By now, I think most of you can recite by heart the locations where panic hardware is required by code (if not, here’s a Decoded article and a video).  One of the locations where panic hardware is required by the IBC is on doors equipped with a lock or latch, serving an assembly occupancy with an occupant load of 50 people or more.

A change to the 2021 edition of the IBC addresses how to secure egress doors serving an exterior space like a roof terrace or enclosed courtyard, where the path of egress leads through the interior of the building.  Prior editions of the code would not allow these doors to be locked, which created a conflict between egress and security.  The 2021 change allows the doors to be secured on the exterior/egress side if certain criteria are met, and I wrote about this code change in this Decoded article.

The application described in the 2021 IBC allows a key-operated locking device, like a double-cylinder deadbolt, to be used to lock an exterior egress door leading into the building, and this locking method may be used on exterior spaces with an occupant load of 300 people or less – including assembly occupancies.  So the question is this:

Does the 2021 IBC section addressing the locking of exterior spaces allow panic hardware to be omitted on doors serving exterior assembly spaces with an occupant load of 50 people or more?

The Quick Answer – as I understand it, the intent of this code change is that the key-operated lock would be installed as an alternative to the panic hardware (keep in mind – the AHJ always has the final say).  If the roof terrace or enclosed courtyard is an assembly space, and the doors leading into the building are secured on the exterior/egress side using a method that meets the 2021 IBC, the key-operated lock is installed instead of panic hardware.

In Section 1010.2.9 – Panic and fire exit hardware, the 2021 IBC includes an exception stating: Exit access doors serving occupied exterior areas shall be permitted to be locked in accordance with Section 1010.2.4, Item 8.  This is a reference to the section addressing exterior spaces, and it is an exception to the requirement for panic hardware on these doors.  For this paragraph, the 2021 IBC Commentary states: Exception 3 applies to outdoor areas where occupants must egress from an exterior space through the building for means of egress. Section 1010.2.4, Item 8 has specific allowances and requirements for door locks for this application, which would allow a key-operated lock to be installed instead of panic hardware if all of the criteria are met.

Since this is a new code section, it’s best to check with the AHJ to confirm that their interpretation is consistent with mine, but it wouldn’t really be necessary to install panic hardware in addition to the double-cylinder deadbolt if the doors are not required to latch.  Panic hardware is only required by code for doors equipped with a lock or latch, so doors with push/pull hardware would be code-compliant.  When the space is occupied, the key-operated lock would be unlocked and the door would not latch.  When the space is unoccupied and the door is locked with the key-operated lock, the door would not allow free egress even if it was equipped with panic hardware.

I could imagine an application where due to high wind (or in rare cases – a fire rating) the doors might need to be latched all the time.  In that situation the doors should have panic hardware if serving an assembly occupancy, and the AHJ should be consulted about whether the double-cylinder deadbolt can be installed in addition to the panic hardware.  Based on the 2021 IBC Commentary (above), I don’t think the intent of the code is to allow both panic hardware and a key-operated lock, but I don’t know that it negatively impacts the life safety of the building occupants to have both types of hardware on the door.  Keep in mind that this change does not go into effect until the 2021 IBC is adopted in your project’s jurisdiction.  In the meantime, the criteria listed in the 2021 edition could be used to request a code modification from the AHJ.

There is another exception in the panic hardware section that is sort of related and may set a precedent for the new section with regard to panic hardware: A main exit of a Group A occupancy shall be permitted to have locking devices in accordance with Section 1010.2.4, Item 3.  This exception allows panic hardware to be omitted when a key-operated lock is used on the main entrance to a building classified as Group A (assembly), when all of the other criteria are met.  The 2018 IBC Commentary confirms: This option is an alternative to the panic hardware required by Section 1010.1.10.  There is a Decoded article about the requirements for main entrance doors with key-operated locks here, and an update here.  The other two exceptions in the panic hardware section address the use of electrified hardware on doors with panic hardware.

Any questions?

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