This post was published in the December 2015 issue of Doors & Hardware
UL 294 is the Underwriters Laboratories Standard for Access Control System Units, which is used to evaluate the construction, performance, and operation of access control systems. This listing evaluates the safety of the system, and ensures that the products will operate reliably without creating a hazardous condition. The standard covers four different levels for product testing, with variations in the requirements for destructive attack, line security, endurance, and standby power. The current model codes do not specifically state which of these levels must be met in order for the system to be code-compliant, but 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.
NFPA 101 – The Life Safety Code
A requirement for products to be listed in accordance with UL 294 first appeared in the 2009 edition of NFPA 101 – The Life Safety Code. In this edition, a new section was added under Special Locking Arrangements, addressing the requirements for electrically-locked elevator lobby doors which allow egress out of the elevator lobby during an emergency. For these doors, NFPA 101-2009 requires a UL 294 listing for “the electronic switch for releasing the lock” (section 7.2.1.6.3), and references the 2004 edition of the standard.
In the 2012 edition of NFPA 101, the elevator lobby section was revised to require the lock to be listed to UL 294, with no mention of a listing for the switch. In addition, a requirement for a UL 294 listing was added to Section 7.2.1.5.6 – Electrically Controlled Egress Door Assemblies. 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. The revision to the 2012 edition of NFPA 101 requires hardware for new installations covered by Section 7.2.1.5.6 to be listed in accordance with UL 294. No changes were made with regard to UL 294 listings in the 2015 edition, and both editions reference the 1999 edition of the standard, revised 2010.
The International Building Code (IBC)
UL 294 was referenced by the IBC for the first time in the 2012 edition, 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. The change to this section allows doors in certain locations to 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. The referenced standards chapter of the 2012 IBC lists the 1999 edition of UL 294, including revisions through 2009.
In the 2015 edition of the IBC, requirements for UL 294 listings were expanded to several additional sections, and the 1999 edition of the standard was referenced with revisions through September 2010. The following sections of the 2015 IBC reference UL 294:
- 1010.1.9.6 – Controlled Egress Doors in Groups I-1 and I-2 – applies to the electrified locking of egress doors in certain types of units in a health care facility.
- 1010.1.9.7 – Delayed Egress – applies to delayed egress locks which release within 15 seconds after actuation of the release timer (30 seconds when approved).
- 1010.1.9.8 – Sensor Release of Electrically Locked Egress Doors – applies to electrified locks – typically electromagnetic locks, which are released by a sensor to allow egress.
- 1010.1.9.9 – Electromagnetically Locked Egress Doors – applies to doors with electromagnetic locks released by a switch in the door-mounted hardware.
Each of these sections requires the door locking system units 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.
Code Questions
The two common code questions that arise regarding UL 294 are – A) which electrified applications are subject to the listing requirements? and B) which components of a system are required to be listed?
The answer to Question A depends on which code has been adopted in a project’s jurisdiction – typically the code that was in effect when the building permit was issued. The recent editions of NFPA 101 – The Life Safety Code and the International Building Code (IBC) require UL 294 listings for certain electrified applications – not 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 IBC does not contain a similar section. An access control system that consists of a reader controlling access and hardware that allows free egress is not 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).
The model codes do not specifically answer Question B – which components of a system require the UL 294 listing? Is the listing 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. I have seen some AHJs require the UL 294 listing for locks and power supplies only, and others who 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.
Keep in mind that although the UL 294 listing may not be required by code for a particular application, it may be included in specifications to establish the level of quality desired by the end user, architect, and/or security consultant. Some manufacturers have tested and listed electrified products which are not typically used in the systems required by code to have the listing, to establish the safety of their products and differentiate them from equipment that has not be tested.
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Dear Sirs
I was reading document about the sixth edition of the UL294 access control standard.
I have a doubt, and I would like to collaborate, there are four levels of performance (destructive attack, line safety, resistance and standby power).
And four levels of access (I, II, III, IV). In an installation as I define what level of access is it? for example:
A simple office, is access level I?
A bank access level II or IV?
Government offices, what level of access?
Is there a table where the levels are classified by the type of installation, or what parameters define this classification?
Thank you
Angela
Good job!
Hi Folks, would OSHA say that Delayed Egress hardware is acceptable on Exit Discharge doors from non high-hazard areas; provided it is UL 294, and the other IBC/IFC conditions are met (3/15 second, manual re-arm, signage, lighting…)?
Hi Mike –
I don’t know of an OSHA requirement that would prohibit the use of a delayed egress lock if the lock is code-compliant. Here are OSHA’s requirements related to the means of egress:
1926.34(a) General. In every building or structure exits shall be so arranged and maintained as to provide free and unobstructed egress from all parts of the building or structure at all times when it is occupied. No lock or fastening to prevent free escape from the inside of any building shall be installed except in mental, penal, or corrective institutions where supervisory personnel is continually on duty and effective provisions are made to remove occupants in case of fire or other emergency.
1926.34(b) Exit marking. Exits shall be marked by a readily visible sign. Access to exits shall be marked by readily visible signs in all cases where the exit or way to reach it is not immediately visible to the occupants.
1926.34(c) Maintenance and workmanship. Means of egress shall be continually maintained free of all obstructions or impediments to full instant use in the case of fire or other emergency.
– Lori
Thanks Lori!
Hi Lori, another question. Do you know if UL 294 listed HW could be set for a lower delay time, such as 7-10 seconds? Or is 15 the lowest? Do you know the science / rationale behind the 15 seconds? Thanks! Mike
Hi Mike –
I don’t think the delay time is a function of UL 294 – it comes from the model codes. 15 seconds is the maximum delay that is allowed by code unless the AHJ approves a 30 second delay. I am not sure if any manufacturers offer products with a shorter delay.
– Lori
Hi Lori,
I’m confused about the UL 294 requirement for panic hardware on a Delayed Egress system (7.2.1.6.1 point 6). This point means that the panic hardware must have a paper which indicate that this object is certified UL 294, or the functionality of the panic hardware must complete the points that are mentioned on UL 294. I hope have been clear on my question.
Hi Diego –
The codes require the hardware to be listed to UL 294, so the product will have a listing/label to indicate that it complies with the UL 294 standard.
– Lori
Is this considered a fire rated device?
Hi John –
I’m not sure what you mean…UL 294 is a different listing from the listings for components of fire door assemblies. So some UL 294 products could be acceptable for use on fire doors, but others may not be. The listing to look for with regard to a fire rating is UL 10C.
– Lori
Do door alarms/horns need to be UL294 Certified when installed in an access control system?
Hi David –
The model codes aren’t 100% clear on that, but based on experience (I’m not the AHJ), I would say no. If the horn is required by code – like for a delayed egress lock – it would typically be supplied as part of the listed hardware, so in that case the whole assembly would be listed.
– Lori
I have an E Occupancy that is wanting to put these on an egress doors going out a school cafeteria. Do I understand right that they are not allowed on E occupancies?
Hi Ron –
Can you tell me specifically what hardware they are asking for? This post is not about one particular application.
– Lori
Lori,
They are wanting to put a 15 second delay on the egress because they have smaller kids. It is going to be an Early Childhood Care Center. But it is going to be a very a completely new school.
Ron
Hi Ron –
It depends on which code has been adopted in the center’s jurisdiction. The IBC currently allows delayed egress locks on doors serving classrooms with an occupant load of less than 50. There’s more info here: https://idighardware.com/2018/05/decoded-delayed-egress-locking-systems/.
– Lori
Lori,
Thank you