When there is a desire to lock a door in the direction of egress for security reasons, today’s Quick Question is often raised:

During a lockdown, is a room or area considered a “place of detention or restraint”?

The quick answer: No. 

The International Building Code (IBC) mandates that most doors required for egress or provided for egress purposes must meet the code requirements.  This includes unlatching the door with one releasing motion for free egress without the use of a key, tool, special knowledge or effort.  These requirements help to ensure that when a building occupant needs to use a door to exit, they can do so without any barrier to egress.

The code includes two exceptions stating that doors serving “places of detention or restraint” a) are not required to unlatch with one releasing motion and b) are allowed to have locks that do not permit free egress.  In the 2021 edition of the IBC, these exceptions are found in sections 1010.2.1 Unlatching and 1010.2.4 Locks and Latches.

But what is considered a “place of detention or restraint” where it would be acceptable to have doors that do not allow free egress?  This issue most often comes up with regard to security products used for barricading a door during a lockdown.  When I have pointed out that the doors (classroom doors, for example) must be code-compliant, some product developers have responded by saying: “During an active shooter event, the room becomes a place of detention and restraint, and the door is exempt from the codes.”  This is not the intent of the IBC.

When a code requirement is not crystal clear, alternative interpretations can occur.  That’s one of the reasons that the BHMA Codes, Government, and Industry Affairs Committee (BHMA CGIA) has spent so much time and effort to make changes to clarify the model codes.  Based on the confusion about places of detention or restraint, I have added this to my code development wish list for the 2027 model codes.  Until then, we have to rely on the IBC Commentary to help demonstrate the intent of the code.  I also spoke to ICC staff to confirm my interpretation.

With regard to Section 1010.2.4 – Locks and Latches, the IBC Commentary states:

Where security and life safety objectives conflict, alternative measures, such as those permitted by each of the listed situations, may be applicable. Item 1 is needed for jails and prisons (Occupancy Group I-3).

Item 1 is applies to places of detention or restraint, and the Commentary clarifies that this is intended to apply to I-3 occupancies.  Use Group I-3 is defined by the IBC as follows:

308.4 Institutional Group I-3. Institutional Group I-3 occupancy shall include buildings and structures that are inhabited by more than five persons who are under restraint or security.  A Group I-3 facility is occupied by persons who are generally incapable of self-preservation due to security measures not under the occupants’ control. This group shall include, but not be limited to, the following:
– Correctional centers
– Detention centers
– Jails
– Prerelease centers
– Prisons
– Reformatories

Buildings in Group I-3 are further classified as one of five different occupancy conditions based on the level of security, and Section 408 of the 2021 IBC addresses the requirements for these facilities.  This section includes detailed criteria for facilities where building occupants are not allowed to evacuate during a fire, to help ensure life safety with a defend-in-place strategy.

It’s clear from the IBC Commentary that the egress exceptions for places of detention or restraint are intended to apply to I-3 occupancies like jails, prisons, and other locations where building occupants are typically detained.  A room in another type of occupancy, such as an educational or business occupancy, does not “become” a place of detention and restraint when lockdown occurs.  Doors serving these spaces are required to comply with the egress requirements stated in the adopted codes.  For more information about the requirements for classroom doors, refer to the Decoded article linked here.

Do you have experience or insight on this issue?  I’d love to hear from you in the comments.

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