Codes, Laws & Regulations for the Professional Locksmith

Today’s marketplace is much more complicated then when I started running service calls on my bicycle, delivering keys and picking up locks to bring back to my father’s shop. Back then a Best key was considered “Factory Restricted” and the blanks controlled by the manufacturer. We have come a long way in the past 50 years, or have we?

When I look back, the big push was in 1989 after the Meridian fire in Philadelphia when the three firemen lost their lives in a tragic accident when power was pulled from the building that they had just entered and all of the stairwell doors opened when the fail safe electric strikes released the latches. Within a year, the Underwriters Laboratories Fire Mark (F in a circle) would no longer be affixed to any fail safe electric strike. To this day the UL Fire Mark will only appear on “Fail Secure” electric strikes. Building and fire codes were changed to reflect these new codes/laws.

Building & Fire Codes versus today’s laws, what is the difference? Well codes are suggestions made by the associations of code officials. Laws are the result of the code guides submitted by the model code associations to the state governments that turn them into the law. Each state is its own constitutional body that must vote in their state uniformed Building and Fire Code in order for it to become the law in each state. Once voted in by the general assembly, it is the law. Violations are punishable from a misdemeanor to a felony depending on the action and the severity of the incident.

What throws us for a loop is that not all states vote the codes into law at the same time or even vote in the same year model guide codes. You may have a one to two code series difference.

For example, in Pennsylvania they adopted IBC 2000 but skipped over 2003 and then adopted 2006. The reason for this is that there were major changes in the codes and they needed time to train all of their code officials and specifying architects. It is always advisable to call your state Fire Marshall’s office and verify what version of the code guide they are using.

If the answer is we are using the IBC 2006 with changes, that means that they have “BLUE” pages. Blue pages are the language section that must correspond with the state constitutional wording. If you are purchasing your code guide from the International Code Congress, ask if there are blue pages for your state. They will be numbered to correspond with the white pages that must be replaced.

The American with Disabilities’ Act of 1990 (ADA) threw everyone for a loop since it required levers on all door locks/latches accessible to the public. This was a requirement on at least one access door and every door in the means of egress. Even though these doors made up less than one third of the doors within a structure, the architects weren’t having any of that mismatched hardware in their designed buildings. So the change orders went out immediately to switch everything to levers.

For most North American manufacturers, this was not a problem for mortise locks but a big problem for cylindrical levers. Today cylindrical lever locks are a common commodity, but in 1990 they were not. This caused a major retooling of our industrial base.

I developed the ADA course in October of 1990 for the Associated Locksmith of America (ALOA) and in developing the course I discovered that there really wasn’t much to the ADA Act of 1990 that would benefit the locksmiths with the exception of a few areas. I expanded the course to include the model building and fire codes zeroing in on “Means of Egress” since this is the area where locksmiths would get into the most trouble.

This course had become so popular that by 1995 I started training ALOA ACE instructors to teach my course. As a group, we conduct more than 150 seminars a year across the United States.

In 1998, all three of the model code associations merged to form one unified group. The code groups that merged were BOCA (Building Officials Code Administrators), UBC (Uniformed Building Code), and SBC (Standard Building Code). They then formed the International Code Congress who produces the IBC (International Building Code) and IFC (International Fire Code).

These codes are voted into law within your state. Another important code association is called NFPA (National Fire Protection Association). NFPA is the standard for Life Safety Codes, Fire Systems Codes, National Electric Codes, and Access Control System Codes. You will find that NFPA ties directly to the state building codes as they must work hand and hand.

In 2007 NFPA introduced NFPA 80. This was a total rewrite of the standard for door and window assemblies. The big change was the new mandatory “Fire Door Assembly Inspection Service.” This new requirement puts the burden onto the facilities to conduct an annual inspection of critical fire door assemblies and have a written report available for the code official when they make their annual visit. The big hold up with putting this new requirement into the building and fire standard is that most of the state building codes are ICC controlled so in 2009 ICC introduced the 2009 IFC (International Fire Code) to be piggy backed with the IBC building code that is the law in most states.

ALOA will be releasing their new Fire Door Assembly Inspection (FDAI) course in January 2010 with a new PRP (proficiency registration program) to go with it. This program will be scheduled as a 16 hour course at this time but may be adjusted after discussions with accreditation organizations to meet their guidelines.

Two other organizations in our industry currently offer Fire Door Assembly Inspection classes; the Door Hardware Institute (www.dhi.org) and the International Fire Door Inspector Association (www.ifdia.org). DHI has stated prerequisite courses in order to take the FDAI course. It is a good idea to find out about the DHI FDAI course prior to registering for it.

The International Fire Door Inspector Association requires a prospective locksmith to take a free, timed exam online to determine knowledge levels. Upon successful completion of the examination, the locksmith can sign up for the online accredited course, estimated to take between 22-25 hours. According to IFDIA, the course includes a free membership in the IFDIA, along with free online report writing tools and advertising opportunities.

DHI has a contract with Intertek (owners of the Warnock Hersey mark) to provide “certification” of their students. IFDIA has accreditation of their online curriculum provided by International Accreditation Services, whose parent company, the International Code Council is responsible for writing the IFC (as discussed previously). ALOA is in the process of completing their curriculum for a two day Fire Door Assembly Inspector course. ALOA is applying for accreditation through existing accreditation services and hope to have this completed in the first quarter of 2010.

These courses are fee based. However, there are no required courses for being a Fire Door Assembly Inspector. An individual can be a Fire Door Inspector if he or she has the knowledge and experience. This would entail knowledge of fire doors, frames, and all hardware associated with the proper application and operation on these assemblies.

Without sufficient experience, most local authorities having jurisdiction (LAHJs) cannot personally gauge your proficiency as an inspector. This is where these various courses provide value. Although the LAHJ is not required to accept any report, they are more likely to accept one from someone who has been vetted by a third party.

There can be a conflict of interest if a locksmith acts as both a Fire Door Assembly Inspector and the company that provides the necessary repairs. I would consider making it a policy to not bid on the necessary repairs for any project that you conducted a fire door assembly inspection and provided a written report that you charged a fee to the owner. Doing the inspection for free so that you can obtain the necessary repairs is also unethical. It is not unethical to bid a job based on your experience to bring an opening up to code.

Staying current with the codes requires attending a certification seminar at least every three years so you know what has changed since the last time you were certified. Most state licensing requires a course in building codes, fire codes, and barrier free ADA laws to have a requirement of 2 CEU’s (Continuing Education Units) in each section to keep your license current.

This is an exciting new field that locksmiths should take advantage of to grow your company.

Tom Demont, AHC, CFL, CIL, CML has been in the locksmith industry for 50+ years. He developed the first codes life safety codes class for locksmiths in 1990.

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