This post will be 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 126.96.36.199.3), 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 188.8.131.52.6 – 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 184.108.40.206.6 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.
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.