This is a long post, but an important one, about a change to NFPA 101, Life Safety Code. I’ve separated it into sections to make it easier for you to read what you need to, and skip what you already know.
Many of you will remember that in 2017, there was talk of making a change to NFPA 101-2018 regarding the allowable number of releasing operations for egress doors in schools. The change would have allowed classroom doors in existing educational occupancies to have hardware that requires two releasing operations, instead of the one operation to unlatch the door that has been required for decades. To recap what occurred:
- This Decoded article and this guest blog post from Joe Hendry (now with the ALICE Training Institute) outline the concerns associated with two releasing operations.
- At NFPA’s annual meeting, the vast majority of voters opted for a single operation to unlatch the door, but appeals were filed by a barricade device manufacturer.
- Stakeholders submitted their positions on the issue during the appeal process, and the appeals were denied by the NFPA Standards Council. The language allowing two releasing operations was not included in the 2018 edition of NFPA 101.
Through the entire process and in the years since, this quote from the NFPA 101 Technical Committee on Means of Egress stuck with me:
“It is the position of the TC on Means of Egress that increasing the number of latch/lock releasing operations is dangerous and could create a hazard to occupants. Technology exists that will meet the current code requirement for not more than one latch/lock releasing operation. The need for multiple operations is contrary to decades of experience resulting in fatalities in schools and other buildings. Single-action egress is an important aspect of life safety for all emergencies.”
Earlier this year, a school district in Maryland submitted a TIA to revise the 2018 edition of NFPA 101. A TIA is a Tentative Interim Amendment – a change that may be proposed as a revision to an existing standard, to address a problem that is of an emergency nature. TIA 1436 proposed the addition of a line of text in the section addressing classroom doors in existing schools: “(3) Two non-simultaneous releasing operations shall be permitted.“
Despite opposition to the change and an appeal from the Builders Hardware Manufacturers Association (BHMA), and testimony from the Massachusetts State Fire Marshal on behalf of the National Association of State Fire Marshals (NASFM), the TIA has been approved. Language allowing two non-simultaneous releasing operations on classroom doors in existing schools will be added to the 2018 edition of NFPA 101.
It might seem like this change was proposed in order to allow classroom barricade devices – that was not the intent. The school district would like the ability to add deadbolts to existing classroom doors, and the substantiation for the proposed TIA specifically states, “The use of dangerous, non-compliant barricade devices will continue to proliferate until the Code offers a reasonable solution such as that offered by this TIA.”
The full proposal and substantiation can be read here, but this paragraph further addresses the proponent’s concerns about classroom barricade devices:
“Lacking the provision for two releasing operations on existing classroom doors, some schools are opting to purchase aftermarket barricade devices or utilize other ‘homemade’ solutions (e.g., sliding sections of fire hose over the door closer arm, rope, wedges, etc.), which restrict entry by a would-be assailant, but also restrict emergency egress and entry by school staff and emergency responders. Barricade devices can also be utilized by an assailant to contain occupants in a classroom and prevent assistance from entering.”
The transcript of the NFPA hearing has been posted here, and the section on the NFPA 101 TIA begins on page 324.
NFPA 101-2018 – Revised
The revised section in Chapter 15 – Existing Educational Occupancies states:
220.127.116.11.4* 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:
(1) The locking means shall be capable of being engaged without opening the door.
(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.
(3) Two non-simultaneous releasing operations shall be permitted.
(4) The releasing mechanisms 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.
(5) 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.
(6) The door shall be capable of being unlocked and opened from outside the room with the necessary key or other credential.
(7) The locking means shall not modify the door closer, panic hardware, or fire exit hardware.
(8) Modifications to fire door assemblies, including door hardware, shall be in accordance with NFPA 80.
(9) 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.
(10) 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.
ALL requirements must be met: Locking devices used on classroom doors must meet ALL of the requirements of this section. For example:
- The releasing hardware must be mounted between 34 and 48 inches above the floor. Security devices which mount at the bottom of the door or wrap the closer arm would not typically have their releasing hardware within the allowable range, and would not be compliant with this section.
- The door must be able to be unlocked from the outside with a key or other credential – like an access control card, code, or fob. Devices which barricade the door from the inside and can not be removed by an authorized person from the outside are not compliant.
- If the classroom door is a fire door assembly, all hardware must be listed to UL 10C and preparations for retrofit security devices must be acceptable per NFPA 80. Job-site preparations for hardware on fire door assemblies is typically limited to 1-inch-diameter holes unless the preparation is allowed by the listings of the door, frame, and hardware manufacturers, or approval for a field modification is obtained in advance from the listing laboratory.
- The two operations to unlatch the door must not be required to be performed simultaneously. Two self-latching devices with latchbolts that must be retracted at the same time would not comply.
Applies to NFPA 101 only: The International Building Code (IBC) and International Fire Code (IFC) limit releasing operations for egress doors to one operation to unlatch the door (all latches simultaneously). The extra releasing operation allowed by the TIA would only apply to jurisdictions that have adopted NFPA 101-2018 – and only to existing buildings. Classroom doors in new buildings are limited to one operation to unlatch the door by Chapter 14 of NFPA 101.
Chapter 15 addresses existing K-12 schools: NFPA 101 includes other chapters which address existing day care facilities and college classrooms, so technically this change can be applied only to existing K-12 schools. The change was not made to the other chapters.
Accessibility requirements: The ADA Standards for Accessible Design require door hardware to be operable without tight grasping, pinching, or twisting of the wrist, so security devices on classroom doors must be operable in this manner.
Do not install with panic hardware: In my interpretation, doors required to be equipped with panic hardware are not allowed to have any additional locking devices, per this section of NFPA 101:
18.104.22.168.12* Devices shall not be installed in connection with any door assembly on which panic hardware or fire exit hardware is required where such devices prevent or are intended to prevent the free use of the leaf for purposes of egress, unless otherwise provided in 22.214.171.124.
One More Thing
I highly recommend reading the transcript of the NFPA hearing that took place on August 6th, 2019, particularly the testimony from Peter Ostroskey, the Massachusetts State Fire Marshal (representing NASFM), who is also a member of the NFPA 3000 technical committee. The transcript is here and the discussion for TIA 1436 begins on page 324. Here is a portion of this testimony:
There are many concerns associated with the use of retrofit security products, as outlined in the Decoded article – Classroom Security Considerations. School districts should carefully consider their options, as they may already have sufficient security or may be able to upgrade existing locksets using code-compliant conversion kits.