I’ve been thinking about this code change for a while now, trying to understand the intent of the proposal.  I’m wondering if any of you have any insight on this new language.

Here’s a little background.  In the 2009 editions of the International Building Code (IBC), International Fire Code (IFC), and NFPA 101 – Life Safety Code, changes were made that allowed what is now commonly called “controlled egress” in certain types of units in health care facilities.  These areas are typically locations where the clinical needs of patients require containment for their safety or security – often memory care units and infant nurseries.

Since the 2009 editions of the model codes, controlled egress locks in the path of egress from these health care units have been required to be fail safe electrified locks, which unlock when power is cut.  Under normal operation, these doors do not have to allow free egress, but the codes mandate multiple means of releasing the locks when evacuation is needed.  There is more information about electrified controlled egress locks in this article and in this video.

The change that has been approved for the 2021 IBC has been inserted into the Locks and Latches section.  It references doors serving patients described the same way as the sections on electrified controlled egress – “where the clinical needs of persons receiving care require containment or where persons receiving care pose a security threat.”  However, the new section does not require electrified locks, does not mandate any of the automatic release functions, and only requires clinical staff to carry the keys, codes, or other means needed to operate the locks at all times.

Here is the new paragraph – Item 2 in the Locks and Latches section:

IBC-2021:  Locks and latches. Locks and latches shall be permitted to prevent operation of doors where any of the following exist:

1.Places of detention or restraint.

2. In Group I-1 Condition 2 and Group I-2 occupancies where the clinical needs of persons receiving care require containment or where persons receiving care pose a security threat, provided that all clinical staff can readily unlock doors at all times, and all such locks are keyed to keys carried by all clinical staff at all times or all clinical staff have the codes or other means necessary to operate the locks at all times.

[Additional sections follow – refer to the code.]

This change (E52-18) was a joint effort between ICC and the American Society for Healthcare Engineering (ASHE), a subsidiary of the American Hospital Association.  When a code change is submitted, there is a reason statement that accompanies the proposal to explain why the change is needed.  In many cases, the reason statement helps to explain the intent of the new language, but I still have questions.  Here’s the reason statement from the proposal:

This manual locking provision recognizes what is currently permitted under the Federal Standards and Centers for Medicaid and Medicare Services enforcement rules where the restraint of patients is allowed for the safety of the patient and/or the public (K222). This may be needed as part of the progression of treatment for patients. 

CMS ID K222 referenced in the reason statement can be found here.

It seems like the intent of this change is to allow mechanical locking of doors in health care facilities, without specifically calling out where these locks may be used.  I’m guessing that it is intended to apply to behavioral health facilities, but that’s not clear from the new language.  I am going to try to learn more about this change and will post an update when I do, but if you have any thoughts on this section or experience with the similar section in NFPA 101, please share in the comments.

Where is this mechanical locking typically allowed?

Who decides when mechanical locks preventing egress are acceptable?


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