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.
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.
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.
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.
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.
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.
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.”
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.
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.
Changes Coming to UL 325 for Gate Operators
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67410825 Rev.04 - 02/2016
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