For decades, this industry has struggled to determine the best compromise between fire safety and building security. Building owners and occupants demand both safety and security, but as we’ve seen time and again, it’s impossible to maximize one without inhibiting the other. Ultimately, the safety of the building occupant must always take precedence over the security of the facility. It’s for this reason that the local, state and international building codes are designed to ensure occupant safety by delineating exactly where the line between safety and security must be drawn.
Unfortunately, safety is sometimes sacrificed in a misguided effort to enhance security. The temptation to increase security can materialize in a number of different ways, and it’s vital that we stay current on the latest code requirements in order to recognize when that line is being crossed. What follows are some of the most common examples of how enhancing security can lead to code violations.
Panic Hardware
The image of egress doors with panic hardware chained together is probably one of the most extreme and obvious examples of safety being sacrificed in pursuit of security. However, there are also many instances where auxiliary locks are installed on doors that are required to have panic hardware. Some of these installations are code violations and some are not, so it’s important to have a solid understanding of the latest code requirements.
NFPA 101 – Life Safety Code states that “Devices shall not be installed in connection with any door assembly on which panic hardware or fire exit hardware is required where such devices prevent or are intended to prevent the free use of the leaf for purposes of egress, unless otherwise provided in 7.2.1.6.”
The use of electromagnetic locks in conjunction with panic hardware is an issue that is frequently misunderstood, in part because of NFPA 101’s prohibition on the installation of secondary locks on doors with panic hardware.
The other source of confusion comes from the language added to the 2009 edition of the International Building Code (IBC), stating that electromagnetic locks released by door-mounted hardware could not be used on doors where panic hardware was required. Although it was not the intent of the proposal to prohibit the use of mag-locks on doors with panic hardware, it was largely interpreted that way. The code section was clarified in the next edition to allow this application on doors with panic hardware, as long as a switch in the panic hardware releases the mag-lock to allow egress. Other types of locks, such as deadbolts and surface bolts, are not allowed to be installed on doors equipped with panic hardware.
While panic hardware is typically required by the model codes for doors serving assembly occupancies, both NFPA 101 and the IBC allow key-operated locks on the egress side of some doors serving certain occupancy types. This includes some assembly occupancies – depending on the occupant load. The use of the key-operated lock is limited to the main door or doors to the building. A double-cylinder deadbolt is the most commonly-used hardware for this application, and the lock must be readily distinguishable as locked. Signage is also required on the egress side of the door if equipped with a key-operated lock, stating “THIS DOOR TO REMAIN UNLOCKED WHEN THIS SPACE IS OCCUPIED.” It’s important to know the locations where key-operated locks are allowed, so check the applicable code requirements for additional criteria.
Stairwell Re-entry
One of the most confusing issues in the battle between safety and security is the topic of stairwell re-entry and the use of locks to prevent entry from the stairs to the tenant floors. Much of the complexity stems from the differing requirements between the IBC and NFPA 101. Although NFPA 101 allows mechanical locks on stairs serving four stories or less, the IBC’s requirements for stairwell re-entry are more stringent and apply in more jurisdictions than the NFPA 101 requirements. The IBC does not allow mechanical locks on stair doors, regardless of the number of stories the stairs are serving.
The IBC requires stairway doors to be openable from both sides without the use of a key or special knowledge or effort, with some exceptions. The discharge door can be locked on the outside, but must allow free egress out of the stairwell. Many interior stairwell doors are locked on the stair side, to prevent unauthorized access to the floors of the building. For these doors, the IBC requires electrified locks which can be unlocked simultaneously upon a signal from the fire command center or from another approved location. For high-rise buildings, stairwells with electrically-locked doors must also have a stairway communication system. Every fifth floor must have a telephone or other two-way communication device that can be used to call a constantly-attended location.
Because the purpose of stairwell re-entry is to allow building occupants to leave the stair and find another exit, some buildings that are allowed to have a single exit stairway are exempt from the stairwell re-entry requirements. This would typically be limited to buildings like air traffic control towers and some residential buildings.
NFPA 101 – The Life Safety Code has slightly different requirements from the IBC, and these only apply when the adopted code is NFPA 101. Stairs serving four stories or fewer are allowed to have doors that are mechanically locked on the stair side. The 2003 edition of the IBC also included this exception, but it is not allowed by any other editions of the IBC. For stairs serving more than four stories, NFPA 101 requires re-entry from the stair enclosure to the building, so doors can be equipped with either non-locking hardware, or fail safe locks that unlock upon initiation of the building fire alarm system.
NFPA 101 also allows “selected re-entry,” where some doors may be mechanically locked and others must allow re-entry. When a “selected re-entry” design is used, NFPA 101 requires the following:
- Re-entry must be allowed on at least two levels.
- There must not be more than four locked floors between re-entry levels.
- The top or next-to-top floor in the stairwell must allow re-entry, with access to another exit on that level.
- Signage is required on the stair side of doors that allow re-entry.
- On levels where re-entry is not allowed, signage is required on the stair side indicating the location of the nearest re-entry level or exit discharge in both directions (up and down).
NFPA 101 also includes several exceptions for occupancies where stairwell re-entry is not required – consult the code for more information. Note that the NFPA 101 requirements for stairwell re-entry only apply if NFPA 101 is the code that has been adopted in the project’s jurisdiction.
Electromagnetic Locks
Although mag-locks are relatively easy to retrofit, some important code requirements must be followed to ensure life safety. Two sets of requirements are included in the model codes that are typically applied to electromagnetic locks. These sections address two different applications, so for each mag-lock installation, one set of requirements must be followed.
The two applications addressed by the model codes are:
- An electrified lock released by a sensor that detects an occupant approaching the door and unlocks the door, or
- An electrified lock released by door-mounted hardware that incorporates a switch to immediately release the lock for egress.
For electromagnetic locks released by a sensor, the applicable section in NFPA 101 is called Access-Controlled Egress Doors. In the IBC, the section title was previously consistent with NFPA 101, but was changed in the 2015 edition to Sensor Release of Electromagnetically Locked Egress Doors. According to the IBC and NFPA 101, an electrified lock released by a sensor mounted on the egress side to detect an approaching occupant must also be unlocked in the direction of egress by the following:
- Loss of power to the sensor
- Loss of power to the lock or locking system
- Activation of the building fire alarm or automatic sprinkler system, where provided, and the door must remain unlocked until the fire protection system has been reset.
- A manual unlocking device (typically a push button) that is located 40 to 48 inches above the floor and within 5 feet of the door. Ready access must be provided to the push button, and the button must be marked “Push to Exit.” Pushing the button must directly interrupt power to the lock, independent of the other electronics, and the door must remain unlocked for at least 30 seconds.
For electromagnetic locks released by door-mounted hardware incorporating a switch, the applicable code sections are Electrically Controlled Egress Door Assemblies (NFPA 101) and Electromagnetically Locked Egress Doors (IBC). Beginning with the 2018 edition of the IBC, this section will be called Door Hardware Release of Electrically Locked Egress Doors. The model codes include the following requirements for an electrified lock released by door-mounted hardware that incorporates a built-in switch:
- The hardware mounted on the door must have an obvious method of operation and must be readily operated with one hand and under all lighting conditions.
- Operation of the hardware must directly interrupt the power to the lock, and the door must unlock immediately.
- The door must also unlock upon loss of power to the locking system.
- If panic hardware is required, operation of the panic hardware or fire exit hardware must release the lock.
- Note that this section does not require the door to unlock upon activation of the fire protection system.
Although these code sections may refer to “electrified locks,” mag locks are the most common type of lock that is released by a sensor, or by a switch in the door-mounted hardware. Both of these applications must be allowed by the use group or occupancy classification; they are not allowed in every type of building. Refer to the applicable code for the list of occupancy types where these locks are acceptable, along with specific requirements regarding emergency lighting and the activation of manual fire alarm boxes.
Classroom Barricade Devices
In recent years, several school districts have attempted to enhance classroom security by installing barricade devices on classroom doors. As a result, during the current model code cycle, the requirements for classroom security were reviewed to determine whether the existing code requirements should be relaxed. After examining the issues of school security and safety from an all-hazards perspective, the decision was made to not only maintain existing requirements, but to add a mandate that strengthens the current codes for classroom security.
The following code change proposals have now been approved for the 2018 edition of the International Building Code (IBC):
1010.1.4.4 Locking arrangements in educational occupancies. In Group E and Group B educational occupancies, egress doors from classrooms, offices and other occupied rooms shall be permitted to be provided with locking arrangements designed to keep intruders from entering the room where all of the following conditions are met:
1. The door shall be capable of being unlocked from outside the room with a key or other approved means.
2. The door shall be openable from within the room in accordance with Section 1010.1.9.
3. Modifications shall not be made to listed panic hardware, fire door hardware or door closers.
1010.1.4.4.1 Remote operation of locks. Remote operation of locks complying with Section 1010.1.4.4 shall be permitted.
This code language applies to K-12 schools and also colleges and universities. The locking requirements apply to classrooms as well as offices and other occupied rooms. If the rooms are lockable, the code now requires that they be able to be unlocked from the outside using a key or other approved means. Locks are not required, but if locks are used, the doors have to meet the requirements for egress – one operation to unlatch, no key, tool, special knowledge or effort, and no tight grasping, pinching or twisting required. Also, listed panic hardware, fire door hardware, and door closers must not be modified to accommodate retrofit security devices. If the locks meet the other requirements of this section, remote operation is acceptable.
While these code changes marked an important victory in the battle to ensure safety is prioritized over security, states may still modify the model code requirements. Several state fire marshals have released bulletins stating that classroom barricade devices may be used during an active assailant incident, although this is inconsistent with guidelines for classroom security from the National Association of State Fire Marshals (NASFM). Of greater concern, in Ohio and Arkansas the state legislatures actually passed laws that allow classroom barricade devices, despite the objections of their state code officials.
While this is a more extreme example of safety being sacrificed in an effort to enhance security, it serves as a good reminder that state and local jurisdictions can modify the model codes, so be sure to check the codes that have been adopted in a project’s location. And as always, when in doubt, consult the local AHJ for clarification.
Lori Greene, DAHC/CDC, CCPR, FDAI, FDHI is the Manager - Codes and Resources for Allegion. For more information about this topic and to download a free reference guide on codes, visit iDigHardware.com/guide.
