Printed from the blog of Lori Greene, AHC/CDC, CCPR, FDAI
Allegion
Email: lori_greene@allegion.com, Blog: www.idighardware.com or www.ihatehardware.com


Sep 20 2018

Locks Used Only for Security Purposes

Category: Accessibility,Locks & KeysLori @ 12:36 am Comments (2)
Share

This thumbturn-operated flush bolt on a retail store could be considered a lock used only for security purposes (IBC), but is it operated only by security personnel (ADA)?

According to the model codes and standards, most operable hardware, such as lever handles, thumbturns, keypads, and access control readers must be mounted between 34 inches and 48 inches above the floor.  This allows the release devices to be operated by the majority of people – adults, children, and people using wheelchairs.  State requirements may be more restrictive; for example, the California Building Code requires operable hardware to be mounted between 34 inches and 44 inches above the floor.

In the International Building Code (IBC) and the accessibility standards, there are exceptions to the required mounting height, but the exceptions vary.  For example, the IBC states:

1010.1.9.2 Hardware height. Door handles, pulls, latches, locks and other operating devices shall be installed 34 inches (864 mm) minimum and 48 inches (1219 mm) maximum above the finished floor. Locks used only for security purposes and not used for normal operation are permitted at any height.*

An example of a lock “used only for security purposes and not used for normal operation” would be a deadbolt mounted in the bottom rail of a glass door serving a retail store.  This lock would be unlocked when the store is open, and is not used by customers for access or egress.  Keep in mind, however, that a lock mounted in the bottom rail may conflict with the accessibility requirement for a flush, smooth surface with no protrusions in the bottom 10 inches of the door (push side of manual doors).

The 2010 ADA Standards and the 2017 edition of ICC A117.1 – Accessible and Usable Buildings and Facilities, also exempt some operable hardware on similar grounds.**  However, these standards exempt hardware on doors designed to be operated only by security personnel, not hardware used only for security purposes.  So who qualifies as security personnel?  In the ADA standards and the ICC A117.1 Commentary, all of the references to security personnel are related to detention and correctional facilities, courthouses, and guards at security gates.  The ADA Guide says this:

Manual doors, doorways, and gates that are designed to be operated only by security personnel, such as guards in a jail or prison, are exempt from requirements for hardware, closing speed, and opening force, but must meet all other requirements, including those for maneuvering clearance. This exception applies only where security personnel have sole control of doors or gates. If automated, such doors or gates are required to comply only with provisions for clear width and thresholds, as well as applicable provisions of the referenced ANSI/BHMA Standards.

The ICC A117.1 Commentary clarifies:

Examples of security personnel are guards in jails, bailiffs in courthouses and guards at security gates.  The intent is not to exempt all the doors that security personnel use, but to exempt specific features of doors that security personnel are responsible for opening, closing and/or locking for security reasons.  Examples would be the door at the cells and between the courtroom and cells in a courthouse. Security personnel should have sole control of the doors. It is not acceptable for security personnel to operate the doors for people with disabilities and allow others independent access.

NFPA 101 – The Life Safety Code requires the releasing mechanism for any latch to be located between 34 inches and 48 inches above the floor, with some exceptions for existing hardware.  NFPA 101 does not include an exception to the mounting height for locks used only for security purposes or operated only by security personnel.

The Bottom Line

  • The IBC exempts locks used only for security purposes from the mounting height requirements.
  • The accessibility standards exempt locks operated by security personnel, which applies to very limited locations.  Because this requirement is more stringent than that of the IBC, it’s possible that AHJs may not allow the IBC exemption and instead apply the more limited exemption from the accessibility standards.
  • NFPA 101 includes some exceptions for existing hardware, but otherwise requires hardware to be mounted between 34 inches and 48 inches above the floor.
  • State requirements may vary from those of the model codes and standards.  The more restrictive height requirements in California have resulted in some problems – particularly with access control products.

*Refer to this code section for an additional exemption addressing hardware on pool gates.

**The ADA standards also exempt some existing hardware from the mounting height requirements.

Related Posts

You need to login or register to bookmark/favorite this content.

Recent Posts

2 Responses to “Locks Used Only for Security Purposes”

  1. Don Funsch says:

    in California the bottom 34 inches has to be smoothed with no protrusions from the face of the doors

    • Lori says:

      Hi Don –

      I looked at the CBC – Section 11B-404.2.10 has the requirement for a flush, smooth surface 10 inches up from the floor. Section 11B-404.2.3 is where it talks about projections in the bottom 34 inches of the door height, and it says: “There shall be no projections into the required clear opening width lower than 34 inches above the finish floor or ground.” This section limits the projections into the REQUIRED clear opening width, which is typically 32 inches. It doesn’t prohibit hardware from projecting off the face of the door, as long as it doesn’t project into the 32-inch clear width. For example, if you have a 4-foot-wide door that provides 45″-46″ of clear width, it could have hardware projecting off of the push-side door face because it would not project into the required 32 inches of clear width. At least that’s how I understand the requirements.

      – Lori

Leave a Reply



This website or its third party tools use cookies, which are necessary to its functioning and required to achieve the purposes illustrated in the cookie policy. If you want to know more or withdraw your consent to all or some of the cookies, please refer to the cookie policy. By closing this banner, scrolling this page, clicking a link or continuing to browse otherwise, you agree to the use of cookies.

This website or its third party tools use cookies, which are necessary to its functioning and required to achieve the purposes illustrated in the cookie policy. If you want to know more or withdraw your consent to all or some of the cookies, please refer to the cookie policy. By closing this banner, scrolling this page, clicking a link or continuing to browse otherwise, you agree to the use of cookies.