20-0810 Door Hardware Accessories Clarification

QUESTION

Our team is requesting further details/clarifications as to what constitutes as a hardware “accessory” as it applies to door hardware, as well as confirmation on our interpretation of exception I14-E6 v2.1 (10/2010) – Miscellaneous Hardware & Accessory Products.
The manufacturer has claimed all the items (below) in the submittal to be hardware accessories and therefore has not provided manufacturing locations or raw material sourcing locations:
  • Butts & Hinges
  • Door Closers
  • Exit Devices (ie panic hardware or push plates)
  • Door Holders
  • Locksets (levers/handles and locking mechanisms)
  • Protection Plates (ie kick plates)
Do the items in the submittal (listed above) fall within “accessory hardware for doors” and therefore exception I14-E6 v2.1 can be applied?
Lastly, our interpretation of exception I14-E6 v2.1 is that if these are considered accessories, their manufacturing location must still be tracked and within the appropriate zone. However, their raw material sourcing does not need to be tracked. Therefore, the manufacturer must provide the manufacturing location of all of these items & they must fall within Zone 2 to be compliant.
Is our interpretation above correct, or do we not need to track accessories for both manufacturing location and raw material sources?

ANSWER

Door holders, butts and hinges, and protection plates would be considered Miscellaneous Hardware, and therefore do not need to be tracked under either I11 Red List or I14 Appropriate Sourcing. Note however, that any product known to contain Red List ingredients should be avoided.
Door closers, exit devices, and locksets, though utilitarian, are made up of multiple interacting components and would not be considered Miscellaneous Hardware and Accessory Products. These items would need to comply with both Red List and Appropriate Sourcing requirements.
Also note that products specified to ensure a specific type or brand of product is used are not considered miscellaneous hardware and must be tracked for ingredients and location.

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