325,
Fourth Edition as published September 18, 1998.
Our application is residential in nature (such as an apartment complex) –
does this OSHA regulation affect us?
By OSHA’s definition, an employee workplace takes on a very broad definition.
Because managers, service personnel, etc. are employed and working on the
property, UL 325 standards can be construed to apply. The same rationale
could also be applied to gated communities and even individual gated
residences if service personnel such as lawn or pool maintenance or trash
service personnel use the gated entry.
What are the potential consequences of non-compliance under OSHA’s
regulations?
The consequences can be severe and extremely costly. The governing Federal
Law empowers OSHA to levy fines up to $70,000 for each
piece of non-listed equipment and to impose a jail sentence of up to
6 months. Additionally, parties found guilty of false
certification can be subjected to additional fines and jail time.
Who is going to check the gate system to determine if it is in compliance
with the new standard?
No one at the present time; however, keep in mind two things: (a) the Consumer
Product Safety Commission has submitted a proposed revision to the new
International Building Code where, if passed, building code officials would
then be inspecting gate systems for compliance where the IBC is adopted and
enforced and (b) there is a potential for liability if a gate system is not
installed in compliance with UL 325.
Am I required to update existing installed operator to the new UL 325
Standard?
No. There is no retroactivity with respect to UL 325 but as above, potential
liability exposure may exist in systems that are non-compliant.
Can older operators that do not meet the standard be repaired?
Yes. Again, the issue of liability for non-compliant systems could come into
play here as well. (Note: Sunbelt Systems has adopted a policy of not
repairing any operators whose general condition increases the likelihood of an
entrapment incident; i.e., faulty clutch mechanisms, poorly function gates,
etc.)
Can I upgrade operators already installed to the new standard?
There are no requirements to upgrade existing operators and such an upgrade is
dependant upon the product itself; your local dealer and/or the manufacturer
should be consulted on this matter.
What is the significance of the operator usage classifications?
These classifications are intended to signify specific end use applications as
defined in UL 325.
Can operators be classified under more than one of these classifications?
Yes. UL 325 requires that “a (listed) vehicular gate operator shall be
permanently marked (labeled) to specify all intended Classes of
applications.” (parentheses and underline added)
What is the difference between a primary and secondary entrapment protection
device?
The secondary entrapment devise is intended as a backup feature should the
primary device fail or not work properly.
Do photoelectric cells or contact sensing (reversing) edges have to be
installed on all gates?
Not necessarily. These two options are among several acceptable means of
meeting the UL 325 Standard. Contact your local dealer or the manufacturer
for information about acceptable protection devices to be installed on a
particular gate.
Do I have to install both photoelectric cells and reversing edges as
secondary devices to be in compliance with the standard?
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.
Will an operator function if a photoelectric cell or reversing edge is not
connected?
This is dependent upon the particular operator’s design – consult your dealer
or the manufacturer for this information.
How far away from the gate should an access device (pushbutton, card reader,
etc.) be installed?
The first sentence of Section 51.8.4(f) of the standard 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.” The location of these
devices must, therefore, be determined based on the layout of each particular
system and this requirement.
If a reset switch is to be installed, where does it have to be installed?
UL 325 requires that “controls intended to be used to reset an operator after
two (2) sequential activations of the entrapment protection device or devices
must be located in the line-of-sight of the gate. Care should also be taken
to locate the reset device to avoid creating a point of contact with the gate
while the individual is operating the reset switch (see question 12 above).
Do I have to install a separate pedestrian gate?
UL 325 states that if the operator is for vehicular control, pedestrians
must use a separate entrance. (emphasis added)
Do the new UL 325 requirements apply to both new and existing gates?
UL 325 requirements will apply to all new construction of gates and existing
gates if they are automated. Older, non-automated gates may need to be
altered to meet the new requirements before a gate operator is installed.
Do I have to install guarding or screening on a gate?
Yes, however, this applies only to horizontally sliding gates.
If such a gate is not guarded or screened in accordance with the
manufacturer’s instructions, it cannot claim to be in compliance with UL 325.
Does the 2-1/4 inch sphere test start at the bottom of the gate or is
it measured from the ground up to the 4-foot height?
UL 325 requires that “all openings of a horizontal slide gate are guarded or
screened from the bottom of the gate…” (emphasis added)
If a slide gate is on wheels and there is a 4-inch gap between the ground and
the bottom of the gate, is this okay?
The standard does not include provisions governing the gap between the bottom
of the gate and the ground (DASMA, AFA and NOMMA are working on a joint gate
construction and installation standard that will address this matter).
Do swing gates need to be guarded and screened so that a 2-1/4 inch sphere
will not pass through?
Not at the present time.
More Information
If you need further information on UL 325, please contact us at
info@sunbeltsys.com or visit the
DASMA website at
www.dasma.com or the AFA website at
www.americanfenceassoc.org.
You may also contact UL directly at (847) 272-8800 and you can purchase the
complete UL 325 Standard from Global Engineering Documents at (800) 854-7179.
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Sunbelt
Gated Access Systems, Inc.
