I don’t like surprises (except for the surprise package that I received from one of you last holiday season)…especially when it comes to codes. Even though the codes change every few years there’s usually plenty of time during the code development cycle to see the proposed changes, and then more time to get used to the changes before the new code is adopted.
Something recently caught me by surprise and I feel like I should bring it to light so that anyone who is specifying, supplying, or installing electrified hardware on stairwell doors will be aware of the potential issue. This post might get lengthy, but stick with me, and feel free to pass it along to your colleagues.
In the 2012 edition of the International Building Code (IBC), stairwell reentry is addressed in section 1008.1.9.11 (see below). This section provides several options for locking stair doors on the stair side, with remote release via the fire command center. The requirements for stairwell reentry ensure that a building occupant can leave the stair if it becomes compromised by smoke, and also allows firefighter access from the stair into the building.
Exit discharge doors must provide free egress from the stair side but can be locked on the side opposite the stair side, according to the IBC. An exit discharge door would typically be the door that leads from the stairs to the exterior, an exit passageway, or a lobby. For stair doors other than the exit discharge, the options provided by this section are:
- Option A – stair doors that are openable from both sides – passage sets or fire exit hardware with non-locking lever trim on the stair side
- Option B – for stairs serving 4 stories or less, the doors can be locked on the stair side if they can be released without unlatching by a signal from the fire command center or a location inside the main entrance
- Option C – for buildings where a single exit stair is allowed (not very common), stair doors in some occupancies can be locked on the stair side with no requirement for remote release (new in 2012)
- Option D – doors arranged in accordance with section 403.5.3 (see below), which allows doors to be locked on the stair side if they can be unlocked simultaneously without unlatching via a signal from the fire command center – this section also requires a stairway communication system
Here’s the issue. Option A provides no security. Option B is limited to stairs serving 4 stories or less. Option C is very rare. And Option D refers to a section in the high-rise chapter of the IBC. So what happens when we have a stair serving more than 4 stories, but the building is not a high-rise? For example, a 5-story building that does not have an occupied floor more than 75 feet above the lowest level of fire department vehicle access (this is the IBC definition of a high-rise building), or a building with 3 stories above grade and 2 below.
If you asked me about this a few months ago (and some of you have), I would have recommended that you specify fail-safe electrified locks/fire exit hardware, and that the architect should discuss it with the code official to see if a stairway communication system would be required. But I recently ran into a different interpretation – that the IBC does not allow stair doors to be locked AT ALL if the building falls into this grey area between a 4-story stair and a high-rise, or that the AHJ may require additional measures beyond the stairway communication system.
On one side of the discussion are those who believe that because Option D references the high-rise chapter, it only applies to high-rise buildings, or buildings designed to meet ALL of the criteria for a high-rise. On the other side are those who point out that the reference in section 1008.1.9.11 only points to section 403.5.3, and doesn’t require compliance with the entire high-rise section.
A little history for those of you who are still reading…the 2003 edition of the IBC allowed stairs serving 4 stories or less to have locks on the stair side with no requirement for remote release. It also included the paragraphs that are in the high-rise section, allowing locks which could be unlocked remotely without unlatching. The 2003 IBC Commentary included the suggestion that “It would be reasonable to permit this arrangement in buildings other than high-rise buildings.”
In the 2006 edition of the IBC, the paragraph allowing mechanical locks on stairs serving 4 stories or less was changed to require remote release of those doors. At that point, the difference between the locking requirements for 4-story stairs and high-rise buildings was essentially the requirement for a stairway communication system. For anyone who is wondering what NFPA 101 says about this, The Life Safety Code still allows the use of mechanical locks on stairs serving 4 stories or less, and does not limit the use of electrified locks to high-rise buildings. It also includes parameters for “selected reentry,” which are not included in the IBC.
Of course, an AHJ (Authority Having Jurisdiction) can make the determination that the doors can be locked if remote unlocking (without unlatching) is provided, possibly requiring a stairway communication system or other safety measures. I will be working with the BHMA Codes & Government Affairs Committee to create a proposal for the 2018 IBC to help clarify this, but until then we should be prepared to have this discussion when a project falls into the grey area.
If you have experience or insight to share, I’d love to hear about it.
From the 2012 IBC:
1008.1.9.11 Stairway doors. Interior stairway means of egress doors shall be openable from both sides without the use of a key or special knowledge or effort.
1. Stairway discharge doors shall be openable from the egress side and shall only be locked from the opposite side.
2. This section shall not apply to doors arranged in accordance with Section 403.5.3.
3. In stairways serving not more than four stories, doors are permitted to be locked from the side opposite the egress side, provided they are openable from the egress side and capable of being unlocked simultaneously without unlatching upon a signal from the fire command center, if present, or a signal by emergency personnel from a single location inside the main entrance to the building.
4. Stairway exit doors shall be openable from the egress side and shall only be locked from the opposite side in Group B, F, M and S occupancies
where the only interior access to the tenant space is from a single exit stair where permitted in Section 1021.2.
5. Stairway exit doors shall be openable from the egress side and shall only be locked from the opposite side in Group R-2 occupancies where
the only interior access to the dwelling unit is from a single exit stair where permitted in Section 1021.2.
403.5.3 Stairway door operation. Stairway doors other than the exit discharge doors shall be permitted to be locked from the stairway side. Stairway doors that are locked from the stairway side shall be capable of being unlocked simultaneously without unlatching upon a signal
from the fire command center.
403.5.3.1 Stairway communication system. A telephone or other two-way communications system connected to an approved constantly attended station shall be provided at not less than every fifth floor in each stairway where the doors to the stairway are locked.