I recently ran into a situation in the field, where there was a lot of confusion about which code section applied to a particular type of electrified hardware.  I’m guessing that some of you have had this problem as well, so I’m hoping this article helps to sort that out.  By starting with Type 1 and asking these questions, it should be easy to rule out which code sections don’t apply, and find the one that does.  This post was published in  Door Security + Safety
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If an access control reader is used to control access, but the door hardware allows free egress, the application is not subject to the code requirements for special locking arrangements.

For those of us who work in the door and hardware industry, electrified hardware has become part of our daily life.  We throw around terms like fail safe / fail secure, delayed egress / controlled egress, and electromechanical lock / electromagnetic lock, without thinking twice about what they mean – we just know.  The same can be said of mechanical hardware…when we discuss lock functions, types of panic hardware, or closer mountings, it often sounds like another language to those outside of the industry.

With that said, there are MANY people who don’t work with electrified hardware every day but who need to understand it on some level.  Architects, end users, and code officials must know how each door in an access control system will function, and which section of the model codes applies to that application.  A lack of understanding can lead to inconsistent interpretations, project delays, and unnecessary changes in the field.

Special Locking Arrangements are electrified locking systems that affect egress, such as delayed egress or controlled egress locks.  Although there are quite a few code sections that apply to these applications, the majority of doors with access control readers are not considered special locking arrangements, because the hardware allows free and immediate egress – independent of the access control system.  These systems are considered “normal locking arrangements” and are subject to the same egress requirements as doors with standard mechanical hardware.

The model codes that we most often refer to for information related to access control systems are the International Building Code (IBC), International Fire Code (IFC), and NFPA 101 – Life Safety Code.  The requirements of the i-Codes and the NFPA codes are similar, although they are not exactly the same.  There may also be state-specific code modifications that apply to these systems.  Detailed information about the requirements can be found by referring directly to the codes, and the following questions will help to determine which model code section applies to each application.

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Type 1) Does the electrified hardware delay egress for 15 seconds (or 30 seconds) to deter unauthorized use of the door? 

If yes, this is a delayed egress locking system.  Under normal operation, this hardware delays egress for 15 seconds, or 30 seconds where approved by the Authority Having Jurisdiction (AHJ).  This hardware is most commonly used to deter unauthorized use of an exit, helping to prevent theft or elopement.  The 15-second timer is actuated by an attempt to exit, when a force of not more than 15 pounds is applied for up to 3 seconds.  Immediate egress is required (no delay) upon activation of the fire alarm or sprinkler system, and upon power failure.

For detailed requirements on hardware that delays egress for 15 seconds (or 30 seconds where approved by the AHJ), refer to IBC/IFC-2018: 1010.1.9.8 – Delayed Egress / NFPA 101-2018: 7.2.1.6.1 – Delayed Egress Electrical Locking Systems.

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Type 2) Is the electrified hardware used to control egress indefinitely in a memory care facility or other health care unit where patients require containment for their security or safety? 

This application is called a controlled egress lock, which is only allowed in health care units where the clinical needs of patients require their containment to prevent them from leaving the facility unaccompanied; it is not allowed by the model codes in other types of occupancies.  In health care units where controlled egress locks are installed, all clinical staff must carry the keys, codes, or other credentials required to operate the locks, and the unlocking procedures must be part of the facility’s emergency plan.  The model codes include automatic release requirements that apply to some occupancy types.

For detailed requirements on electrified hardware that prevents egress from a health care facility until evacuation is needed, refer to IBC/IFC-2018: 1010.1.9.7 Controlled Egress Doors in Groups I-1 and I-2 / NFPA 101-2018: 18/19.2.2.2.5 (New and Existing Health Care), also refer to 20/21.1.3.6 (New and Existing Ambulatory Health Care).

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Type 3) Is the lock an electromagnetic lock released by a sensor above the door? 

Unlike most electrified locksets, electromagnetic locks will not allow egress when powered unless the proper release devices are installed. For this reason, they are considered a special locking arrangement.

There are two code sections that apply to electromagnetic locks, depending on the type of release devices installed (see also Type 4).  An electromagnetic lock consists of an electromagnet in a housing mounted on the door frame, and a steel armature mounted on the door.  When power is applied, the magnet bonds to the armature and locks the door.  Without the release devices mandated by the model codes, these locks would not allow egress when they are powered, so it’s crucial to understand what is required by each of the two applicable code sections.

One method of releasing a mag-lock is with a sensor above the door on the egress side that detects an approaching occupant and unlocks the lock.  In past editions of the model codes, the section addressing this application was called Access Controlled Egress Doors, leading some to believe that this section was applicable to every door equipped with an access control reader.  That was not the intent of the codes, so the section titles were changed to indicate that the sections apply only to locks released by a sensor – not to every door with access control.  Note that some sensors mounted above the door are used by the security system to signal that someone has exited and may have nothing to do with the locking or unlocking of the door (this code section does not apply to those sensors).

For detailed requirements on electromagnetic locks released by a sensor, refer to IBC/IFC-2018: 1010.1.9.9 Sensor Release of Electrically Locked Egress Doors / NFPA 101-2018: 7.2.1.6.2 – Sensor-Release of Electrical Locking Systems.

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Type 4) Is the lock an electromagnetic lock released by a switch in the door-mounted hardware? 

Another method for releasing an electromagnetic lock is via a switch in the door-mounted hardware.  Instead of a sensor above the door, these systems use an electronic switch in the lever handle, panic hardware, or electronic touch-sensor bar to release the mag-lock for egress.  This switch is often called a request-to-exit switch or RX/REX switch.  This section would not apply to a door with an access control reader where the mechanical lockset or panic hardware allows free egress.  It is only applicable to systems where a switch in the door-mounted hardware releases an electrified lock – typically a mag-lock.

For detailed requirements on electromagnetic locks released by a switch in the door-mounted hardware, refer to IBC/IFC-2018: 1010.1.9.10 – Door Hardware Release of Electrically Locked Egress Doors / NFPA 101-2018: 7.2.1.5.6 – Door Hardware Release of Electrically Locked Egress Door Assemblies.

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Type 5) Does the door serve an elevator lobby that does not have direct access to an exit stairwell?

The Life Safety Code permits electrified locking of elevator lobby doors if all of the criteria stated in the code are met. The lock must unlock automatically upon actuation of the sprinkler system or fire alarm system (except when the system is initiated by a manual fire alarm box) and upon loss of power to the lock. A two-way communication system must be installed in the elevator lobby to allow a building occupant to call for help.  The IBC and IFC require elevator lobbies to have at least one door that leads to an exit.  These codes do not currently include sections which would allow elevator lobby egress doors to be locked, although some states and cities have modified the I-Codes to allow an application similar to what is described in NFPA 101.

For detailed requirements on egress doors serving elevator lobbies, refer to IBC-2018: 3006.4 – Means of Egress / NFPA 101-2018: 7.2.1.6.3 – Elevator Lobby Exit Access Door Assemblies Locking.

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Type 6) Is the door an interior fire door assembly leading to a stairwell, where the lever handle on the stair side of the door is typically locked? 

In buildings where stairwell doors are locked (or lockable) on the stair side, the stairwell reentry requirements address the means of allowing reentry back into the building if the stairwell becomes compromised during a fire.  This ensures that building occupants can leave the stairwell and find another exit, or shelter in place and wait for rescue.  The unlocked stair doors also allow firefighters to access each floor.  NFPA 101 and the I-Codes differ in how stairwell reentry is addressed.  While the Life Safety Code allows some stairwell doors to be mechanically locked on the stair side with other doors allowing reentry, the IBC and IFC require all interior stairwell doors to be capable of remote unlocking from a switch at the fire command center or other approved location.

Note that some stairwell doors may have hardware providing reentry on the stair side, in combination with another type of electrified hardware, such as delayed egress or controlled egress, on the egress side.  These doors must meet the requirements of all applicable sections.

For detailed requirements on the reentry requirements for locks on the stair side of stairwell doors, refer to IBC/IFC-2018: 1010.1.9.12 – Stairway Doors and 403.5.3 – Stairway Door Operation / NFPA 101-2018: 7.2.1.5.8.

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Type 7) Is there an access control reader on the outside, that controls access while the door hardware provides free egress at all times?

If yes, it’s likely that the doors in question are not considered one of the “special locking arrangements.”  The most common type of access control system includes a reader that controls access only – and does not impede egress in any way.  The lever handle or panic hardware on the egress side allows egress the same way a door with standard mechanical hardware would.

Currently, there is not a separate section in the model codes that is specific to access control systems which control access but do not affect egress.  Because these systems are not considered special locking arrangements, they must comply with the code requirements for “normal locking arrangements” – the same sections that would apply to doors with mechanical hardware.

These doors must be operable for egress with no key, tool, special knowledge or effort, and with no tight grasping, pinching, or twisting of the wrist.  Operable hardware must be mounted between 34 and 48 inches above the floor, and one releasing operation must unlatch the door (with a few exceptions).  Hardware for these systems is not required by the model codes to be listed to UL 294 – Standard for Access Control System Units.

The IBC/IFC Commentaries and the NFPA 101 Handbook include information which clarifies that the sections on special locking arrangements do not apply to electrified hardware that allows free egress at all times – independent of the access control system.

For detailed requirements on egress through doors with “normal locking arrangements”, refer to IBC/IFC-2018: 1010.1.9 – Door Operations / NFPA 101-2018: 7.2.1 – Door Openings.

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Conclusion

When considering which code requirements must be followed, first identify which category the hardware falls into, and then refer to the applicable code section(s).  This summary is not intended to provide complete information about the types of electrified hardware referenced.  More information can be found in the code sections listed with each application.  Keep in mind that state or local requirements may differ from those of the IBC/IFC or NFPA 101, so it’s important to be aware of the codes in your project’s jurisdiction. Refer to the adopted codes for the detailed code requirements, and contact the Authority Having Jurisdiction if you need assistance.

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