EGRESS DOORS AND LOCKS
One of the primary issues regulated by building codes and fire safety codes has always been means of egress. Although doors and locks have always been part of the chapter on means of egress, requirements have changed over the years, and what was legal “back then” may not be legal now. In addition, other provisions that have been in the codes for a long time still aren’t always well understood, either be design professionals or by code officials.
WHAT TYPE OF DOOR?
The general rule is that doors constituting part of a means of egress must be of the pivoted or side-hinged swinging type. [IBC 1010.1.2] However, there are some exceptions, which typically apply where the occupant load is small and the life safety hazard is low.
WHEN IS A DOOR NOT A DOOR?
No, this isn’t a riddle — it’s an issue code officials are confronted with when building designers elect to push the envelope. The fundamental philosophy in the codes is that occupants need to be able to see and visually identify the means of egress — including doors. Let’s look at what the IBC actually says.
Section 1010.1 consists of three paragraphs. The third paragraph states:
The IBC Commentary for this section goes on to explain:
The Commentary reiterates that egress doors can’t be hidden or disguised, but what about pairs of doors, when the building management only unlocks the active leaf when they open a premises for business, and they leave the inactive leaf locked — often with hidden flush bolts that are actuated by flip levers in the face of the meeting stile of the door? I have heard more than one code official say that, as long as the active leaf provides sufficient egress capacity for the number of occupants served by that door, the inactive leaf can remain locked.
In my view, this runs contrary to the fundamental concept that, “If it looks like a door, it should be a door.” A locked inactive leaf isn’t available for use unless and until someone releases the top and bottom flush bolts, which is not going to happen during an emergency evacuation. What is more likely to happen is that people will rush toward both doors, and someone will be injured either by being trapped and pressed against the immovable inactive leaf, or by being pushed through it and being cut by the broken glass. Does the code really allow inactive leaves of double doors to remain locked during occupancy?
First, let’s look at IBC section 1010.2, Door Operations:
A door locked by hidden flush bolts doesn’t require a key or a tool to unlock it, but it does require special knowledge of what concealed flush bolts are and how they operate, and they also may require considerable effort to unlock if people are pushing against them trying to escape a fire.
The Commentary for section 1010.2 says the following:
Of course, panic hardware on both leaves of pairs of doors eliminates any question — but panic hardware is only required when the doors serve an occupant load of 50 or greater.
IBC section 1010.2.2, Hardware, adds another criterion that has to be satisfied:
This eliminates double-cylinder dead bolts, most deadbolts with thumb turns, and it probably also eliminates concealed flush bolts because the operation requires pinching the flip levers to pull them out of the recesses in the face of the door stile.
LET’S LOOK AT LOCKS
IBC section 1010.2.1, Unlatching, begins to address the question of manual, concealed flush bolts:
Concealed flush bolts almost always come in pairs, one for the top and one for the bottom, and they operate independently. So they don’t meet the single operation criterion.
IBC section 1010.2.4, Locks and Latches, goes on to provide that:
Most of the conditions allowing doors to be locked against egress are special occupancies. However, condition number 4 is hardware-related and not limited to any specific occupancy classification:
The type of concealed, manually-operated flush bolts that are very often found in double doors in storefront type construction are thus NOT allowed under our current building code. Automatic flush bolts, on the other hand, don’t require manual intervention; when the active leaf opens, automatic flush bolts in the inactive leaf retract automatically, leaving the door free to open.
Finally, IBC section 1010.2.5, Bolt Locks, provides that:
It doesn't get any clearer than that. This provision goes back at least to the 2003 International Building Code (as 1008.1.8.4). However, the 2003 version had just two exceptions to this provision. The current provision has five exceptions. Two of the new exceptions (numbers 3 and 4) may apply:
These exceptions were added in the 2009 edition of the International Building Code. It is important to note that both of these exceptions include the provision that “The inactive leaf shall not contain doorknobs, panic bars or similar operating hardware.” This statement is clarified in the Commentary; the requirement is there to establish that “the active leaf must meet means of egress requirements and the inactive leaf must not have any operating hardware so that it could be mistaken for an egress door.” The exceptions expressly mention doorknobs and panic bars but, as clarified by the Commentary, it would seem prudent to include push bars and door pulls under the “or similar operating hardware” language of the code because, if it looks like a door, it should function as a door. In case of an emergency evacuation, we don’t want people to pile up against something that looks like a door but doesn’t open when they push on it.
Finally, it’s also important that Exception number 4 tells us if the occupant load is 50 or greater, manually-operated flush bolts are allowed only if the entire building is protected by a NFPA 13 automatic sprinkler system.
The Commentary also suggests that these exceptions are intended primarily to apply to doors where the inactive leaf is usually closed, is not required or used for egress, and is opened and used for moving equipment and furnishings. A typical application is an automobile showroom, which often has one pair of oversized doors (one of which may be asymmetrically wide) to allow driving display vehicles into and out of the building. This provision should not apply to pairs of doors that are both equipped with door pulls and push bars and which are sometimes both open for customers to use and other times the staff forgets or are too lazy to unlock the flush bolts.
Where only the active leaf of a pair of doors is to be used as the exit door, consider requiring that the EXIT sign be centered over the active leaf, rather than centered over the interface between the active and inactive leaves.
What about locks on single doors? There’s no simple answer; too much depends on the use group classification and the occupancy. The simplest is one- and-two-family dwellings. For those, the rules are easy:
So, no double-key deadbolts. And “readily openable” is often interpreted to mean one operation, which would require that deadbolts need to be connected to the latchbolt so that turning the knob or lever retracts the deadbolt at the same time it retracts the latchbolt. However, the IRC Commentary only says that double-key deadbolts are not allowed.
In the IBC, however, locking provisions are not as simple or as clear-cut. First, let’s take another look at IBC section 1010.2, Door Operations:
As discussed above, the IBC Commentary informs us that:
The problem is that many businesses have employees come in before the business opens and remain after the business has closed for customers. The businesses want to lock the doors while the staff work inside the premises. But IBC section 1010.2 requires that egress doors “shall” be readily openable from the egress side without the use of a key. In addition, IBC section 1010.2.1, Unlatching, says:
IBC section 1010.2.2, Hardware, goes on to provide that:
And the IBC Commentary says:
Taken together, these provisions seem to argue that the code does not allow a business with a hollow-metal, storefront door to lock the door with a double-key deadbolt while anyone is working inside. But we see such businesses all over the state — why are they allowed to continue?
The answer is found in the fire codes. The NFPA 101 Life Safety Code for existing occupancies includes a provision (paraphrased) that a space is not considered to be occupied when the occupant load is less than 10 people. The I-Codes do not include a similar provision. This means that Fire Marshals can allow such locking arrangements to continue in existing businesses. However, if a tenant space is altered and for new buildings and new occupancies, there is no corresponding provision in the building code. Under the IBC, “occupied” is not defined. If we look in a dictionary for the definition, we find that “occupy” is a verb, of which “occupied” is the past tense. “Occupied” has several meanings, but the ones that fit here basically mean “to be in”:
For our purposes in enforcing the building code, therefore, doors cannot be locked against egress with any arrangement that requires more than one operation to open the door, or which involves tight grasping, tight pinching or twisting of the wrist to operate when people are inside.
Lock manufacturers are aware of this, and they have products that satisfy all the applicable requirements. One such product is made by Adams-Rite, a major hardware manufacturer that is owned by the same corporation that also owns the Sargent company: Assa Abloy. The Adams-Rite MS+® 1890 Series MS® Deadlock/Deadlatch provides a deadbolt for security overnight, when the space is completely unoccupied, along with a separate latchbolt (which can be actuated from the inside by a push paddle) to keep customers out while allowing employees to have easy, single operation egress from inside before business hours.
MS+® 1890 Series MS® Deadlock/Deadlatch
If Adams-Rite makes one, it’s probably safe to assume that other major lock companies offer a competing product. But it’s not our job to become the specifier. As long as we know that there is at least one product that complies with the code, we don’t need to be concerned that enforcing the code creates an impossible situation for the applicant.
CONCLUSIONS
Doors and locks are a crucial part of the egress paths from buildings. For any arrangement other than panic hardware, understanding what requirements apply can appear confusing. It’s easier if we just remember that the basic rule-of-thumb is that opening any door in a means of egress cannot require more than one operation. (There are certain exceptions in the code, but those are for specialized occupancies such as institutions and prisons.)
One of the primary issues regulated by building codes and fire safety codes has always been means of egress. Although doors and locks have always been part of the chapter on means of egress, requirements have changed over the years, and what was legal “back then” may not be legal now. In addition, other provisions that have been in the codes for a long time still aren’t always well understood, either be design professionals or by code officials.
WHAT TYPE OF DOOR?
The general rule is that doors constituting part of a means of egress must be of the pivoted or side-hinged swinging type. [IBC 1010.1.2] However, there are some exceptions, which typically apply where the occupant load is small and the life safety hazard is low.
- Private garages, office areas, factory and storage areas with an occupant load of 10 or less.
- Group I-3 occupancies used as a place of detention.
- Critical or intensive care patient rooms within suites of health care facilities.
- Doors within or serving a single dwelling unit in Groups R-2 and R-3.
- In other than Group H occupancies, revolving doors complying with Section 1010.1.4.1.
- In other than Group H occupancies, special purpose horizontal sliding, accordion or folding door assemblies complying with Section 1010.1.4.3.
- Power-operated doors in accordance with Section 1010.1.4.2.
- Doors serving a bathroom within an individual sleeping unit in Group R-1.
- In other than Group H occupancies, manually operated horizontal sliding doors are permitted in a means of egress from spaces with an occupant load of 10 or less.
WHEN IS A DOOR NOT A DOOR?
No, this isn’t a riddle — it’s an issue code officials are confronted with when building designers elect to push the envelope. The fundamental philosophy in the codes is that occupants need to be able to see and visually identify the means of egress — including doors. Let’s look at what the IBC actually says.
Section 1010.1 consists of three paragraphs. The third paragraph states:
The IBC Commentary for this section goes on to explain:
The Commentary reiterates that egress doors can’t be hidden or disguised, but what about pairs of doors, when the building management only unlocks the active leaf when they open a premises for business, and they leave the inactive leaf locked — often with hidden flush bolts that are actuated by flip levers in the face of the meeting stile of the door? I have heard more than one code official say that, as long as the active leaf provides sufficient egress capacity for the number of occupants served by that door, the inactive leaf can remain locked.
In my view, this runs contrary to the fundamental concept that, “If it looks like a door, it should be a door.” A locked inactive leaf isn’t available for use unless and until someone releases the top and bottom flush bolts, which is not going to happen during an emergency evacuation. What is more likely to happen is that people will rush toward both doors, and someone will be injured either by being trapped and pressed against the immovable inactive leaf, or by being pushed through it and being cut by the broken glass. Does the code really allow inactive leaves of double doors to remain locked during occupancy?
First, let’s look at IBC section 1010.2, Door Operations:
A door locked by hidden flush bolts doesn’t require a key or a tool to unlock it, but it does require special knowledge of what concealed flush bolts are and how they operate, and they also may require considerable effort to unlock if people are pushing against them trying to escape a fire.
The Commentary for section 1010.2 says the following:
Of course, panic hardware on both leaves of pairs of doors eliminates any question — but panic hardware is only required when the doors serve an occupant load of 50 or greater.
IBC section 1010.2.2, Hardware, adds another criterion that has to be satisfied:
This eliminates double-cylinder dead bolts, most deadbolts with thumb turns, and it probably also eliminates concealed flush bolts because the operation requires pinching the flip levers to pull them out of the recesses in the face of the door stile.
LET’S LOOK AT LOCKS
IBC section 1010.2.1, Unlatching, begins to address the question of manual, concealed flush bolts:
Concealed flush bolts almost always come in pairs, one for the top and one for the bottom, and they operate independently. So they don’t meet the single operation criterion.
IBC section 1010.2.4, Locks and Latches, goes on to provide that:
Most of the conditions allowing doors to be locked against egress are special occupancies. However, condition number 4 is hardware-related and not limited to any specific occupancy classification:
The type of concealed, manually-operated flush bolts that are very often found in double doors in storefront type construction are thus NOT allowed under our current building code. Automatic flush bolts, on the other hand, don’t require manual intervention; when the active leaf opens, automatic flush bolts in the inactive leaf retract automatically, leaving the door free to open.
Finally, IBC section 1010.2.5, Bolt Locks, provides that:
It doesn't get any clearer than that. This provision goes back at least to the 2003 International Building Code (as 1008.1.8.4). However, the 2003 version had just two exceptions to this provision. The current provision has five exceptions. Two of the new exceptions (numbers 3 and 4) may apply:
These exceptions were added in the 2009 edition of the International Building Code. It is important to note that both of these exceptions include the provision that “The inactive leaf shall not contain doorknobs, panic bars or similar operating hardware.” This statement is clarified in the Commentary; the requirement is there to establish that “the active leaf must meet means of egress requirements and the inactive leaf must not have any operating hardware so that it could be mistaken for an egress door.” The exceptions expressly mention doorknobs and panic bars but, as clarified by the Commentary, it would seem prudent to include push bars and door pulls under the “or similar operating hardware” language of the code because, if it looks like a door, it should function as a door. In case of an emergency evacuation, we don’t want people to pile up against something that looks like a door but doesn’t open when they push on it.
Finally, it’s also important that Exception number 4 tells us if the occupant load is 50 or greater, manually-operated flush bolts are allowed only if the entire building is protected by a NFPA 13 automatic sprinkler system.
The Commentary also suggests that these exceptions are intended primarily to apply to doors where the inactive leaf is usually closed, is not required or used for egress, and is opened and used for moving equipment and furnishings. A typical application is an automobile showroom, which often has one pair of oversized doors (one of which may be asymmetrically wide) to allow driving display vehicles into and out of the building. This provision should not apply to pairs of doors that are both equipped with door pulls and push bars and which are sometimes both open for customers to use and other times the staff forgets or are too lazy to unlock the flush bolts.
Where only the active leaf of a pair of doors is to be used as the exit door, consider requiring that the EXIT sign be centered over the active leaf, rather than centered over the interface between the active and inactive leaves.
What about locks on single doors? There’s no simple answer; too much depends on the use group classification and the occupancy. The simplest is one- and-two-family dwellings. For those, the rules are easy:
So, no double-key deadbolts. And “readily openable” is often interpreted to mean one operation, which would require that deadbolts need to be connected to the latchbolt so that turning the knob or lever retracts the deadbolt at the same time it retracts the latchbolt. However, the IRC Commentary only says that double-key deadbolts are not allowed.
In the IBC, however, locking provisions are not as simple or as clear-cut. First, let’s take another look at IBC section 1010.2, Door Operations:
As discussed above, the IBC Commentary informs us that:
The problem is that many businesses have employees come in before the business opens and remain after the business has closed for customers. The businesses want to lock the doors while the staff work inside the premises. But IBC section 1010.2 requires that egress doors “shall” be readily openable from the egress side without the use of a key. In addition, IBC section 1010.2.1, Unlatching, says:
IBC section 1010.2.2, Hardware, goes on to provide that:
And the IBC Commentary says:
Taken together, these provisions seem to argue that the code does not allow a business with a hollow-metal, storefront door to lock the door with a double-key deadbolt while anyone is working inside. But we see such businesses all over the state — why are they allowed to continue?
The answer is found in the fire codes. The NFPA 101 Life Safety Code for existing occupancies includes a provision (paraphrased) that a space is not considered to be occupied when the occupant load is less than 10 people. The I-Codes do not include a similar provision. This means that Fire Marshals can allow such locking arrangements to continue in existing businesses. However, if a tenant space is altered and for new buildings and new occupancies, there is no corresponding provision in the building code. Under the IBC, “occupied” is not defined. If we look in a dictionary for the definition, we find that “occupy” is a verb, of which “occupied” is the past tense. “Occupied” has several meanings, but the ones that fit here basically mean “to be in”:
For our purposes in enforcing the building code, therefore, doors cannot be locked against egress with any arrangement that requires more than one operation to open the door, or which involves tight grasping, tight pinching or twisting of the wrist to operate when people are inside.
Lock manufacturers are aware of this, and they have products that satisfy all the applicable requirements. One such product is made by Adams-Rite, a major hardware manufacturer that is owned by the same corporation that also owns the Sargent company: Assa Abloy. The Adams-Rite MS+® 1890 Series MS® Deadlock/Deadlatch provides a deadbolt for security overnight, when the space is completely unoccupied, along with a separate latchbolt (which can be actuated from the inside by a push paddle) to keep customers out while allowing employees to have easy, single operation egress from inside before business hours.
MS+® 1890 Series MS® Deadlock/Deadlatch
If Adams-Rite makes one, it’s probably safe to assume that other major lock companies offer a competing product. But it’s not our job to become the specifier. As long as we know that there is at least one product that complies with the code, we don’t need to be concerned that enforcing the code creates an impossible situation for the applicant.
CONCLUSIONS
Doors and locks are a crucial part of the egress paths from buildings. For any arrangement other than panic hardware, understanding what requirements apply can appear confusing. It’s easier if we just remember that the basic rule-of-thumb is that opening any door in a means of egress cannot require more than one operation. (There are certain exceptions in the code, but those are for specialized occupancies such as institutions and prisons.)