I usually consider myself a pretty tenacious person, but I have to admit, after a 12-year struggle with UL 294, I was ready to cry “uncle.” If you have not been following this issue, here are the high points:
- UL 294 is the Standard for Access Control System Units.
- Beginning with the 2009 edition of NFPA 101 and the 2012 edition of the International Building Code (IBC), several code sections pertaining to electrified hardware have required components to be listed to UL 294 (here is a past article about this).
- Not all types of access control systems were/are required by code to have the listing*, but some AHJs asked for proof of the listing on every piece of electrified hardware, regardless of the type of system.
- The codes are not specific about which components require the listing – UL 294 is not applicable to every type of electrified hardware (for example, some products are listed instead to UL 1034) – but again, the lack of prescriptive information in the codes meant that some AHJs have been looking for the UL 294 listing on every single component.
- This became such a time-consuming thing to explain (and some AHJs did not accept our explanation), so some manufacturers began re-listing products to UL 294 that were already (and correctly) listed to another UL standard.
A proposal has been submitted for the 2024 edition of the IBC, to try to clarify which components require the UL 294 listing, and to add the option for a UL 1034 listing instead. The 2024 code development cycle is just getting started, so there’s no way to know whether this proposal will be approved. In the meantime, UL has published an article in their newsletter called Proper Application of UL Standards for Controlled or Delayed Egress Locking Devices – UL 294 & 1034.
This article includes a table with information about the different UL listings that might apply to door hardware, including UL 294, UL 1034, UL 305, UL 634, and UL 10C. A system could have components with a combination of these listings, depending on the types of components included in the system, whether panic hardware is required, and whether the opening is required to be a fire door assembly. This establishes the possibility that an access control system could have components with various listings, since UL 294 does not apply to all types of components.
“An end user or code authority can see various configurations of equipment incorporated into a system and the equipment may have different forms to suit a specific application. A very common scenario is the use of UL 294 certified access control systems units controlling locks certified to UL 1034.
Other prevalent applications include special locking arrangements that have dedicated system component equipment and certified locks connected to control a request to exit (REX) system. For this application, the REX system certification is specific to the system components submitted for investigation.
The various permutations of locking hardware and systems applications (see table) allows for the use of the devices in accordance with model building and life safety codes, with the common element of safety by design.”
* In the 2021 model codes, the UL 294 listing is required for specific types of access control systems – typically those that could restrict egress in some way. The most common application for electrified hardware has a reader that controls access, with hardware that allows free egress at all times – regardless of the status of the access control system. The model codes do not require the UL 294 listing for this type of system. Here are the systems that are required by the current model codes to have components listed to UL 294:
- 2021 IBC:
- 1010.2.11 – Door hardware release of electrically locked egress doors (typically electromagnetic locks released by an RX switch in the hardware mounted on the door)
- 1010.2.12 – Sensor release of electrically locked egress doors (typically electromagnetic locks released by a sensor above the door to detect an approaching occupant)
- 1010.2.13 – Delayed egress locking system (hardware which under normal operation delays egress for 15 seconds, or 30 seconds where approved by the AHJ)
- 1010.2.14 – Controlled egress doors in Groups I-1 and I-2 (doors which deter elopement of patients in health care facilities who require containment for their safety or security)
- 2021 NFPA 101:
- 188.8.131.52.7 – Stair Enclosure Re-Entry – new installations (stairwell doors which lock on the stairwell side but must unlock to allow building occupants to leave a compromised stairwell during a fire)
- 184.108.40.206.1 – Delayed Egress Electrical Locking Systems – new installations (hardware which under normal operation delays egress for 15 seconds, or 30 seconds where approved by the AHJ)
- 220.127.116.11.2 – Sensor Release of Electrical Locking Systems – new installations (typically electromagnetic locks released by a sensor above the door to detect an approaching occupant)
- 18.104.22.168.3 – Door Hardware Release of Electrically Locked Egress Door Assemblies – new installations (typically electromagnetic locks released by an RX switch in the hardware mounted on the door)
- 22.214.171.124.4 – Elevator Lobby Exit Access Door Assemblies Locking (elevator lobby doors with electrified hardware that are locked on the lobby side but can be released to allow egress through a tenant space)