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


Apr 27 2017

I need you.

UPDATE:  This article has been revised and posted here.

This is not just another article on classroom security.  This is an opportunity to impact the decision to change NFPA 101 – The Life Safety Code in a way that could negatively affect life safety in our schools.  I want to make sure I didn’t miss any important points.  I need you to set aside 20 minutes to read it as if you weren’t already familiar with the issue, really think about it, and let me know if there’s something I should add or change.  I know you have other things to do, but I’m asking for this one favor.  Let’s not look back on this moment in history and think, “If only we had done something…”

Note:  I will be adding some images to illustrate the types of applications that would be allowed if this change is approved.

Classroom Security AND Classroom Safety – Why Compromise?

Several proposed changes are currently being considered for the 2018 edition of NFPA 101 – The Life Safety Code. There is one proposed change – just one little word, actually – that is a major deviation from the current model codes and is inconsistent with both the International Building Code and International Fire Code:

“The releasing mechanism shall open the door leaf with not more than two releasing operations.”

This proposed language applies only to existing buildings and would not affect new buildings, but there are three occupancy chapters where this language regarding two operations would be inserted: Chapter 15 – Existing Educational Occupancies, Chapter 17 – Existing Day Care Occupancies, and Chapter 39 – Existing Business Occupancies.

Many college and university classroom buildings are considered business occupancies, so the proposal for Chapter 39 would include classroom doors within these facilities. Unfortunately, because the proposal for this chapter does not specifically reference classrooms or colleges/universities, the language could actually be applied to any room in any business occupancy with approval from the Authority Having Jurisdiction (AHJ).

This language would allow building owners to request the AHJ’s permission to use retrofit security devices in any existing business occupancy.  NFPA 101’s definition of a business occupancy and the examples listed in Annex A include city halls, courthouses, outpatient clinics, town halls, and office buildings, in addition to college and university classrooms.  This could put AHJs in a tough position, similar to the situation in some states where school districts have pushed for AHJs to allow classroom barricade devices in schools.

More is Not Always Better

When reviewing the proposed language, one should begin by considering the current one-operation requirement versus the proposed two-operation limit for existing buildings. Would increasing the number of operations that must be performed to open a door actually enhance the level of safety in our classrooms?  Does the potential for increased security justify delaying occupants’ evacuation?  What is the motivation behind this change and does it outweigh the potentially deadly consequences?

The Life Safety Code has required hardware to unlatch with one releasing operation for almost 30 years.  Even as far back as the 1927 edition of the Building Exits Code, doors were required to be “so arranged as to be readily opened.”  Similar language still exists in the Life Safety Code today.

The 1985 edition of NFPA 101 required a simple type of releasing device such as a knob, handle, or panic bar, with a method of operation that is obvious, even in the dark.  In the 1988 edition, a line was added to quantify the allowable number of operations:  “Doors shall be openable with no more than one releasing operation,” with an exception for one additional releasing operation on dwelling units in residential occupancies.  The requirement for one releasing operation has been included in the ten editions of the Life Safety Code that have been published since 1988.

Sacrificing Life Safety for Cost Savings

So why change now?  There is no shortage of code-compliant products available to provide the necessary level of security for any of these occupancies.  Even in areas prone to vandalism and theft, there are a variety of ultra-secure products approved for use on exterior doors which release with one operation. The only reason I can think of for changing to two operations is to allow schools to buy retrofit security products at a lower cost than traditional hardware.

In response to the many school shootings and other school-related incidents in the US, there has been a heightened focus on school security. However, rather than addressing the existing locks, key systems, glazing, and security procedures that may not provide a sufficient level of protection, some school districts have elected to install retrofit security products, also known as classroom barricade devices. As mentioned previously, AHJs in many states came under tremendous pressure to approve these products, despite clear violations of the existing model codes. One unfortunate example occurred in Arkansas, where the State Senate voted unanimously to amend the fire code requirements and allow the use of barricade devices despite the strong objections of their state fire marshal, who also happens to be a top law enforcement official.

The end result has been a number of inconsistencies from one state to the next, and even greater variations between school districts where conditional use of retrofit security devices is allowed. First responders could arrive on-scene without knowing what to expect and without the tools needed to access rooms equipped with classroom barricade devices.  In addition to impacting evacuation, these devices could also be used by someone intent upon barricading the door to commit a crime or take hostages, delaying response by staff or law enforcement.

While it may be relatively inexpensive to purchase and install barricade devices on classroom doors, in some cases it may actually cost less to simply address the existing doors and hardware.  The locks might need to be rekeyed and keys distributed to all staff members.  Existing glazing can be addressed with security film to delay access through a sidelight or vision light.  New protocols, like keeping existing classroom function locksets locked during the school day, could also enhance existing security at a relatively low cost, without creating potential threats to occupants’ life safety.

Safety vs. Security

The model codes do allow two releasing operations for the entrance door to a dwelling unit or sleeping unit.  This exception seems reasonable, as the person who is disengaging the locks for egress is probably the same person who engaged the locks and is likely to be very familiar with the method required to do so.  However, a student attempting to remove a retrofit security device in order to evacuate a classroom may not know how to disengage a locking device that was installed by the teacher.

NFPA 101 also currently allows two releasing operations for existing hardware on a door that is serving a room with an occupant load of 3 people or less.  Obviously, the occupant load of an average classroom is well over 3 occupants.  It hardly seems reasonable to raise the limitation from 3 occupants to 30 or more, especially when most of those occupants are children.

Under the stress of an emergency situation, the average person struggles to correctly perform just one fine motor skill. This point was also made by Joseph Hendry, CLEE, who has decades of experience in law enforcement and who now works for the ALICE Training Institute, training civilians to proactively handle the threat of an aggressive intruder or active shooter event. “Several assumptions are being made without considering that most people are unable to perform one fine motor skill under stress,” he said. “Requiring them to perform two is probably beyond 90-95% of the people I see in training.” He went on to note that even highly-trained law enforcement officers miss 70-80% of rounds fired under stressful situations.

Another issue that is apparently being overlooked is the fact that classroom doors are not exempt from the accessibility requirements that apply to doors on an accessible route.  These standards require hardware to be operable with one hand, and with no tight grasping, pinching, or twisting of the wrist; the proposed change to NFPA 101 does not include this requirement, and this creates a conflict with the accessibility standards.  To ensure that classroom doors are usable by everyone, these standards must apply at all times, particularly in the event of an emergency.

It should also be noted that there is nothing in the proposed language to prevent the two releasing operations from having to be performed simultaneously.  This type of operation could restrict egress for many occupants under normal conditions, and could seriously impact evacuation under the stress of an emergency situation.

“A Hazard to Occupants”

In order for NFPA 101 to allow two releasing operations for certain egress doors, an exception would need to be added in Chapter 7 – Means of Egress, referencing the applicable occupancy chapters. Chapter 7 of NFPA 101 currently requires doors to be openable with one releasing operation, and the Technical Committee on Means of Egress – a different committee than those considering the proposed language for the occupancy chapters – is opposed to the addition of the new language in Chapter 7.

The committee stated that increasing the number of releasing operations is “dangerous and could create a hazard to occupants.”  They went on to note that there is existing technology that meets the current code requirements and that allowing multiple operations “is contrary to decades of experience resulting in fatalities in schools and other buildings.”

Many of our existing codes were developed in response to tragedies like the fires at the Triangle Shirtwaist Factory or the Cocoanut Grove Nightclub – situations where people died because they were unable to evacuate quickly and safely during an emergency. We have worked for decades to ensure that life safety is maintained, first and foremost, in any building. It’s the reason chains and padlocks aren’t allowed on exit doors, despite how inexpensive and effective those chains are at preventing unauthorized access. After so many years of steadily improving life safety and successfully reducing the number of fatalities due to structure fires, I can see no justification to change the Life Safety Code in way that could reverse those gains.

Joseph Hendry raised similar concerns, noting, “I find it hard to believe that no human-subject testing is being conducted before considering the change from one releasing operation to two. Allowing something so far beyond the pale – without studying human response to stress – is unconscionable in the use of retrofit security devices. The mistakes we made with lockdown are being exacerbated by the push for these devices.”

It’s Not Too Late

Fortunately the proposed changes to NFPA 101 have not yet received final approval, and some of the points will be discussed in June at the National Fire Protection Association’s annual conference.  Eligible members will have the opportunity to vote on the final language that will be included in the 2018 edition of NFPA 101.

Given the concerns related to evacuation and accessibility, the inconsistencies with other model codes and standards, the non-specific language around business occupancies, and the lack of evidence establishing that the new language would not be detrimental to life safety, I hope the voters will carefully consider their decision and vote to maintain that crucial balance between safety and security.

18 Responses to “I need you.”

  1. Adam says:

    Thank you for compiling this, there is one point that I wonder is worth including that I feel is lost in this: It is important to note under the current limit of one-operation, a person must simply figure out that one action in an emergency–you press on a lever, it works, or perhaps no lever is present, so you toggle a deadbolt. Not only does the change of two actions add a step, but since the actions are undefined, it can be impossible to know which actions must be taken or are already taken. Is the deadbolt already thrown, or did I just throw the deadbolt and lock myself in further when I use a lever? The permutations, even when you understand how it works, go up. If you don’t understand how it is supposed to work, then the issue could lead to even greater confusion.

  2. Eric Rieckers says:

    Nothing comes to mind that should be revised or edited in any way. Excellent job.

  3. Lisa says:

    Lori,

    I think this article is excellent and clear. Let me know how I can support it. Will you be sending it with a signed petition to the NFPA?
    I’m going to share this with some friends from Newtown, CT too.

  4. Jerry Richmond AHC/CDC says:

    The only people pushing for this change to “two” actions are peddlers, looking to make a fast buck, and frightened and uninformed parents who are easily preyed upon out of their fear. Wake up ladies and gentlemen! This isn’t the Dark Ages! There is nothing wrong with the current codes. Our products and our intelligence on how to properly apply them, will keep little Bobby and Susie safe and secure!

  5. Bill Cushman says:

    Why stop at 2. Why not make it 100 actions to open a door? Simple, ZERO is the best for life safety. And 1 is the BEST we can do. Anything beyond the BEST is ridiculous, unsafe, and honestly driven by greed.

  6. Raymond Holman, AHC says:

    All good points. It’s a disgrace when school districts have to choose between life safety and security. Considering how many products are currently on the market to solve this problem, this should not be an issue but is being promoted by those who would benefit the most, and cash-strapped school districts who don’t feel they have a choice. If the legislature wants to have a real impact, find the funding to do it right instead of compromising our kid’s (and grandkid’s) safety.

  7. Rich says:

    I totally agree with Adam’s thought. In addition, what will happen in an emergency situation when someone approaches a door with a lever or an exit device that has always opened that type of door in the past. Now it doesn’t let the door open because of a new and unfamiliar device that has been added. The person stalls, momentarily confused because the expected action of the door opening did not happen. Panic ensues because of the imminent threat behind him, and now a crowd of people are jamming up against the door and the secondary device cannot be disengaged with pressure against it. You now have a pile of dead people at that door in a fire situation. If the secondary device releases as smoothly as a lever or a push bar, it would still be confusing to the general public that has learned the current “standard” operating procedure. If a secondary device jams up or quits working with pressure against the door, any panic situation requiring fast exit would have the potential of sealing the door shut. Try to get a panicked crowd to back off the door to free it. Any device added to a room that requires an exit device, should have to comply with the same push pressure restrictions as an exit device.

  8. Jack Ostergaard says:

    Several thoughts – you touched on this but the one operation was implemented because of fire incidents which are still more likely than a shooter incident – I’m sure you have recent numbers to back this up.
    Suggest a change in the first para of Safety & Security – change “student” to “young child” or “young student” Also point out that this person may not be capable of removing or operating some of these barrier devices.
    Thanks again for standing up on this incredibly important issue!

  9. Glenn Younger says:

    Well done. I believe that is never hurts to mention other places where the 2 step process runs afoul of common sense and other rules / guideleines.
    “Another issue that is apparently being overlooked is the fact that classroom doors are not exempt from the accessibility requirements that apply to doors on an accessible route. These standards require hardware to be operable with one hand, and with no tight grasping, pinching, or twisting of the wrist; the proposed change to NFPA 101 does not include this requirement, and this creates a conflict with the accessibility standards. To ensure that classroom doors are usable by everyone, these standards must apply at all times, particularly in the event of an emergency.”
    The 2nd operation is, almost always, non compliant with accessablity guidlines. With numbers approaching 30% of the population operating with some physical limitations, it seems that this should be an even bigger priority, and with slightly stronger language. Just a thought.

  10. John dalrymple says:

    Another example to cite is the Iroquois theater. The locking mechanisms on these doors were bascule locks and hence so complicated to operate that the ushers were trained in their use. But those ushered weren’t there for the matinee so the loss of life was compounded by doors that the public could not operate.

    The examples that we could cite are too numerous to list Lori. This movement to prove de cheap security is dangerous. People are going to be harmed or killed if this measure passes.

  11. Khozema Kazi, AHC, FDAI says:

    There will always be more than one person at the door attempting to escape and each will try to do or undo what the other would have done on the door hardware when two operations are required, leading to further delay in egress and resultant fatalities. Therefore there shud be no compromise on current ‘one operation’ requirement.

  12. Luis I. Marrero says:

    Lori,
    Your article is SPOT ON, lets hope that great minds think alike and at the time of the vote they support this position.

    Cheers

  13. Michael W Schroeder says:

      I’m a retired firefighter, and fire prevention officer of 30+ years. 
    For the majority of those years I conducted fire inspections in Life Safety Occupancies, schools, hospitals, nursing home, CBRF’s, detention facilities, psychiatric hospitals… etc.
      I have witnessed drills so preplanned that when the alarm goes off the smokers are well into their second butt, and the bagel shop across the street has already served up some nice bagels with creamcheese and lox.
      When “I” conducted the drill it was unannounced.  I picked people who thought that this was a bit of a waste of time, after all they weren’t in grade school anymore. I challenged them with an unannounced drill. Many couldn’t even let the people in the immediate area know there might be a problem, much less pull an alarm, operate anything, or do the simplest tasks.
      I am talking about people are “normally” without any impairments. This applies to the Teacher, Social Worker, Psychiatrists, Nurses, Doctors, Lawyers, off duty Police Officers, Judges, Senators, Representatives, US Marshalls, State Supreme Court Justices, and Department Administrators. All normally intelligent people who should have some degree of emergency training.
       This is where our evolutionary biological science becomes important, we likely developed the flight response to survive the threat of a predator. Conducting the unannounced drill placed them under enough mild stress to release adrenaline  and have a negative effect on their performance.
      This principal is simple, and well understood in the emergency services community, and armed forces. They train “intensively” (not always successfully) to get accustomed  to the release of adrenaline.
       Adrenaline released when you feel a threat may give you strength and  give you speed.  It will not give you the ability to do simple math, or solve “ANY” sort of complex problem. You hear people describe incidents like they happened in slow motion. You loose your peripheral vision and hearing. In short, you may be stong and fast but you also become blind and stupid.
       The last thing you need is a door that opens with more than one action. Why throw more hardware on the door when there are already mortise locks that will open the lock and the deadbolt with a single action. This type of lock has been around forever, it is reliable easy to operate and code compliant for areas not requiring panic  hardware.
       If two actions made it safer, I’d be all for it, but it doesn’t, it makes it less safe.

  14. Rick Halloran says:

    Excellent article. I might stress the accessibility issues. I would have to believe that the USDOJ would strike down any regulation that would require more than one hand to operate door hardware. I also think you will get severe piush back from organization representing persons with cognitive disabilities. I might also question how one will get both mechanisms in the 14″ height range (34″ to 48″) for 2010 ADAS or the 10″ (34″ to 44″ ) range for California Building code.

  15. Rex Dougherty says:

    Lori, I couldn’t agree with your assessment of the issue more. One motion is as much as most people can handle in a duress situation. I know this isn’t going to be a popular statement with our second amendment fans, but, it’s time that our government address the real issue that NFPA-101 is trying to deal with here and that’s keeping guns out of the hands of those who are suffering from mental issues. We simply can’t continue to penalize the innocent for the lack of action on the part of government to do their job.

  16. Joel Niemi says:

    This is well presented.

    Because the proposal is for existing buildings, if adopted it would move new structures nearer to the top of the slippery slope for 2-action hardware. You know that would be coming after the barricade-device salespeople run out of older-building customers.

    I suggest pointing out that existing buildings may, from a safety standpoint, be the very ones that should Not be harder to exit from. For instance, a 20 year old building might not have the fire sprinklers which a newer structure might. Smoke partitions and the plethora of products for sealing their edges are a new thing. Anything that delays, hinders, or endangers easy exiting – like 2 operations instead of one – compromises the occupants’ safety. I’m not saying that every new building is intrinsically safer than an old one, but why purposefully make them less safe?

  17. Khozema Kazi, AHC, FDAI says:

    Michael W Schroeder, yours and others with similar experience/views, should be put to the NFPA committee deliberating this issue.
    specially important is your comment ‘Adrenaline released when you feel a threat may give you strength and give you speed. It will not give you the ability to do simple math, or solve “ANY” sort of complex problem. You hear people describe incidents like they happened in slow motion. You loose your peripheral vision and hearing. In short, you may be stong and fast but you also become blind and stupid’
    Concluding that it will be beginning of a waiting disaster if the two operation language is included in the new revision.
    I am already getting goose bumps.

  18. Jerry Rice says:

    I have heard multiple times from school districts that “we would have to lay a teacher or two off to purchase the compliant hardware.” Their two main arguments deal with speed and cost. “I can get these after market products faster and save money.” All of your arguments are truthful and logical, and I am sure the districts would agree to install the correct stuff, if they could get them for the same price. Too bad you cannot ROI the compliant hardware against the average financial settlement in loss of life or assault charges. Just saying, you might need to speak their language. Well written article, thanks for your leadership – as always!

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