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.