Printed from the blog of Lori Greene, AHC/CDC, CCPR, FDAI
Allegion
Email: lori_greene@allegion.com, Blog: www.idighardware.com or www.ihatehardware.com


May 16 2016

BBS Memo – Temporary Door Locking Devices

Category: Egress,Locks & Keys,School SecurityLori @ 10:20 pm Comments (30)
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BBS Memo 935When the Ohio Board of Building Standards (BBS) was required by a new state law to create rules allowing classroom barricade devices, there were some who rushed out to celebrate without reading the fine print.  The BBS just issued a memo recapping the requirements of the law, including the limitations on the number of steps to remove the device from the door:

“If a school chooses to use TDLDs, it must submit an application with required information to the building department with jurisdiction for approval. While the scope of the project will not necessitate the preparation of detailed construction documents, per OBC § 106.1.1 the application should include information sufficient to determine compliance with the code, including, but not limited to, evidence of a properly adopted and filed school safety plan, a statement that both police and fire officials have been notified of the proposed TDLD, a description of the proposed TDLD, and, if applicable, a confirmation by the owner that any bolts, stops, brackets, pins employed by the device and that are permanently mounted pursuant to OBC § 1008.1.9.11.2(1) do not affect the fire rating of a fire door assembly. The code does not prescribe in what form this information or evidence of such communications shall be provided…Primarily the building official must determine the number of operations necessary to remove the device. Only a device that requires not more than one operation to be removed may be approved. The code permits two operations to remove the device if the school building is equipped throughout with an automatic sprinkler system.”

Some of the classroom barricade devices on the market today can not be removed with one operation as required in Ohio for non-sprinklered buildings, or even the two operations allowed for fully-sprinklered buildings.  The memo also recommends that schools consult with their legal counsel to ensure that applicable accessibility requirements are met.  When I spoke to a lawyer for a disability rights group, his opinion was that using a locking device that requires tight grasping, tight pinching, or twisting of the wrist was a violation of the ADA.  I hope to have a more official interpretation at some point.  Here’s the recommendation from the Ohio BBS’ memo:

“Finally, building officials can also communicate to school officials intending to use a TDLD that, while the accessibility provisions of OBC Chapter 11 and ANSI A117.1 do not apply to temporary security devices, there are provisions of the “Americans with Disabilities Act of 1990” (104 Stat. 327, 42 U.S.C.A. 12101, as amended) that may apply to the use of the temporary door locking device but are outside the scope of the building code. Schools should consult with their legal counsel regarding any other applicable requirements.”

If your state has not yet addressed the topic of classroom barricade devices – either with a memo addressing the model code requirements or a state code modification, the state board responsible for code changes may want to consider adopting the language that has been approved for the 2018 edition of the International Building Code (this change can be found here).  The new IBC language reinforces the existing model code requirements, and adds a requirement for authorized access from the outside of a locked door using a key or other credential.  If your state HAS addressed classroom security, I’d love to hear about it.  I’ve collected information for some states on my School Security page, but I’d like to compile a more extensive list.

30 Responses to “BBS Memo – Temporary Door Locking Devices”

  1. Chuck Park says:

    So this is good news, but only if there’s enforcement of the rules.

    • Lori says:

      Well, it could be worse. One extra operation (in addition to the lever handle) I can live with – even 2 is not so bad for sprinklered buildings. BUT…I have major concerns about the possibility that an unauthorized person could install the device and trap someone in the classroom with them, in order to commit a crime. Most of the devices do not allow access from the outside by a staff member or emergency responder. There have been several school shootings where the shooter brought materials from home to barricade the door, and the police were not able to get in to help. If some kid installs a classroom barricade device and attacks my daughter, and nobody can get into the classroom…that’s what worries me.

      – Lori

  2. Glenn Younger says:

    I had the opportunity to speak before the San Diego Unified School board about this problem.
    After I told the Virgina Tech shooting story, about how all of those killed and shot happened only AFTER the exit devices were locked together by the shooter with a padlock and bike cable, was there move away from any use of temporary devices. They were one vote away from authorizing money for them, based on their police dept’s suggestion. This district is now working slowly to go to code compliant hardware.

    The cheap, fast and dangerous TDLD solution will keep popping up. For example: we have a active shooter training agent for the local FBI office who has been suggesting TDLD’s. Because it was coming from someone “official” the TDLD was gaining traction when presented to schools. At this point every large law enforcement agency (city, county, state or federal) has an active shooter response plan. Just like Fire Marshals, those folks will need to be trained on the dangers of TDLDs, and how there is a better way.
    The good news is Virginia Tech is such a perfect example of what happens when a shooter locks down from the inside that the dangers can be made real. Thant story needs to be told over and over.

    • Lori says:

      Hi Glenn –

      There are a couple of other good (sad) examples – Platte Canyon High School and the West Nickel Mines Amish Schoolhouse. Both involved barricading, and law enforcement was delayed because of it. There was also a study of 19 barricading incidents in schools: http://www.citeulike.org/user/rborum/article/7416432. I have heard that the California State Fire Marshal has prepared a letter to be sent to each school district, reiterating that these devices are not allowed in California.

      – Lori

      • Glenn Younger says:

        Thanks Lori,

        Seems like every school district is broke, and if they have a police dept who is advocating for the cheap stop gap solution…if creates a problem. Parents and school boards cheer because it looks like a low cost solution. Slow and steady will win the race. We work to change minds one at a time.

        • Lori says:

          Yes – that is exactly right. It’s just crazy to me that (most) schools know they can’t chain their panic hardware together but they don’t see a problem with using a classroom barricade device. Slow and steady will prevail, but I struggle with being patient, and I worry about the first time it hits the news that a kid secured a classroom and assaulted someone. 🙁

          – Lori

    • Steve says:

      The arguement Glenn Younger is pushing is leading readers in the wrong direction. Of course, if the main exit door down the hall is locked, and restricting egress, potential victims need safe rooms, with extra support devices to hold off the bad guy till 1st responders arrive.
      The Virginia Tech example is not a good example of an intruder barricading victims inside a room. …..
      The Virginia Tech shooter chain locked the main exit doors down stairs not the classrooms, The victims were in classrooms not the hallway. He killed students and teachers in unlocked classrooms, returning multiple time to these rooms. He did not get into the locked classrooms. Almost all survived in the locked classrooms because they barricaded the classroom doors giving them time to jump out the 2nd story classroom windows.
      If I remember correctly, a teacher barricading the door long enough for most student to jump before he was shot though the door.

  3. Thomas chin says:

    The mere mention of accepting a barracade device for use during a lockdown creates a very hazardous condition where it can not be unlocked by a secondary person from the other side. Much like the military employing two man rule to avoid these potentially dangerous situations.just because it’s inexpensive doesn’t mean it will do the job safely.
    Most of these devices are sold by ex-law enforcement personal trained to attract these dangerous outcome by attracting and annoying an attacker. People should look for a better way by protecting the perimeter and intiate redundancy in a life safety plan.

    T

  4. Steve says:

    Some TDLDs, temporary barricade devices, do have special release tools for 1st responders to gain entry if needed. I agree this is a must when choosing a device. These devices are meant to keep a bad guy out of your safe place, but If a bad guy takes hostages , and uses this device for his own barricade, we can only hope he uses one of these police friendly, easily releasable, barricade devices. You DO need a good door knob lock in place BUT you also need a second layer of security like TDLDs for when the window and door knob lock are breached. TDLDs are very affordable and in wide spread use across our great country, and will out perform high end, high priced, replacement door knob locks when up against an active shooter .

    • Lori says:

      Correct – some classroom barricade devices do have a method to release them from the outside, but it depends on having the proper tool and the ability to access the device from under the door. Not all doors have the correct clearance to be able to do this reliably. As long as there is no requirement for access from the outside, either type of device (with or without access from the outside) will be used. There are no standards for these devices to ensure this safety feature is included. In past school shootings, locks have not been breached except by breaking the glass, and glass can be addressed fairly inexpensively. I disagree that classroom barricade devices are needed – as you mentioned, the benefit is the low cost. If extra security and low cost are the prevailing factors, why not save some money and use a chain and padlock?

      – Lori

    • Joe says:

      Thanks Steve, well said. The TDLDs exist because the times demand it. The fire codes are changing because the times demand it. Some powerhouse hardware companies take advantage of convenient wordage to avoid losing market share. But at what cost? Full disclosure, I own the TDLD company that has the little red handle. TDLDs will save lives, ours has, in Texas, according to a source at that school. Hostile intruders seldom bring enough equipment to barricade themselves into all the classrooms. I hope as Lori does, that my daughter has a backup devise she can use, in her classroom, if chaos erupts down the hall.

      • Lori says:

        Hi Joe –

        I think you may have misunderstood my comment. I don’t want anyone to be able to barricade the classroom door and assault my child (or anyone’s child), especially if the device prevents access by school staff and emergency responders. There have been several school shootings where the shooter brought materials to barricade the door, and multiple people were killed – in part because law enforcement officers were delayed. In my opinion, hanging the necessary barricading materials next to the door will exacerbate the problem. I would love to hear more about the Texas incident.

        – Lori

        • Joe says:

          Hi Lori, TDLDs are to prevent the shooter from getting in. Once they get in, it’s usually game over. Most damage is done in the first few minutes, before any emergency responders could arrive. I understand the hostage taking scenario, but it can be prevented if the bad guy can’t get in, right?

          • Lori says:

            What if the “bad guy” is already in the room and uses the device to barricade the door and take hostages? This is not an uncommon scenario. This is why classroom function locksets were invented – to keep unauthorized people from locking classroom doors. Whether the “bad guy” wants to kill people or commit a “lesser” crime, the barricade device delays school staff and law enforcement. What is the school’s liability in this situation, if the school gave the perpetrator the necessary tool to secure the classroom? This is only one of the many concerns with this security method.

            – Lori

          • Joe says:

            Good points Lori, The school can keep the locking member out of sight, teachers desk, drawer, etc., there are many ways to barricade a door, a belt on the closer, desks and chairs.
            I appreciate your thoughts, great debate.
            Joe

  5. Joe Hendry says:

    Lori, you are absolutely correct about the clearance issue. One device I have observed marketed as having a special tool for releasing the device from the ingress side of the door for law enforcement is a disaster waiting to happen. It can be defeated by simply slipping a heavy metal hanger under the door to trigger it’s release. The solution is to upgrade the codes for doors, locks, windows and walls to allow for the use of the evacuation and lock down tactics. These should compliment the fire safety codes, not be in opposition to them. We are not thinking through the problem, only up to it.

  6. Steve says:

    You are absolutely INcorrect, There are requirements. Standards
    are individually mandated by each state. Most require a release
    mechanism or defeat method to disengage TDLDs. All TDLDs are
    different, some need a clearance below the door, some require keys or a wrench, some need a sawzall. Schools should choose simple & easy. Remember most active shooters will not carry enough tools to breach a barricade device. Historically, most shooters have not breached a barricaded door.Also states only allow use during emergency lockdown events, and require training for staff. TDLDs are being allowed to accommodate a balance between life safety and fire code.
    When trying to breach a door, an active shooter will target the
    door knob and window 1st. More layers of security are needed. Yes, ADD force resistant film to windows, yes, ADD high end,high priced door knob locks, YES ADD a School resource officer at each door. BUT LETS GIVE OUR TEACHERS THE TOOLS to protect our kids.

    • Lori says:

      What are the test standards for these devices? I don’t know of any. Classroom barricade devices are not required to be tested to ensure that they will provide the required amount of security, or that they can be removed for evacuation.

      Many states have issued documentation reinforcing their current code requirements which do not allow this type of device to be installed in addition to existing hardware. Here is one example of that documentation: https://dps.mn.gov/divisions/sfm/programs-services/inspections/Documents/Security%20and%20Barricade%20Devices%20on%20Classroom%20Doors%20-%20Info%20Sheet.pdf.

      The few states that do allow the devices DO NOT mandate a way to release the device from the outside. That is not a requirement of the Ohio legislation that is the topic of this blog post.

    • Mark says:

      The legislators have stepped into the code development arena in Ohio taking decision making out of the hands of the fire marshals who have had jurisdiction over life safety codes for decades. In doing so, they have complicated the process for providing security and life safety for our children and staff in school classrooms. They have made it possible for manufacturers of untested and unlisted devices to install barricade devices in classrooms impeding ingress and egress (many do not comply with ADA laws), even though there are code compliant solutions available. The challenge is the code compliant solutions are more expensive. Security and safety is being compromised for the sake of cost. Funds that are available for school security are being prioritized on federal buildings through the Department of Homeland Security, even though schools fall under the DHS umbrella. We need to bring pressure on our legislators to provide funding for school security through DHS instead of forcing them to work through their operating budgets and choose between books and locks. We don’t need legislators involved in changing life safety codes! Do we really believe they understand the issue?

      The fact remains, there are effective code compliant solutions. There is not one documented case of an active shooter breaching a locked door. Third party legal opinions have indicated that schools are at risk if they deploy these devices. I’m sure the lawyers are lining up waiting for the first case of a serious violent event to happen where somebody barricades themselves in a room to act out their crime.

      • Steve says:

        Mark, you say, you don’t need legislators involved making life safety decisions. Really, Are they not human ? I think they possibably actually breed, and have kids, and grand kids, and great grand kids who actually go to schools. What are the odds that one of them actually had relatives learning how to tuck & roll at Virginia Tech, Columbine, or Sandy Hook ? Instead of trashing TDLDs, start taking window and side lites out of classrooms, thats how a shooter will reach in and turn your door knob for easy ingress. ( Oh guess what ? These windows are put there to detour crimenal activity in a classroom).
        Theres plenty of other things you can be doing to make kids safe. The classroom door is the last line of defence. If the perp is past the front door, its too late. Barricade all doors, to ENHANCE & BACK UP the other SAFETY features like knobs. My kids safety can’t rely on a one trick pony… Make BARRICADING Possible and really FAST & EASY with Temporary Door Locking Devices.

  7. Joe says:

    Joe, put the word out to the next hostile intruder, that the door industry isn’t ready yet. I bet you have a backup plan at home. Baseball bat? Gun? Escape hatch? Really?

    • Lori says:

      The door industry is ready to protect students and teachers – with new products and with products that have existed for decades. According to the Sandy Hook Advisory Commission, “The testimony and other evidence presented to the Commission reveals that there has never been an event in which an active shooter breached a locked classroom door.” The only benefit of classroom barricade device over a traditional lockset is the cost, and the potential risks of using the devices are huge. I realize that we will never agree since you are a manufacturer of classroom barricade devices, but I’m positive that time will tell.

      • Joe Hendry says:

        I would have to agree with Lori whole heartedly on this point.I have no dog in this fight, other than the best and correct way to upgrade a facility for this event. As an SME in the field, my professional opinion is that the secondary door locking devices are dangerous and easily used against us for a myriad of reasons. What officers or school personnel are carrying wrenches and reciprocating saws (sawzalls) as part of their day to day operations to breach doors’ secondary barricading devices? These are untested devices, with no manufacturer standards, that are continually marketed as un-breachable by current law enforcement and fire tools in several sales videos. Potential customers may be watching them…right along with those that would be more than happy to use them against us. Bad guys don’t normally barricade, except now we are giving them the means to do so and they don’t have to bring a thing with them.

        • Steve says:

          Glenn you know that any device, gun, baseball bat, or pencil could be used against us, to keep us from getting away.
          In our city, all police and fire vehicles are equipped with the release tool to support our barricade device of choice.
          Our city is better ready for any form of terrorist activity. A rogue student, may be the least of our worries.

      • Steve says:

        The Sandy Hook Advisory Commission, says: evidence presented to their Commission reveals that there has never been an event in which an active shooter breached a locked classroom door.” Good, LETS lock and block. Appearantly it works. Use your Allegions door knob locks,classroom furniture, a teachers body, duct tape, yes even TDLDs,JUST DO IT. The more the merrier. By the way. The actual Sandy Hook Elementary didn’t have ANY locks.

        • Joe Hendry says:

          Steve, just as point of clarification. Sandy Hook Elementary did have locks on all classroom doors. The locks were located on the ingress side of the door and required the teacher to go into the hallway to lock the door. The first recommendation from the Sandy Hook commission was to move those locks to the egress side of the door.

  8. Michael Thorp says:

    Our company received an inquiry for relabeling of fire doors in schools in Ohio that have installed TDLD’s. The school district Facility Supervisor relayed that the code now accepts these devices however they have to document where these are and submit a plan to the Local Building Inspector who will inspect these and then issue a new occupancy permit for any buildings where they installed these.

    The issue for our Company is that they installed some of these on doors that are listed fire rated doors with metal tags on the doors and frames. The Code official has requested that they have a company(such as our company who has certifications for field labeling being an independent testing laboratory) inspect these and certify that their installation has not compromised the integrity of this rating on either the frame or door. They do not believe that this installation has impacted that rating as they did not drill holes through the doors (or frame) to complete this installation and the frames are all filled with mortar as well.

    Not knowing the type of hardware used and installed location points on the doors at this time, as I am waiting on more information, I have a concern in relation to NFPA 80. Since all hardware installed on a fire door must have a fire rating label from a testing agency, have any of the door manufacturers raised concerns of retro fitting this type of hardware on their listed doors and the effects of such installations on the current fire labels being voided? Would they allow a relabeling to comply with the local official’s request. Obviously in a school district with 12 buildings and a hundreds of doors supplied by different manufacturers, researching the test data in regards to allowable hardware modifications would be most intensive. Since these type of assemblies were not even designed or thought of when most of the doors were manufactured, I am thinking that an EET report might be required from the listing agencies.

    With installation on mineral core doors, if the hardware to attach is not in a reinforced area, the core could be compromised and since they indicated holes were not drilled through the door, such hardware being surface mounted on the wood veneer will have no structural integrity at all. This could lead the hardware to being pulled away exposing the core. That would requiring replacing the door since there is no acceptable repair available once the core is exposed. Any guidance here would be appreciated as we are treading into uncharted waters in many respects.

    • Lori says:

      This is a tough one. All of the components used on a fire door are supposed to be listed for that purpose. I don’t know of a classroom barricade device that is listed for use on a fire door. There’s also the question of modifying the door, but most of the devices can be installed without drilling holes larger than the 1″ that is allowed by NFPA 80. I think your concern about eventually having visible holes is a valid one. I would recommend contacting the listing lab before relabeling or certifying the doors.

      – Lori

  9. Michael Thorp says:

    So I found out the school district used a Hager 275D slide bolt UL listed for use on an inactive leaf. They then modified the bolt, removing the pin to then allow the bolt to be removed, leaving only the slide guides attached to the doors. They then painted the handle of the bolt red. There was a hole/strike plate installed in the soffit of the frame adjacent to the stop to receive the bolt. I called the Engineering department of Hager Companies and explained the situation. Obviously, I knew the answer that the modification done voids their labeling as the installation was not done in accordance to the instruction (not an inactive leaf) plus it was modified by the removal of the pin to remove the bolt completely (the pin that keeps the bolt within the guides). So they now have an unrated improperly installed modified piece of hardware on a fire door. Now to see what the door manufacturer states. A quagmire for sure here.

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