Changes Coming to UL 325 for Gate Operators
By Rick Sedivy, DoorKing Director of Marketing and Regulatory Affairs,
and Tom DeSilvia, LiftMaster Director of Engineering for Regulatory and Test Services
Starting on Jan. 12, 2016, new UL 325 changes take effect, bringing a series of new mandates for
the gate operator industry. Here’s a quick guide to the key modifications.

  1. Entrapment-Protection Devices. Gate operators are required to have a minimum of two
    independent means of entrapment protection where the risk of entrapment or obstruction
    exists. A manufacturer can use two inherent-type systems, two external-type systems, or
    an inherent and an external system to meet the requirement. However, the same type of
    device cannot be used for both means of protection.
  2. Monitoring Required. An external non-contact sensor or contact sensor may be used as a
    means of entrapment protection. However, the sensor must be monitored once every cycle
    for (1) the correct connection to the operator and (2) the correct operation of the sensor.
    If the device is not present, not functioning, or is shorted, then the gate operator can only
    be operated by constant pressure on the control device. Portable wireless controls will not
    function in this case.
  3. Entrapment Risk Identification. As in the past, it’s up to the installer to examine the
    installation and determine where a risk of entrapment or obstruction exists. Manufacturers
    are required to provide instructions for the placement of external devices, but they give
    only examples of suggested entrapment protection in their installation manuals. If the
    installer identifies a risk of entrapment or obstruction, at least two independent means of
    entrapment protection are required.
  4. Terminology Change. The terms “primary” and “secondary” have been removed in
    the description of entrapment protection devices. This was done to emphasize that all
    entrapment protection devices are equally important.
  5. The End of Type E. Type E (audible alarm) devices can no longer be used for entrapment
    protection. This change was made because the Type E device is really a warning device,
    not an entrapment-protection device. Also, all gate operator classes are now required to
    have an audio alarm that sounds when two successive obstructions are encountered via a
    contact-type system.
  6. Access Control Location for Emergency Use. An exception has been added in the
    manufacturer’s instructional requirements for the location of controls that operate the gate.
    The instructional requirements state that these controls must be at least 6′ away from
    any moving part of the gate. In the new exception, “Emergency access controls only
    accessible by authorized personnel (e.g., fire, police, EMS) may be placed at any location
    in the line-of-sight of the gate.”
  7. Barrier-Arm Operator Exception. An exception has changed for barrier-arm gate
    operators requiring entrapment protection. The previous exception stated that a barrier-arm
    operator did not require entrapment protection if the arm did not move toward a rigid
    object closer than 2′. The distance has been reduced to 16″ so it more closely aligns with
    the industry-defined entrapment protection provisions in ASTM F2200.
  8. Gate Operator Class II and Class III Definitions. The definitions for installation classes
    for gate operators were modified. Class II now includes commercial locations accessible
    to the general public. Class III was refined to specify industrial locations not accessible
    to the general public. These changes, while seemingly minor, may affect which gate
    operator is suitable for a particular installation location.

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