I’ve written about UL 294 – Standard for Access Control System Units several times in the past, but the questions keep coming.  Here’s today’s question:

Is the UL 294 listing required by the model codes for panic hardware with the electric latch retraction / electric dogging feature (EL/QEL)?

The short answer: No (or almost never)

You all know it’s unusual for me to give a yes/no answer, so here’s the rest of the story…

UL 294 is a listing that is required by code for SOME TYPES of access control systems (not all types).  Currently, the International Building Code (IBC) requires the listing for access control systems with electromagnetic locks (sensor release or door hardware release), delayed egress locks, and controlled egress locks in health care facilities.  NFPA 101 – Life Safety Code requires the listing for those systems, as well as access control systems for elevator lobby egress doors.

The UL 294 listing is not required by the model codes for access control systems where the reader controls access but the hardware allows free egress – just like mechanical hardware would.  For example, if a door has an electric strike with a storeroom function lockset, the lever handle allows free egress.  If a stair door has fire exit hardware with electrified trim that allows stairwell reentry during a fire, the panic hardware touchpad on the egress side allows free egress at all times.  These examples are not required by the model codes to have the UL 294 listing.

Some electrified hardware is DEFINITELY required by the current model codes to have the UL 294 listing because it is ALWAYS used in the systems that require the listing.  These products include electromagnetic locks, delayed egress locks, and controlled egress locks, as well as any other components used in those systems – like the power supplies and credential readers.

Some electrified hardware MIGHT be used in the systems that require the listing – like a controlled egress system or an elevator lobby system.  If a particular piece of hardware will be used in one of these systems, it will need the UL 294 listing; if the hardware is being used in a different type of system, the listing is not required.  Products that might be used in one of these systems include electromechanical locks, electrified lever trim for panic hardware, and electric strikes.

Electric latch retraction hardware is typically used either for controlled access/free egress, or to release the latch on an automatic door.  It would not typically be used in any of the systems that are required by the model codes to have the UL 294 listing.*  With that said, some AHJs believe that the model codes require the UL 294 listing on every piece of hardware with a wire, so there may come a day when electric latch retraction panic hardware has the listing just to avoid problems in the field.

* The only type of system I can think of where the EL/QEL might need the UL 294 listing is when there is a fire door with an automatic operator, that also needs delayed egress or controlled egress.  For example, a cross-corridor fire door in a hospital would often have an automatic operator with electric latch retraction fire exit hardware to allow the auto operator to open the door.  If the door also has a delayed egress or controlled egress system, the components of that system would need the UL 294 listing.  Although the electric latch retraction would not really be part of the delayed egress or controlled egress system, I could see where it might be considered all one system since it’s all on the same door.

Can you think of an application where the model codes would require electric latch retraction panic hardware to have the UL 294 listing?

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