When I created iDigHardware in 2009, I never in a million years thought that code officials would read it. But I am so proud to say that I have many readers who are AHJs, and sometimes they even ask me questions. A fire marshal recently asked me today’s Quick Question:
A school district in my jurisdiction wants to use chains and padlocks to secure the school buildings at night and on weekends. Do the model codes allow this when the building is not occupied?
This might seem like a simple question to answer, but there are strong opinions on both sides. Here are my thoughts on this issue:
NFPA 101 differentiates between what is allowed when the building is occupied vs. not occupied, so some AHJs interpret the requirements of the Life Safety Code to apply only when a building is occupied, and not when it is unoccupied. But what often happens is that the chains and padlocks used to secure a building when it is unoccupied, remain in place even when the building IS occupied. I also think about firefighters in an unoccupied building during a fire, unable to exit through chained doors.
I spend most of my time working with the I-Codes – the International Building Code (IBC) and the International Fire Code (IFC). These codes require egress doors to unlatch with one releasing motion, without a key, special knowledge, or effort, and the I-Codes don’t differentiate between occupied/unoccupied with regard to egress. I don’t see anything in the IFC that says egress doors can be locked in the direction of egress when the building is not occupied (with some exceptions related to special locking arrangements).
There are several sections in NFPA 101 and some explanatory information in the Life Safety Code Handbook that I would interpret to mean that chains and padlocks can not be used on a school’s egress doors – even when the building is not occupied:
18.104.22.168.3.2 Where means of egress doors are locked in a building that is not considered occupied, occupants shall not be locked beyond their control in buildings or building spaces, except for lockups in accordance with 22.4.5 and 23.4.5, detention and correctional occupancies, and health care occupancies.
22.214.171.124.1 Door leaves shall be arranged to be opened readily from the egress side whenever the building is occupied.
126.96.36.199.3 Locks, if provided, shall not require the use of a key, a tool, or special knowledge or effort for operation from the egress side.
From the Handbook:
The intent of permitting a building with 10 or fewer occupants to be considered unoccupied – if it is not open for general occupancy and not open to the public – is to allow small security details or small cleaning crews inside a building without applying all the Code requirements. This will allow door assemblies to be locked and lights to be turned off without violating the Code. The limited number of occupants will use lights as they need them and then turn them off. In the case of security personnel they will carry their own lights and keys. For example, see the criterion of 188.8.131.52.5.1(4) for making a key available to occupants, which is applicable to a special type of key-operated dead bolt lock.
The wording of 184.108.40.206.3.2 reiterates that it is not the intent to allow people, no matter how few the number, to be locked in a building without a ready means of egress. Even in detention and correctional facilities, where locked door assemblies are permitted, 24-hour staffing must be provided in sufficient numbers to start the release of locks necessary for emergency evacuation or rescue and initiate other necessary emergency actions within 2 minutes of alarm.
If we try to apply the code sections for key-operated locks to these doors with padlocks and chains (this section is typically applied to double-cylinder deadbolts), the I-Codes do not permit key-operated locks to be used on educational facilities, and in the use groups where they are permitted, they are only allowed on the main entrance doors. NFPA 101 also includes a section on key-operated locks, but the locks are allowed where permitted by the occupancy chapters. Chapters 14 and 15, covering new and existing educational occupancies, do not permit key-operated locks. NFPA 101 also states in the key-operated locking section that a key must be immediately available to any occupant inside the building when it is locked, and it is unlikely that every person in the building after hours would have keys for all of the padlocks.