I’m working on my next Decoded column for Door Security + Safety Magazine, and it’s about a really important change to the International Building Code. Although the change affects a relatively small number of doors, I receive questions about this application all the time.
The 2021 IBC will specifically address the acceptable means of locking egress doors that serve exterior spaces – like balconies and roof decks – where the path of egress goes through the interior of the building.
An example of this would be a courtyard, balcony, or roof terrace, where there is a need to prevent access from the exterior space to the building for security purposes, but egress is required through the interior of the building and out to the public way. The Decoded article will describe the application and the code change in more depth, but I wanted to share the proposal, which has been approved as modified by public comment.
The complete change proposal including the reason statement and public comment (E53-18) begins on page 653 of the 2018 Group A Public Comment Agenda. The proposal was originally disapproved by the technical committee, but it was approved as modified when a maximum occupant load was added by public comment (the final action results are here).
To summarize the change, when a means of egress from an exterior space passes through the building, the exit access doors may be equipped with “an approved locking device” if the following criteria are met:
- The calculated occupant load of the exterior space must be no more than 300 people, and the maximum occupant load must be posted on a permanent sign in a conspicuous space near the exit access door if the space is an assembly occupancy.
- A weatherproof telephone or two-way communication system must be located adjacent to at least one exit access door on the exterior side. A change to the International Fire Code (IFC) requires this system to be inspected and tested annually.
- The lock must be key-operated, and readily distinguishable as locked. [One lingering question I have is related to the term “approved locking device.” The definition of approved is: Acceptable to the building official. I’m wondering whether this may be interpreted as requiring AHJ approval for each lock. I don’t think that is the intent of the change, but I will try to find out.]
- A modification to the IBC section on panic hardware clarifies that the double-cylinder deadbolt allowed by this section is an acceptable alternative to panic hardware, provided that all of the requirements are met.
- Each exit access door must have a clear vision panel measuring not less than 5 square feet, which allows visibility of occupants using the exterior area.
- Signage must be posted on the interior side, on or adjacent to each locked required exit access door serving the exterior space, which states: THIS DOOR TO REMAIN UNLOCKED WHEN THE OUTDOOR AREA IS OCCUPIED. Letters must be at least 1 inch high on a contrasting background. [Another lingering question…what if the door is not required for egress capacity, but is provided for egress purposes? (There’s more on that here.)]
Note that this section does not apply to egress courts, which are defined as: A court or yard which provides access to a public way for one or more exits.
Locks are permitted (without meeting the above criteria) for balconies, decks, or exterior spaces serving:
- individual dwelling units or sleeping units
- private office space where the exterior area is 250 square feet or less
Remember, technically this change only applies where the jurisdiction has adopted the 2021 edition of the IBC (once it’s printed!). In other locations, the AHJ would have to be consulted for a code modification, unless the state or local code includes criteria for locking these doors.