This is a door in a school, and it’s a fire door assembly. The existing fire exit hardware can not be locked down from inside of the room, so the two hooks were added on the frame and the retainers on the door.
Thanks to a serendipitous meeting between a door hardware consultant / fire door inspector, and the facility manager for the school district, the doors in this school are currently being made code-compliant again. The consultant donated 40 hours of his time to make this school right (kudos to you!).
It scares me to think about trying to release these latches for egress with even a minimal amount of sideload pressure on the door. Someone would also have to know how to release the latches, and that three operations must be performed – in the correct order.
There has been a lot of talk about accessibility with regard to classroom barricade devices, and the laws in several states that have been created to allow the devices, despite the requirements of the adopted codes. The extra latches on this classroom door would require tight grasping, pinching, and possibly twisting of the wrist to operate. They also look like they are mounted outside of the allowable mounting height range (this school is in California so the range is 34-44 inches above the floor). Because these latches are permanently mounted on the door, they are considered operable parts, and would not be compliant with the ADA Standards for Accessible Design or with ICC A117.1 Accessible and Usable Buildings and Facilities.
But what if the school had purchased a barricade device that is not permanently mounted on the door? Proponents of barricade devices say that these temporary devices are compliant with the ADA. While it’s true that if a device is not mounted on the door, it’s not considered an operable part, that doesn’t mean that it meets the intent of the ADA. If a person with a disability is unable to operate the device, that seems like a problem to me – whether the device is permanently or temporarily mounted on the door.
There are plenty of code-compliant locks and panic hardware that will provide the necessary level of security – far beyond what the retrofit latches on this door will withstand. The problem is, once a school district realizes that they have invested in retrofit security that is not code-compliant, the district may ask their state legislators to sponsor a bill that legalizes the devices they have purchased.
Rather than figuring out how to use the legislative process to circumvent the adopted codes, why aren’t state legislators considering the reasons behind the code requirements that are created to keep building occupants safe? These codes are based on 100+ years of experience, and represent the consensus of hundreds of stakeholders. Just because a law CAN override these regulations, doesn’t mean that it SHOULD.
We are currently working with code officials in several states to help legislators and others understand the potential unintended consequences of retrofit security devices. If you see a bill in your state legislature related to barricade devices, please get me involved.