Locking Exits

[Marshal Chris]

Hello everyone, hope all is well.

Existing I-2 with mag locks on main entrance doors. Does not comply with delayed egress or access controlled egress doors arrangement, not that their permitted anyway. After hours, when someone isn't located at the front desk, the mag lock gets locked "to prevent the patients from the dementia unit from escaping". This lock gets released by the use of a RFID key fab on either side of the door. It's on the main door because they eliminated the doors to the units themselves so they can walk around the building.

I know 101 permits the locking of dementia units provided all staff has a key. However, I don't see any such provision in the IFC (2003 ver/NYS Ver) unless I'm missing something. Anyone have insight?

 

[FM William Burns]

In this example I would look at the mag locks as being an “approved” delayed egress lock like these:



http://www.sdcsecurity.com/UL/index2.aspx





and as long as it functions as provided for in (2009) 1008.1.9.6 and if staff meets #5. Don’t have the 2003 edition.

 

[Marshal Chris]

I'm not at work yet so I'll verify this later but.. 1008.1.9 doesn't appear to go to a .6 in the NYS version..

1008.1.9 Panic and fire exit hardware. Where panic and fire exit hardware is installed, it shall comply with the following:

1. The actuating portion of the releasing device shall extend at least one-half of the door leaf width.

2. A maximum unlatching force of 15 pounds (67 N).

Each door in a means of egress from an occupancy of Group A or E having an occupant load of 100 or more and any occupancy of Group H-1, H-2, H-3 or H-5 shall not be provided with a latch or lock unless it is panic hardware or fire exit hardware.

If balanced doors are used and panic hardware is required, the panic hardware shall be the push-pad type and the pad shall not extend more than one-half the width of the door measured from the latch side.

Thats it.

And FYI, for all looking, if you ever need it, NYS has the codes on the web for free:

http://publicecodes.citation.com/st/ny/st/index.htm

Albeit, they are difficult to maneuver through in its current set up.

 

[TimNY]

I would refer to 1008.1.8.3:

Locks and latches shall be permitted to prevent operation of doors where any of the following exists:

1. Places of detention or restraint.

I believe a magnetic lock would be allowed. As far as I can see the IBC doesn't have a further requirements as to who should have a key or what manner in which the locks should unlatch when you've met #1. I'm sure the health department would have their own regs covering this, and they would be responsible for enforcing them.

 

[Marshal Chris]

The commentary refers to correctional facilities and makes no mention of healthcare. Is a dimetia unit a place of restraint? And I don't think "restraint" is their primary purpose. JMHO

 

[cda]

with out a layout of the facility and what else is going on in it, I would say it is a little hard to make a call over the air

but sounds like if it is legal delayed egress, or have heard of devices that alert or lock down the door if a person that they do not want out goes near the door

sounds like they need to go to plan B, and get it approved prior to use

 

[FM William Burns]

MC,

Why can't the I-2 use (from the 2003 edition of IFC)

1008.1.8.6 Delayed egress locks.

Approved, listed, delayed egress locks shall be permitted to be installed on doors serving any occupancy except Group A, E and H occupancies in buildings that are equipped throughout with an automatic sprinkler system in accordance with :Next('./icod_ifc_2003_9_sec003_par038.htm')'>Section 903.3.1.1 or an approved automatic smoke or heat detection system installed in accordance with :Next('./icod_ifc_2003_9_sec007.htm')'>Section 907, provided that the doors unlock in accordance with Items 1 through 6 below. A building occupant shall not be required to pass through more than one door equipped with a delayed egress lock before entering an exit.

1. The doors unlock upon actuation of the automatic sprinkler system or automatic fire detection system.

2. The doors unlock upon loss of power controlling the lock or lock mechanism.

3. The door locks shall have the capability of being unlocked by a signal from the fire command center.

4. The initiation of an irreversible process which will release the latch in not more than 15 seconds when a force of not more than 15 pounds (67 N) is applied for 1 second to the release device. Initiation of the irreversible process shall activate an audible signal in the vicinity of the door. Once the door lock has been released by the application of force to the releasing device, relocking shall be by manual means only.

Exception: Where approved, a delay of not more than 30 seconds is permitted.5. A sign shall be provided on the door located above and within 12 inches (305 mm) of the release device reading: PUSH UNTIL ALARM SOUNDS. DOOR CAN BE OPENED IN 15 [30] SECONDS.6. Emergency lighting shall be provided at the door.

 

[TimNY]

I would go with the dictionary definition of "restraint".

1 a : to prevent from doing, exhibiting, or expressing something b : to limit, restrict, or keep under control

If the individuals are limited, restricted, or kept under control then they are under restraint and the building is a place of restraint.

Of course, if these people can sign themselves out (ie in a rehab), then I would not say they are under restraint. Also, if only some of the patients are under restraint and others are not, I would not allow them to classify the entire building as a place of restraint.

You say "dementia unit"-- is this a nursing home or a psychiatric center?

 

[FM William Burns]

I must restrain from further comment after this.....and agree with TNY.

Is a dimetia unit a place of restraint? And I don't think "restraint" is their primary purpose.

Yes, it's a place of restraint and the locking means is for that specific and sole purpose (for their safety via wandering off) and permitted.

 

[Gene Boecker]

Try making the "approval" based on the 2009 text. The exception has the language about restraint.

1008.1.9.6 Special locking arrangements in Group I-2. Approved delayed egress locks shall be permitted in a Group I-2 occupancy where the clinical needs of persons receiving care require such locking. Delayed egress locks shall be permitted in such occupancies where the building is equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1 or an approved automatic smoke or heat detection system installed in accordance with Section 907, provided that the doors unlock in accordance with Items 1 through 6 below. A building occupant shall not be required to pass through more than one door equipped with a delayed egress lock before entering an exit.

1. The doors unlock upon actuation of the

automatic

sprinkler system

or automatic fire

detection system.



2. The doors unlock upon loss of power controlling

the lock or lock mechanism.







3. The door locks shall have the capability of being

unlocked by a signal from the fire command center, a

nursing station or other

approved

location.



4. The procedures for the operation(s) of the unlocking

system shall be described and

approved

as part

of the emergency planning and preparedness

required by Chapter 4 of the

International Fire

Code

.

5. All clinical staff shall have the keys, codes or other ​

means necessary to operate the locking devices.

6. Emergency lighting shall be provided at the door.​

Exception: ​

Items 1 through 3 shall not apply to doors​

to areas

where persons, because of clinical needs,

require

restraint or containment as part of the function

of

a mental hospital.

 

[FM William Burns]

There you go (as referenced below or above depending on your settings) 2 out of 3 dentists agree.................

 

[Marshal Chris]

1. What I don't understand is why NYS took that section (1008.1.9.6) out, or is that new for ICC 2009? We're several cycles behind the ICC versions as the NYS is based upon the 03 version of ICC, with the NY Enhancements. So, since we still haven't adopted the 06 version yet, i'm sure it'll be at least 6-9 years before we actually get verbage in our code.

FMWB, I stand corrected. They can use delayed egress, however this installation doesn't comply with the installation requirements.

Just so everyone is on the same page here, these are the main entrance doors to the facility. They house the dementia patients everywhere, so there is no designated unit. 101 actually says, in the appendix, that the special locking arrangement should not apply to facilities where these patients aren't in specific units.

 

[FM William Burns]

Listed v. Approved

Regarding the 09 section, it looks like a clarification/expansion from 03 to 09 to accommodate areas of special need like the dementia paitents but Gene could better advise on that since he’s the man.

The main doors would still be permitted provided the facility meets:

A building occupant shall not be required to pass through more than one door equipped with a delayed egress lock before entering an exit.

and the additional laundry list. Based on the 09 edition, it appears that the main exit doors could be fitted with “approved” delayed egress locking means.

Reading that the hardware is not installed in accordance with the manufacturer’s installation requirements, its potential listing is invalid therefore creating a non-compliant installation since I would not approve a non-listed locking means in occupancies like this. In order for them to use approved delayed egress hardware they will have to meet the manufacturer’s installation requirements if the means is a “listed” installation. Personally, I like the 101 version

 

[hlfireinspector]

If under restraint the building is no longer classed a I-2 but is now classed a I-3 and must be constructed as such. Separation requirements, firewall and smoke compartmention are a lot different in I-3. Just my 2 cents.

 

[TimNY]

If under restraint the building is no longer classed a I-2 but is now classed a I-3 and must be constructed as such. Separation requirements, firewall and smoke compartmention are a lot different in I-3. Just my 2 cents.

Good catch.

As this appears to be an existing facility that has recently changed the egress, I think the "change of occupancy" chapter from the Existing Building Code would need to be referenced for the change from I-2 to I-3.

 

[Gene Boecker]

NOT SO.

Check the definition in 308.3.1 of the 2009 IBC. It includes Mental Hospitals - which, by necessity, include some forms of restraint. These are still hospitals as explained in the commentary. Just because they have a restraint provided in the hospital that does not make them I-3.

A mental hospital is still a hospital and still an I-2 occupancy. This was greatly discussed at the code hearings as well as among staff at the ICC.

 

[TimNY]

I don't have the commentary with me, but from just reading the code I would not come to the same conclusion as you.

I-2: "more than five persons who are not capable of self-preservation"

I-3: "occupied by persons who are generally incapable of self-preservation due to security measures not under the occupants' control"

I appreciate your insight, no doubt you are correct as you have the "inside scoop."

 

[LGreene]

According to section 1008.1.9.7 (2009), a delayed egress lock is required to unlock after 15 seconds (http://www.ihatehardware.com/2009/03/delayed-egress-hardware/). A standard mag-lock isn't a delayed egress lock. Section 1008.1.9.6, added in the 2009 IBC, doesn't describe a delayed egress lock, even though the term is used. The requirements listed there are describing a standard lock that releases upon fire alarm, power failure, etc., but the lock is not required to release after 15 seconds like a delayed egress lock.

There was a code change proposal to add another exception to 1008.1.9.3 Locks and Latches, but I don't know if it was accepted or not. Here's the proposed added text:

6. In Group I-2 occupancies housing clients where the means of egress needs to be secured for the safety of the

clients provided all the following requirements are met:

6.1 The facility is equipped throughout with an automatic sprinkler system in accordance with Section

903.3.1.1,

6.2 The doors unlock upon actuation of the automatic sprinkler system,

6.3 The doors unlock upon activation of the automatic smoke detection system,

6.4 The doors unlock upon loss of power controlling the lock or lock mechanism,

6.5 The door locks shall have the capability of being unlocked by a signal from an approved location,

6.6 Emergency lighting is provided at the door, and

6.7 The facility is constantly staffed.