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. 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.

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