In yesterday’s post I wrote about new text that was added to the 2021 IBC Commentary, clarifying the intent of the code regarding “normal locking arrangements.” This type of electrified hardware allows free egress at all times, independent of the access control system. The sections of the code related to “special locking arrangements” do not apply to electrified hardware that controls access but does not affect egress.
This clarification in the Commentary helps with another interpretation related to electrified hardware – whether the code requires the hardware to be listed to UL 294 – Standard for Safety Access Control System Units. The short answer is that the model codes require this listing for electrified hardware in some types of special locking arrangements; the model codes do not require the UL 294 listing for every type of electrified hardware. But with the confusion surrounding which code section to apply to doors with normal locking arrangements, I have sometimes been asked to show the listing for every piece of hardware with a wire.
In the 2021 IBC, the UL 294 listing is referenced in the following sections:
- 1010.2.11 Door hardware release of electrically locked egress doors – The doors typically have electromagnetic locks that are released by an RX (request-to-exit) switch in the panic hardware, lever handle, or touch-sense bar.
- 1010.2.12 Sensor release of electrically locked egress doors – This section applies to electrified locks released by a sensor on the egress that detects a building occupant approaching; electromagnetic locks are most commonly used in these systems.
- 1010.2.13.1 Delayed egress locking system – Under normal operation this hardware delays egress for 15 seconds, but must allow immediate egress upon power failure and upon fire alarm/sprinkler system activation.
- 1010.2.14 Controlled egress doors in Groups I-1 and I-2 – This section applies only to certain types of health care facilities where patients require containment for their safety or security.
If a system that incorporates electrified hardware is not one of these types of systems, the IBC does not require the UL 294 listing (NFPA 101 requirements are slightly different – see below).
Not all electrified hardware carries the UL 294 listing, because the listing is not necessary for the most common type of system – access control/free egress. For example, if a door has an access control reader controlling an electric strike to restrict ingress, and the lever handle on the lockset allows free egress, the strike would not require the UL 294 listing because it is not part of one of the 4 systems listed above.
But you don’t have to take my word for it. The 2021 IBC Commentary includes the following paragraph (and other similar paragraphs) to clarify the intent of the code with regard to UL 294:
UL 294, Standard for Access Control System Units, applies to construction, performance and operation of systems that control passage through a door and the electrical, electronic or mechanical units of these systems. Item 6 requires the locking system units of the door hardware release electrical locking system to comply with and be listed in accordance with UL 294. It may be appropriate to recognize that this code does not require the units of an access control system (ingress control system) to be listed to UL 294.
Any questions? These resources might help:
- There is more information about the UL 294 requirements – including the references from NFPA 101 – in this post: UL 294 Follow-Up – 2021 Update.
- UL published an article about UL 294 and UL 1034, and it’s important to note that the 2024 IBC will allow either of those two listings in the sections where the UL 294 listing is currently required. There is a post about UL’s article here: UL: Proper Application of UL Standards – UL 294 & 1034.
- I wrote a Quick Question post specific to UL 294 on electric latch retraction panic hardware, which is here: QQ: Electric Latch Retraction & UL 294.