It looks like you're using the 2012 IBC. There is a lot of confusion about these 2 sections, and I'm currently working with a committee to revise the Commentary for the 2015 IBC. Between changes to the code and the revised Commentary, these sections (and others) will be much clearer.
The confusion comes from 2 misinterpretations (no offense if anyone has made these interpretations...I'm happy to discuss this until you agree with me
):
1) Some have interpreted 1008.1.9.8 Access-controlled egress doors to apply to all doors that have access control readers.
2) Some have interpreted 1008.1.9.9 Electromagnetically locked egress doors to apply to all doors with electromagnetic locks.
Here is my interpretation (I know - I am not the AHJ and I have no power, but this is what I do all day every day):
1) Section 1008.1.9.8 does not apply to doors with access control readers, when the access control reader is only controlling access, not egress. The Commentary agrees with me:
"An entrance door that was locked or controlled from the exterior, but allowed free egress at any time, such as with a panic bar or other standard hardware, would not be an access controlled egress door." This section applies to electrified locks when they are of a type which does not allow free egress without additional release devices. A common example of this would be an electromagnetic lock. Without the sensor and push button required by this code section, you would not be able to unlock the door from the egress side. The code also requires the lock to unlock upon fire alarm or power failure.
2) Section 1008.1.9.9 is not the only section that can be used for doors with electromagnetic locks. For many years we have applied section 1008.1.9.8 to electromagnetic locks - section 1008.1.9.9 didn't exist until 2009. The difference between the two sections is that 1008.1.9.9 applies to mag-locks which use door-mounted hardware with an integral switch as the release device for the mag-lock, rather than the sensor and push button. Section 1008.1.9.9 does not require the lock to unlock upon fire alarm, only upon loss of power to the switch in the door-mounted hardware (panic hardware or lever set with request-to-exit switch).
Here are the code sections to aid in the discussion:
1008.1.9.8 Access-controlled egress doors. The entrance doors in a means of egress in buildings with an occupancy in Groups A, B, E, I-2, M, R-1 or R-2, and entrance doors to tenant spaces in occupancies in Groups A, B, E, I-2, M, R-1 or R-2, are permitted to be equipped with an approved entrance and egress access control system, listed in accordance with UL 294, which shall be installed in accordance with all of the following criteria:
1. A sensor shall be provided on the egress side arranged to detect an occupant approaching the doors. The doors shall be arranged to unlock by a signal from or loss of power to the sensor.
2. Loss of power to that part of the access control system which locks the doors shall automatically unlock the doors.
3. The doors shall be arranged to unlock from a manual unlocking device located 40 inches to 48 inches (1016 mm to 1219 mm) vertically above the floor and within 5 feet (1524 mm) of the secured doors. Ready access shall be provided to the manual unlocking device and the device shall be clearly identified by a sign that reads “PUSH TO EXIT.” When operated, the manual unlocking device shall result in direct interruption of power to the lock—independent of the access control system electronics—and the doors shall remain unlocked for a minimum of 30 seconds.
4. Activation of the building fire alarm system, if provided, shall automatically unlock the doors, and the doors shall remain unlocked until the fire alarm system has been reset.
5. Activation of the building automatic sprinkler or fire detection system, if provided, shall automatically unlock the doors. The doors shall remain unlocked until the fire alarm system has been reset.
6. Entrance doors in buildings with an occupancy in Group A, B, E or M shall not be secured from the egress side during periods that the building is open to the general public.
1008.1.9.9 Electromagnetically locked egress doors. Doors in the means of egress in buildings with an occupancy in Group A, B, E, M, R-1 or R-2, and doors to tenant spaces in Group A, B, E, M, R-1 or R-2, shall be permitted to be electromagnetically locked if equipped with listed hardware that incorporates a built-in switch and meet the requirements below:
1. The listed hardware that is affixed to the door leaf has an obvious method of operation that is readily operated under all lighting conditions.
2. The listed hardware is capable of being operated with one hand.
3. Operation of the listed hardware directly interrupts the power to the electromagnetic lock and unlocks the door immediately.
4. Loss of power to the listed hardware automatically unlocks the door.
5. Where panic or fire exit hardware is required by Section 1008.1.10, operation of the listed panic or fire exit hardware also releases the electromagnetic lock.
Let's discuss!