If you’ve been paying attention to recent code changes, you’ve probably noticed that several electrified hardware products are now required to be listed in accordance with UL 294. Recent editions of both NFPA 101 and the International Building Code require products for some types of access control systems to be listed in accordance with ANSI/UL 294, Standard for Access Control System Units. So what is UL 294 and how is it being incorporated into the building, fire and life safety codes?
Known formally as the Underwriters Laboratories Standard for Access Control System Units, UL 294 is used to evaluate the construction, performance, and operation of access control systems. From power supplies and card readers, to delayed egress locks and control panels, the electronic components that are necessary for the proper operation of the access control system are tested thoroughly to ensure they will operate reliably without creating a hazardous condition.
Product performance is evaluated based on four different levels of testing ‑ destructive attack, line security, endurance and standby power. Although the current model codes do not specifically state which of these levels must be met in order for the system to be code-compliant, the testing required for UL 294 – Level 1 establishes that the products are safe for egress purposes, which is the main concern of the model codes.
Code Changes
The requirement for UL 294 compliance first appeared under Special Locking Arrangements in the 2009 edition of NFPA 101 - The Life Safety Code. A new section was added to address the requirements for electrically-locked elevator lobby doors that allow egress out of the elevator lobby during an emergency. Section 7.2.1.6.3 of NFPA 101-2009 requires a UL 294 listing for “the electronic switch for releasing the lock” and references the 2004 edition of the standard.
The elevator lobby section was later revised in the 2012 edition of NFPA 101 to require the lock to be listed to UL 294. However, there was no mention of a listing for the switch. The requirement for a UL 294 listing was also added to Section 7.2.1.5.6 – Electrically Controlled Egress Door Assemblies and requires hardware for new installations covered by this section to be listed. This section is typically applied to doors with electromagnetic locks that are released by door-mounted hardware, such as panic hardware with a request-to-exit switch.
Three years after UL 294 was first referenced by NFPA 101, it was included in the 2012 edition of the International Building Code in section 1008.1.9.8 – Access-Controlled Egress Doors. This is the section that addresses doors with locking devices released by a sensor – typically electromagnetic locks. As a result of this change, doors in certain locations may be equipped with an approved entrance and egress access control system, listed in accordance with UL 294, if the other criteria of the section are met.
In the 2015 edition of the IBC, requirements for UL 294 listings were expanded to include the following sections:
- 1010.1.9.6 – Controlled Egress Doors in Groups I-1 and I-2
- 1010.1.9.7 – Delayed Egress
- 1010.1.9.8 – Sensor Release of Electrically Locked Egress Doors
- 1010.1.9.9 – Electromagnetically Locked Egress Doors
The door locking system units in each of these sections are required to be listed in accordance with UL 294, with the exception of Section 1010.1.9.7 – Delayed Egress, which requires the listing for delayed egress locking system units.
Compliance Challenges
Determining which electrified applications are subject to UL 294 listing requirements can be difficult as NFPA and IBC currently have different requirements. The answer is ultimately dependent on which code has been adopted in a project’s jurisdiction.
Neither of the recent editions of NFPA 101 – The Life Safety Code and the International Building Code (IBC) require UL 294 listings for all locations where electrified hardware might be used. For example, the 2015 edition of the IBC requires delayed egress locks to be listed to UL 294, but NFPA 101 does not. NFPA 101’s section on elevator lobby egress requires the listing, but the IBC does not include a similar section.
An access control system that consists of a reader controlling access and hardware that allows free egress is not currently addressed by the code sections that reference UL 294, so these systems would not require the listing unless mandated by state or local code modifications or the Authority Having Jurisdiction (AHJ).
Even less clear is the process of determining which components of a system require the UL 294 listing. Is it required for the electrified locks, power supplies, conductors, or switches, a combination of these, or all of them? While UL 294 can be used to test the various components, many products were previously listed to UL 1034 – Standard for Burglary-Resistant Electric Locking Mechanisms. There are some similarities between UL 1034 and UL 294, but there are variations in the test criteria and UL 294 includes some additional testing that is not required for the UL 1034 listing. Some AHJs will require the UL 294 listing for locks and power supplies only, and others will look for the mark on every component of a system if the application is covered by one of the code sections that requires the listing. In the absence of prescriptive requirements stated in the code, this interpretation is left up to the AHJ.
Another point to keep in mind is the fact that the UL 294 listing may be included in specifications to establish the level of quality desired by the end user, architect, and/or security consultant, even if it is not required by code for a particular application.
As always, remember that state or local requirements could differ from those of the IBC or NFPA 101, so it’s important to be aware of the codes in your facility’s jurisdiction. Refer to the published codes for the detailed code requirements, and consult the AHJ for more information about the local requirements.
Lori Greene, DAHC/CDC, CCPR, FDAI, FDHI is the Manager of Codes and Resources for Allegion. For more information about this topic and to download a free reference guide on codes, visit iDigHardware.com/guide.
