A couple of weeks ago I posted a terrific news report that addressed the use of barricade devices in Tennessee schools – the fire marshal had enforced the codes and the devices were removed.
Unfortunately, the fire marshal has faced strong opposition from the sheriff in Perry County, who had raised money to buy barricade devices without realizing that they were not compliant with the adopted codes. This is not the first time this has happened…once the money has been collected it becomes even more important to override the safety requirements and buy the devices that the community has paid for.
Now the news reports are basically saying that the state fire marshal has changed the codes in Tennessee, and barricade devices are allowed. But I’m confused. The codes in Tennessee DID change – on June 1st, the state filed an emergency rule filing form, adopting the classroom locking section of NFPA 101-2018. But this code does not say “anything goes” – it includes specific requirements for classroom locking. Here’s the section from the chapter on existing educational occupancies:
126.96.36.199.4 Classroom Door Locking to Prevent Unwanted Entry. Classroom doors shall be permitted to be locked to prevent unwanted entry provided that the locking means is approved and all of the following conditions are met: [Note: “Approved” means acceptable to the authority having jurisdiction.]
(1) The locking means shall be capable of being engaged without opening the door. [Note: The Tennessee form says that the state is not adopting this particular requirement.]
(2) The unlocking and unlatching from the classroom side of the door can be accomplished without the use of a key, tool, or special knowledge or effort. [Note: “Special knowledge or effort” can vary widely, depending on the AHJ’s interpretation.]
(3) The releasing mechanism for unlocking and unlatching shall be located at a height not less than 34 in. (865 mm) and not exceeding 48 in. (1220 mm) above the finished floor. [Note: If the mounting height requirement is enforced (as it is also required by the ADA – a federal law), devices which must be released by reaching to the top or bottom of the door would not be compliant.]
(4) Locks, if remotely engaged, shall be unlockable from the classroom side of the door without the use of a key, tool, or special knowledge or effort. [Note: This typically applies to electrified hardware.]
(5) The door shall be capable of being unlocked and opened from outside the room with the necessary key or other credential. [Note: Many classroom barricade devices can not be unlocked from the outside with a key or credential.]
(6) The locking means shall not modify the door closer, panic hardware, or fire exit hardware. [Note: Barricade devices which attach to existing closers and panic hardware are not compliant with this requirement and could also void the warranty and listings of any existing door hardware.]
(7) Modifications to fire door assemblies, including door hardware, shall be in accordance with NFPA 80. [Note: NFPA 80 and the model codes require products used as part of a fire door assembly to be listed to UL 10C/NFPA 252. I don’t know of any barricade devices that have been tested and listed to these standards. Do you?]
(8) The emergency action plan, required by 15.7.1, shall address the use of the locking and unlocking means from within and outside the room. [Note: NFPA 3000 includes additional requirements and recommendations for emergency action plans, including a requirement for doors to meet the egress requirements of NFPA 101. In addition to the requirements listed here, NFPA 101 also limits doors to one releasing operation to retract the latch or latches. This is one operation to release all latches simultaneously (existing hardware + retrofit security device) – not one operation for each latch.]
(9) Staff shall be drilled in the engagement and release of the locking means, from within and outside the room, as part of the emergency egress drills required by 15.7.2. [Note: There are additional considerations for classroom security, which are addressed in this article.]
Image and Video: Fox 17 News