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May 10 2011

Decoded: New Occupant Load Requirements for Panic Hardware (May 2011)

Category: DHI,Egress,Panic HardwareLori @ 12:24 am Comments (26)

This post was printed in the May 2011 issue of Doors and Hardware

[Click here to download a reprint of this article.]

I started studying code requirements related to hardware in the mid-90’s, and I decided to conduct a little “survey” to see if my fellow hardware consultants could benefit from having a resource for code information.  The survey question was, “When is panic hardware required by code?” and I got quite a few different answers!  Although the answer does vary slightly depending on which code and which edition is being referenced, the answer shouldn’t be all that variable.  I concluded that the hardware industry could use more information about codes and since then I’ve probably answered that question hundreds of times.

In the 2000 and 2003 editions of the International Building Code (IBC), panic hardware was required on egress doors serving Educational and Assembly Occupancies with an occupant load of 100 people or more (as well as certain High Hazard occupancies). The 2006 and 2009 editions of the IBC require panic hardware on these occupancy types with an occupant load of 50 people or more (and all High Hazard occupancies).  Since the occupant load is determined by the area of a room divided by a required number of square feet per person (the factor varies by occupancy type), this means that panic hardware is required for much smaller rooms when referencing the newer editions of the IBC.

For example, imagine a multi-purpose room on a school project that has an area of 600 square feet.  The room will sometimes be used for presentations where the students will sit on the floor, so I would consider it Assembly space with a potential for concentrated use.  The IBC uses a factor of 7 square feet per person for concentrated assembly space without fixed seating (Table 1004.1.1 in the 2009 edition).  600 square feet / 7 square feet per occupant = 86 occupants.  The doors to this room would not have required panic hardware per the 2000 and 2003 editions of the IBC, but do require panic hardware per the 2006 and 2009 editions.

Other requirements for panic hardware include:

  • The actuating portion of the panic device must measure at least half the width of the door (example: a 3′-2″ door requires the touchpad or crossbar to be at least 19″ long).
  • The maximum unlatching force shall not exceed 15 pounds.
  • Panic hardware used on balanced doors must be touchpad type, and the touchpad must not extend more than half the width of the door measured from the latch side.
  • Doors serving electrical rooms with equipment rated 1,200 amperes or more and over 6 feet wide that contain overcurrent devices, switching devices or control devices require panic hardware per the IBC.  There are additional locations for panic hardware required by the National Electric Code.
  • There is an exception for certain Assembly occupancies where key-operated locks may be used.  Consult the IBC for more information.

Here are the applicable excerpts from the 2009 International Building Code:

Graphic: 2009 International Building Code Commentary

1008.1.10 Panic and fire exit hardware.  Doors serving a Group H occupancy and doors serving rooms or spaces with an occupant load of 50 or more in a Group A or E occupancy shall not be provided with a latch or lock unless it is panic hardware or fire exit hardware.
Exception: A main exit of a Group A occupancy in compliance with Section 1008.1.9.3, Item 2.
Electrical rooms with equipment rated 1,200 amperes or more and over 6 feet (1829 mm) wide that contain overcurrent devices, switching devices or control devices with exit or exit access doors shall be equipped with panic hardware or fire exit hardware. The doors shall swing in the direction of egress travel.

1008.1.10.1 Installation. Where panic or fire exit hardware is installed, it shall comply with the following:
1. Panic hardware shall be listed in accordance with UL 305;
2. Fire exit hardware shall be listed in accordance with UL 10C and UL 305;
3. The actuating portion of the releasing device shall extend at least one-half of the door leaf width; and
4. The maximum unlatching force shall not exceed 15 pounds (67 N).

1008.1.10.2 Balanced doors. If balanced doors are used and panic hardware is required, the panic hardware shall be the push-pad type and the pad shall not extend more than one-half the width of the door measured from the latch side.

Note:  NFPA 101 – The Life Safety Code has not changed the threshold for occupant load in regard to panic hardware as of the 2009 edition, so the 100-occupant figure still applies to projects where NFPA 101 is being enforced.  The requirements for High Hazard occupancies also differ between NFPA 101 and the IBC, so consult the pertinent code for more information.

Some state and local jurisdictions have modified the IBC requirements, so check the codes used in the applicable jurisdiction.

This post was originally created on February 25th, 2009, and was printed in the May 2011 issue of Doors & Hardware magazine.

26 Responses to “Decoded: New Occupant Load Requirements for Panic Hardware (May 2011)”

  1. Robert Wright says:

    2003 editions(IBC), panic hardware was required on egress doors serving with an occupant load of 100 people or more. 2009 editions of the IBC require panic hardware on these occupancy types with an occupant load of 50 people or more Question: if the door hardware or the door is being worked on or replaced – is the new 2009 code inforced and will now have to be updated to the new code? and the door replaced

  2. Jodie Meyers says:

    Hey Lori,

    Me again. The code book and life safety are in our office and I’m at home, so forgive me for asking you this question. I was just speaking to an Architect and I told her that I was certain I’d read that in educational facilities, not only are exit devices required on corridor doors, but both leafs of the pull side must also be operable. Am I remembering incorrectly?

    Thanks as always for your help!

    Jodie Meyers

    • Lori says:

      Hi Jodie –

      I haven’t seen anything that would require both leaves to be operable on the pull side. Maybe it’s a local code or a Board of Education requirement?

      – Lori

  3. Cheryl Smith says:

    I am the Safety Coordinator for a college. We have had some questions about panic hardware on some doors on a 1973. This building has a fitness center and some offices in it. Would these doors need to have panic hardware?

    • Lori says:

      Hi Cheryl –

      I’m sorry for the delay! For some reason your comment was not sent to my email so I didn’t see it until now. I’m not sure what the requirements were in 1973, but today you would need panic hardware if the doors were serving Assembly or Educational space with an occupant load of more than 50 people. A college is not considered an Educational occupancy (only K-12), so you’d be looking for Assembly space as the location for panic hardware. Offices would be a Business occupancy. The fitness center could be considered Assembly space but it depends on the size. If you have a floor plan I could take a look. My email address is

      – Lori

    • Ramon Gomez says:

      I too just started at a College again as a safety according to Life Safety Code panic hardware is not required in College because it’s considered a Business Occupancy? The building I’m working with all research.

      • Lori says:

        Hi Ramon –

        NFPA 101 requires panic hardware for Assembly, Educational, Day Care, and High Hazard occupancies that have a certain occupant load. If you look under the Business occupancy classification in Chapter 6, it includes college and university instructional buildings, classrooms under 50 persons, and instructional laboratories. So if the building is a Business occupancy, there isn’t a requirement for panic hardware (although you can definitely use it for durability, ease of use, etc.). If the building contains any classrooms that have an occupant load of 50 or more, those are Assembly occupancies and the panic hardware requirement kicks in.

        – Lori

        • Brandon says:

          I wanted to follow up some on the educational/business occupancy. Although the IBC places colleges and universities under the business classification, some states have amended this wording to place them under the educational occupancy. As an example, I work in Kentucky and our adopted code states that colleges and universities are to be considered educational. You will probably want to check your local codes to see what their specific requirements are.

  4. Bruce says:

    I have an installation at work where a earplug dispenser is installed above the panic door bar. This will cause someone to get their face smashed before the panic door actuates. It may also cut into the door opening of 28 inch door width when open.
    What other standards are in non compliance with this installation condition?

    • Lori says:

      Hi Bruce –

      I can’t think of anything else that would address the dispenser as a code issue, unless it is a fire door. The components of a fire door assembly need to be listed for that use. If it’s not a fire door, the projection into the clear opening width is probably the specific code requirement to reference. NFPA 101 talks about the allowance for projections as specifically related to the projection of panic hardware and fire exit hardware. The intent was not to allow any and all projections into the clear width.

      – Lori

  5. Ramon Gomez says:

    Thank you, Lori

  6. Aidan Bird says:

    An R-2 apartment building which has a penthouse amenity space on the roof is an A occupancy…so the exit doors in the space need to have panic hardware. Would the exit door leaving the exit stair at grade need to have panic hardware? On the roof outside the enclosed amenity space is an occupied roof deck with tables and chairs…Should this space have an exit door with panic hardware? Roof deck exit access is direct to stair enclosure on one side, and then through the enclosed amenity space to the a 2nd exit stair. Roof deck access door from amenity space is a two way exit double door.

    • Lori says:

      Hi Aidan –

      Any doors serving the areas that are Assembly occupancies with more than 50 people (per the IBC) must have panic hardware if they are equipped with a latch or lock.

      – Lori

  7. Gord says:

    Hi Lori,

    In a apartment/condo setting the stairwell doors don’t need an exit device. What about if the have placed a door in the middle of the hallway leading into the corridor with the elevators. would that require an exit device?

    • Lori says:

      Hi Gord –

      Typically you wouldn’t need panic hardware on a cross-corridor door in a residential occupancy unless the door was part of the means of egress for a large gathering space. One exception would be if it happened to be a fire-rated double-egress pair, which is only available with fire exit hardware (as far as I know).

      – Lori

  8. Gord says:

    Thank you very much!

  9. MASASHI says:

    Hello Lori,

    I would like to know if the panic hardware at the doors at assembly space [occupancy group A] needs to be fire rated if the doors are 1.5-hour FPSC doors.

    Thank you,

    • Lori says:

      Yes, panic hardware on fire doors must be fire exit hardware. Here is the applicable language from NFPA 80-2013:

      6.4.4 Locks or Latches. Only labeled locks and latches or labeled fire exit hardware (panic devices) meeting both life safety requirements and fire protection requirements shall be used. Fire exit hardware shall be installed only on fire doors bearing a label stating “Fire Door to Be Equipped with Fire Exit Hardware.” Fire exit hardware shall be labeled for both fire and panic. Fire exit hardware shall have a permanently attached label that bears the serial number and shows the manufacturer’s name and type of approval. The label shall differentiate between panic hardware, which is not acceptable for use on fire doors, and fire exit hardware.

      – Lori

  10. Jack says:

    I have a project that has an interior room (A Occupancy) with an occupant load slightly more than 50 so there are two exits and each one has panic hardware. One of the exit paths goes through two doors of an intervening room and hall. One door going to the exterior. The occupant load of the intervening room is less than 50 even if it is combined with half of the load from the A Occupancy. Neither of the doors has panic hardware. I have been told that panic hardware is not needed due to occupant load. My question is, are the doors for the intervening room and exterior door required to have panic hardware since the door at the start of the exit path (the A occupancy) has panic hardware? So far I have not found anything in the IBC. Maybe there is a reference in NFPA. Thanks in advance for you help.

    • Lori says:

      Hi Jack –

      The panic hardware would be required for any doors that latch or lock, between the Assembly occupancy and the public way. If there was a door with a push plate and pull (no latch or lock), it would not require panic hardware. The is an example in the IBC Commentary to support this:

      For example, an accessory lunchroom located in a business office regulated as an accessory occupancy would need to be protected with an automatic sprinkler system if the lunchroom’s occupant load exceeds 100. In addition, any means of egress doors serving the lunchroom, from the lunchroom to the exterior exit doors, would need to be provided with panic hardware. The lunchroom would need to comply with all other code requirements applicable to a Group A-2 use.

      – Lori

  11. Jack says:

    Hi Lori
    Thanks for the prompt response. I thought panic hardware would be required. Could you point me to the IBC paragraph so I can reference it and the commentary in my response to the Owner?

    • Lori says:

      In the 2015 edition of the IBC, the panic hardware requirement is here (notice it says “doors serving…” which means all of the doors leading from the space to the public way):

      1010.1.10 Panic and fire exit hardware. Doors serving a Group H occupancy and doors serving rooms or spaces with an occupant load of 50 or more in a Group A or E occupancy shall not be provided with a latch or lock other than panic hardware or fire exit hardware.
      1. A main exit of a Group A occupancy shall be permitted to be locking in accordance with Section 1010.1.9.3, Item 2.
      2. Doors serving a Group A or E occupancy shall be permitted to be electromagnetically locked in accordance with Section 1010.1.9.9.

      The IBC Commentary for this section begins with: “Doors that are part of a means of egress from the locations listed in this section shall not be provided with a latch or lock other than panic hardware or fire exit hardware unless one of the two exceptions is met.” This reinforces the interpretation that the panic hardware is required for the doors that are part of the means of egress from those spaces, not just the doors that are part of the walls surrounding the space. The means of egress extends to the public way.

      The IBC Commentary section that I quoted in my previous response was from section 508.2.1 which is about mixed occupancies – not about panic hardware, but happens to give an example that helps to establish the intent of the code.

      – Lori

  12. Jack says:

    Thanks so much for your assistance.

  13. Anna Huang says:

    Hi Lori,
    We have a big open office area which has a small cafeteria in the middle. We used 15 as the Occupancy load factor and the Load is > 50. The big open office area is existing and has 4 exits, 2 exit to stair well and then exterior, 2 exit to rated hallway and exterior. Do we need panic hardware at all 4 exits and others on the egress path?

    thank you so much!

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