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


Dec 14 2017

Decoded: Classroom Security Code Update (May 2018)

In the last 3 years, I have written several dozen articles and blog posts about classroom locking and the need to consider life safety and egress in conjunction with security.  Now that the model-code changes for 2018 have been finalized, many people have asked me for one article to distribute which summarizes the current status of the code requirements.  This article will be printed in the May 2018 edition of Doors & Hardware, but here’s an advance copy – posted in remembrance of the lives lost at Sandy Hook Elementary School 5 years ago today.

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This post will be published in the May 2018 issue of Doors & Hardware

During the code development cycle for the 2018 model codes, the issue of how schools can enhance classroom security without compromising life safety was discussed and debated at length. Should existing code requirements be relaxed in order to allow less expensive security devices to be installed? Should the requirements remain as-is, or should additional mandates be included in the model codes?

The 2018 model code requirements do not allow door closers or panic hardware to be modified to accommodate retrofit security devices.

“Today, schools face significant safety and security threats – and not just in terms of natural disasters,” said Tim Eckersley, Security Industry Association (SIA) board member and Allegion’s senior vice president and president of the Americas.  “Our schools are ‘soft targets’ for man-made violence, too. At the same time, the main instructional buildings of America’s ~100,000 K-12 public schools are, on average, more than 40 years old. Many schools don’t have updated hardware and technology that’s available to protect students, teachers and administrators, at least in part because they don’t have access to funding.”

This critical lack of security funds has helped fuel the growing popularity of retrofit security devices, the majority of which are not compliant with the model codes. Code requirements that have been in place for decades are being overridden in some jurisdictions based on the assumption that the codes mandating free egress, fire protection, and accessibility for all should not apply during an active-assailant situation in a school. In a handful of states, legislators or code officials have gone so far as to modify the state code requirements for egress in order to allow classroom barricade devices to be installed in schools.

Clearly it was time to clarify the intent of the model codes with regard to school security. Through the consensus process used for model code development, stakeholders from all related areas of expertise had an opportunity to take part in the decision and make the case for or against the use of these retrofit security devices, also called classroom barricade devices.

Risk Perception

For more than 3 decades, model codes have required doors in a means of egress to be unlatched with one releasing operation; this requirement will continue in the 2018 edition of the model codes.

Proponents of barricade devices lean heavily on the perception that the threat of an active shooter event in schools outweighs the probability of fire. This has been a successful tactic largely because humans are not always good at accurately assessing risks. We have a tendency to perceive danger based on factors that have nothing to do with the likelihood of a particular event occurring. This is especially true when children are involved. If you were to ask the average parent about the greatest threat their child faces in school, there is a very good chance they would say gun violence. National tragedies like Columbine and Sandy Hook have laid the foundation for the perception that an active shooter event is more likely than a fire or other incident that requires immediate evacuation.

However, the National Fire Protection Association (NFPA) reports that between 2000 and 2013, there were 1,456,500 non-residential structure fires in the U.S., with 1,260 civilian deaths and 21,560 civilian injuries[1] . For the same period, the Federal Bureau of Investigation (FBI) published statistics on active shooter incidents, counting 160 shootings resulting in 487 deaths and 557 injuries[2].

Also overlooked is the fact that many plans for past school shootings have included the use of fires and explosives. Evacuation is a primary component of the emergency plans for schools, but classroom barricade devices not only deter or prevent access to the classroom, they also restrict egress from the room.

In 2015, the National Association of State Fire Marshals (NASFM) published a classroom security checklist, and NASFM members approved a resolution supporting these guidelines. “The state fire marshals understand the security concerns and the need to protect schools and businesses from senseless acts of violence,” said Jim Narva, executive director of NASFM.  “However, some of the proposed solutions may compromise life safety, despite the manufacturers’ good intentions. The NASFM guidelines for classroom security are aligned with the model codes, and underscore the importance of the requirement for new and existing classroom doors to unlatch with one operation, ensuring free and immediate egress. Classroom doors must also meet federal accessibility laws and other requirements of the building codes and fire codes.”

Another risk associated with retrofit security devices is the potential for unauthorized use.  As the Door Security & Safety Foundation noted in its publication on liability of classroom barricades (published on LockDontBlock.org):  “Storing a barricade device in a classroom makes crimes easier to carry out. When used by an unauthorized person, barricades have the significant potential to facilitate unintended consequences such as bullying, harassment, or physical violence. According to the Centers for Disease Control and Prevention (CDC) and the FBI, a member of the student body is most likely to commit violence on school grounds.”

Accessibility

The accessibility standards require releasing hardware to be mounted between 34 inches and 48 inches above the floor, and protruding hardware can not be installed within the bottom 10 inches of the door on the push side.

Another consideration raised was how the use of these products could potentially violate the Americans With Disabilities Act (ADA), a federal law that prohibits discrimination against people with disabilities and sets standards for accessible access and egress. The 2010 ADA Standards for Accessible Design, and ICC A117.1 – Accessible and Usable Buildings and Facilities are the standards that apply to most new and existing buildings in the US. Both of these publications require hardware to be operable without tight grasping, pinching, or twisting of the wrist. In addition, the releasing hardware must be mounted between 34 inches and 48 inches above the floor or ground to ensure that it’s within the accessible reach range.

These accessibility requirements have largely been ignored with regard to classroom barricade devices, as the operation of most designs would be beyond the abilities of many occupants with disabilities. In the midst of a stressful event like a fire or active shooter, it’s likely that many of the students or even teachers could have difficulty operating devices that require the use of fine motor skills and a high level of dexterity. The amount of adrenaline released into our systems when we are under threat has an adverse affect on our performance of even basic mechanical skills, which is why law enforcement, firefighters and others who regularly encounter these situations must train so intensively to respond effectively in an emergency.

Classroom doors nationwide are required to comply with the ADA, so it’s unclear how states can adopt codes that are in conflict with a federal law. As noted in a letter written to the NFPA Standards Council by Curt Decker, the executive director of the National Disability Rights Network (NDRN), allowing these devices to be utilized in classrooms would be “…discriminatory to those with physical or visual impairments, impedes egress, and is in violation of standards and laws regarding accessibility.”

New Code Requirements

Classroom security locks help to prevent unauthorized lockdown, and indicators ensure that the locked/unlocked condition is obvious to school staff.

Fortunately, the outcome of this code development process was an overwhelming decision to not only maintain the existing egress requirements for classroom doors, but to add an additional safety mandate. The 2018 editions of the International Building Code (IBC), the International Fire Code (IFC), and NFPA 101 – The Life Safety Code will include the following requirements for classroom doors:

  • The latch(es) on egress doors must be unlatched simultaneously by one releasing operation from the egress side. Hardware used to release the latch(es) must be mounted between 34 inches and 48 inches above the floor.
  • Operation of the hardware for egress must be accomplished without tight grasping, pinching, or twisting of the wrist, and without the use of a key, tool, special knowledge, or effort. If electrified locks are remotely engaged, they must allow free egress from the classroom side of the door.
  • Locked classroom doors must be able to be unlocked from the outside with a key or other approved means, to allow access for school staff and emergency responders; this is the new requirement that was added to the 2018 model codes.
  • Door closers, panic hardware, and fire exit hardware may not be modified by retrofit locking devices, and modifications to fire door assemblies must be in accordance with NFPA 80 – Standard for Fire Doors and Other Opening Protectives.
  • The facility’s emergency plan must address the locking and unlocking of classroom doors, and staff must be drilled in these operations.
  • In addition, NFPA 101 requires the doors to be lockable from within the classroom, without opening the door.

In an NFPA Journal article about the proposed code changes to NFPA 101, Ron Coté, the NFPA’s technical services lead for life safety wrote, “The classroom door locking criteria will help weed out the dangerous hardware and locking means, currently available in the marketplace, that do not provide safe egress from the classroom.”

Code-Compliant Security

Electrified locks used on classroom doors may be locked from a remote location, but must allow free egress.

Although the intent of the model codes is perfectly clear, there is more work to be done. School administrators, code officials, and the general public must be informed of the model code changes and introduced to the numerous options for locks that meet all of the requirements for egress, fire protection, and accessibility while providing the necessary level of classroom security. As was noted in the final report of the Sandy Hook Advisory Commission (2015) “There has never been an event in which an active shooter breached a locked classroom door.”

Schools can also enhance security in other ways such as the installation of impact-resistant glazing adjacent to door hardware, distribution of keys to all staff including substitute teachers, improving perimeter security by locking and monitoring exterior doors, standardizing visitor protocols, and conducting regular training and drills for students and staff.  Many of these best practices are addressed in the Guidelines for School Security published by the Partner Alliance for Safer Schools (PASS).

Summarizing the issue, Robert Boyd, the Executive Director of the Secure Schools Alliance recently noted, “You don’t have to sacrifice life safety for security. You don’t have to destroy fire codes or violate laws that help the disabled to protect vulnerable populations. You won’t save money by using inappropriate products, when affordable solutions that meet codes and laws exist; you only expose yourself to new liabilities. It is irresponsible to make it difficult to flee a hazardous situation…Schools house our most vulnerable population, our children, and their safety should be first.”

[1] National Fire Protection Association (NFPA) – Non-Residential Structure Fires

[2] FBI Study of Active Shooter Incidents in the United States Between 2000 and 2013

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Lori Greene, DAHC/CDC, FDAI, CCPR, is manager – codes and resources for Allegion. She has worked in the door and hardware industry since 1986, and in her current role she provides support and education on code requirements that apply to door openings. Her website, iDigHardware.com, includes numerous resources such as online training, videos, and a downloadable code reference guide. The site is updated each weekday with new information, and readers can subscribe to daily or weekly notifications of new posts. Lori can be reached at lori.greene@allegion.com.

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If you have any suggested changes for this article before it is formatted into a printable version, please leave a comment in the reply box. 

2 Responses to “Decoded: Classroom Security Code Update (May 2018)”

  1. Glenn Younger says:

    Hi Lori,
    Another terrific summary on an important topic.
    As you may know, in California we have a somewhat unusual situation where a state law was passed regrading requirements for school doors for protection. AB211 passed in 2010, and is enforced by the Division of the State Architect.
    Since many door and hardware codes crazy ideas start in California (like levers instead of knobs, levers with returns on them, etc) and then move across the contintent, I’m wondering if it might be interesting to look at the California requirements and compare to current codes regarding school buildings, classrooms etc.
    Just a thought.
    Some more background:
    https://www.ocde.us/Facilities/Documents/DOOR%20HARDWARE%20DSA%20BULLETIN%2011-05%2006-24-11.pdf
    https://www.documents.dgs.ca.gov/dsa/fls/flssecurityvsexiting.pdf

    Keep up the good work!

    • Lori says:

      Thanks Glenn! The BHMA CGA did look at the CA legislation when we were working on the model code change proposals, but we had to balance what we hoped to incorporate into the codes with the possibility of losing the whole proposal because we were asking too much.

      – Lori

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