Last week, a supervisor from a state fire marshal’s office contacted me to ask a question to which I had not really given much thought.  He had noticed a change in the 2024 model codes related to the UL listings for electrified hardware used in special locking arrangements, and wondered how it would affect the safety of the applicable systems.

Using the sensor-release locking section as an example, the 2021 IBC states: The door locking system units shall be listed in accordance with UL 294.

In the 2024 IBC, the same section states:  The electromechanical or electromagnetic locking device shall be listed in accordance with either UL 294 or UL 1034.

You’ll note two important changes here.  UL 1034 has been added as an alternative listing to UL 294, as some products are a better fit for evaluation using one standard or the other.  The other change is related to the components that require the listing.  Prior to the 2024 edition, the listings applied to “the door locking system units” (an undefined term).  The 2024 IBC clarifies that it is the electromechanical or electromagnetic locks that require the listing.

Because I’m a huge fan of clarity, I have been content with this change to the model codes.  Prior to the 2024 edition, it was unclear which components needed the listings – the electrified locks, power supplies, credential readers, power transfers…or all of the above?  Now it’s clear that the code requirement applies to the locks, and only the locks.

The AHJ’s question about this change was whether the lack of a requirement for listings on the other components would provide the same level of safety as having the listings on every part of the system.  It’s a great question, and I’d love to hear from you on it.  My thoughts are:

• In the past, having the UL 294 listing on the various components of a system didn’t ensure that the components would work together correctly.  They were not necessarily tested as a system – there was no requirement for that in the codes.  With that said, some of the product listings require a specific (listed) power supply or other components.  For example, the Von Duprin Chexit delayed egress device must be used with a power supply that is also listed to UL 294.
• The head of our compliance engineering department confirmed that there are other components of the system (besides the lock), that are not required to be listed to UL 294 but are evaluated to other standards.  For example, electric hinges are evaluated to UL 634, and electric strikes have always been listed to UL 1034, as that standard better addresses electric strikes.  So there are other UL listing that would apply – they’re just not specifically referenced in the model codes.
• The requirement in current and past editions of the model codes only applies to special locking arrangements like electromagnetic locks (sensor release or door hardware release), delayed egress locks, controlled egress in health care, etc.  These listing requirements do not apply to “normal locking arrangements” – electrified hardware that allows free egress at all times.  So the most common type of access control system – a normal locking arrangement that allows free egress – has electrified hardware that is not required by the model codes to be listed.

I’m curious to hear what you have to say on this issue.  Are access control systems as safe as they were before, if only the electrified locks are required by code to have the UL 294 (or UL 1034) listing?

WWYD?

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