Anyone remember who the tiny person in red is? 🙂
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.
There’s more:
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.
What do you think about this change? Does it cover all the bases? Any thoughts on my lingering questions?
You need to login or register to bookmark/favorite this content.
I guess door swing and exit signage still applies?
On exit sign, is there a situation where you might have a patio, but an exit sign is not required?? So should the code require one, if this section is used???
Or, if a patio has multiple doors, does this section apply to them all?
Signage on the communication device? So someone knows what it is and why there?
“”The lock must be key-operated, and readily distinguishable as locked””” inside or out, or both?
at least it is a start to address a recurring problem.
Hi Charles –
Yes, I would say door swing and signage would still apply. On the exit sign, if the code requires one, I don’t see anything that would permit it to be omitted. Regarding the multiple doors, I would take the cautious approach and use the double-cylinder deadbolt and signage on all of the doors, and the two-way communication system at the most obvious door.
The communication system has to meet the requirements of 1009.8.1 and 1009.8.2. Good point, and I will go into more depth on this in the Decoded article. 1009.8.1 addresses where the system has to be able to call, and 1009.8.2 addresses the posted instructions.
It doesn’t say whether the lock has to be readily distinguishable as locked on both sides. Normally with key-operated locks on the main entrance, the indicator is on the egress side, which in this case would be on the exterior. What do you think? Should the indicator be on both sides?
I think it’s a pretty good start.
– Lori
– Lori
If the space has an occupancy of 200 would it still have a panic and then a double cylinder deadbolt?
Hi Mike –
The way I interpret the code, the doors would not have panic hardware, only double-cylinder deadbolts.
– Lori
“The calculated occupant load of the exterior space must be no more than 300 people”
Let’s take a completely random scenario, say a casino wants to build a parking garage and have a new restaurant on top with an open deck for dining and events. You know… a random scenario. 🙂
Would this outdoor area be fixed in size? If they use it for dining only, with tables and chairs, we’d be 15 net, so 4,500 square feet maximum. But if they use it for events, standing space, we’d be 5 net, so 1,500 max.
Am I reading this right? Perhaps they could do double duty by having 4,500 sqft and a maximum occupancy of 300 people during events, but we know how that would go.
Hi Rick –
I’m not sure how an AHJ would handle this, if the occupant load for the normal use of the space is less than 300 people but there’s a potential for more occupants if the space is used another way. I think your double-duty solution would probably be how they would calculate it…if the occupant load was limited to 300 people and an event had more than that, it would increase the liability for the building owner so maybe they would think twice.
– Lori
I think the indicator should be on the inside with signage. The person on the outside will know the door is locked, and the obligation to keep the door unlocked when the space is occupied belongs to the responsible part(ies) inside the building.
Not a fan. This leaves too much of the responsibility to the owners or occupants of the building for life safety. I do not like the panic hardware exception that is in the 2015 that we use now. If 300 people are running toward the door and the front ones see the locked sign, everybody behind him will continue to push forward in a panic. This is all happening while that person(s) in the front say “Wait everyone I have to make a phone call before the doors will open.
I am a building official and I prefer to build in the fire safety requirements. Fire alarm and power failure can release doors. Also doors can open any time but door alarm will be set off.
I’ve done a few school courtyards before. School courtyards typically have several points of access where ensuring all are unlocked can be difficult, at best.
The best way I’ve handled this in the past is to provide exit devices on the exterior side of the opening then secure the doors locked with mag locks. Tie all the mag locks together with a key operated switch with green (unlocked LED) and red (locked LED) at each opening.
A few safeguards that were in place were 1) interior and exterior signage, 2) exit signage, and 3) FA pull stations were also placed in the courtyard at each door re-entering the school. Since the mag locks would deactivate upon activation of the fire alarm, this satisfied the AHJs concerned of persons “trapped” in the courtyard. It also satisfied the school system concerns of security since the fire department would be there in minutes.