Sometimes a code change is proposed, and it seems like a very simple change that couldn’t possibly be misinterpreted. What could be the harm in removing one little word? [Stick with me and keep reading.]
You may be familiar with the code requirements for key-operated locks (if not, there’s an article here). In a nutshell, this section allows a double-cylinder deadbolt on the main entrance of a building, if certain criteria are met. There are restrictions on the occupancy type, and the lock must be of a type that is “readily distinguishable as locked” (for example, the lock has an indicator). The door must also have signage stating that the door is to be left unlocked while the building is occupied.
In the 2015 edition of the International Building Code (IBC), the word “exterior” was removed from this section, and a slight change was made to the text of the signage. The image below is from the redline version of the IBC, which shows all of the changes from one version to the next and is very helpful when learning about a new edition. This is from Section 1010.1.9.3:
The purpose of this change was to allow double-cylinder deadbolts on retail stores in malls that are not exterior doors. While I do generally agree with the use of this application for retail stores in a mall, these changes have created a big opportunity for misinterpretation of the IBC.
I have been asked several times lately whether it is acceptable to install a double-cylinder deadbolt in various locations. For example, someone wanted to use a double-cylinder deadbolt to secure the door leading to a multi-stall restroom in an office building. No way – right?? Someone could get locked inside with no way to exit!
When I say “no” I like to have a code section to wave around in support of my answer (so I don’t look like the bad guy). Well, look at the new section above and tell me where it says that a double-cylinder deadbolt can’t be used on a multi-stall restroom in a business occupancy. The ONLY thing I can point to is that this application is limited to the “main door or doors” – which previously was interpreted to mean the main entrance to the building. In recent discussions, the argument has been that the restroom door is the main door to the restroom. The change to the signage sort of supports that argument by referring to “this space” rather than “this building.”
It is not the intent of the IBC to allow just any door that is the main entrance of a space, a room, or an area to be locked with a double-cylinder deadbolt. The intent is for this section to apply to the main entrance to the building, and this can be stretched to retail entrances in a mall now that the word “exterior” is gone. The premise is that the building or mall store would not be able to be open and functioning with the door locked. If we start allowing any old room or space to be locked with a double-cylinder deadbolt, it will severely impact the life safety requirements that we have worked so hard to uphold for decades.