Locks / CBC 11B-404.2.7 and the IBC 1010.2.3

[user_pc_9876]

Trying to install some electronic locks on doors in a building in California and hoping for some assistance navigating a discrepancy between the CBC 11B-404.2.7 and the IBC 1010.2.3:

11B-404.2.7 of the CBC states that "Handles, pulls, latches, locks, and other operable parts on the doors and gates shall comply with Section 11B-309.4. Operable parts of such hardware shall be 34 inches (864 mm) minimum and 44 inches (1118 mm) maximum above the finish floor or ground." (emphasis added).

Meanwhile, the IBC 1010.2.3 seems to specify a maximum height of 48 inches for the hardware.


The locks we are looking to install have an operable internal push button at around the 45-46 inch mark.

My sense in asking around was that, while CBC has a more stringent rule with respect to the maximum allowable height, AHJs have not taken issue with locks are as long as their operable parts are below 48 inches. Has anyone else dealt with this issue specifically? Also, I am not seeing the exception in the CBC for "locks used only for security purposes and not used for normal operation" -- does anyone know the history of this exception and if some version of it exists in the CBC?

 

[Yankee Chronicler]

Why can't your lock be mounted 2 inches lower to comply with the CBC requirement?

 

[user_pc_9876]

I think because the lock would then no longer align with the hole in the existing doors.

 

[arwat23]

I don't see a discrepancy between CBC 1010.2.3 and 11B-404.2.7. 1010.2.3 applies to all doors, while 11B-404.2.7 only applies to doors that are required to be accessible. When the door needs to be accessible, Ch 11B (or 11A depending on the project) comes into play. In that case, the more strict requirement wins.

If the door doesn't need to comply with Ch 11B (doesn't need to be accessible), then ignore the technical requirements of 11B. That would mean 48" is the max allowed. If it does need to be accessible, if Ch 11B is applicable, then 44" is your max.

 

[user_pc_9876]

Got it, thanks @arwat23 . I was just surprised that a lock manufacturer would release a device that couldn't be installed in a large group of doors, or at least made it obvious that it couldn't be. I figured there must have an an alternative explanation.

 

[user_pc_9876]

Also for what it's worth, 2010 ADA Standards also align with the 48 inch maximum.

404.2.7 Door and Gate Hardware. Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.

 

[arwat23]

I was just surprised that a lock manufacturer would release a device that couldn't be installed in a large group of doors, or at least made it obvious that it couldn't be. I figured there must have an an alternative explanation.

Maybe California being California? ICC A117.1 shows 48" is allowed for accessibility, as does the 2010 ADAS.

It's possible that lock would work in most other places, possibly all other places, outside of California.

 

[arwat23]

Also for what it's worth, 2010 ADA Standards also align with the 48 inch maximum.

404.2.7 Door and Gate Hardware. Handles, pulls, latches, locks, and other operable parts on doors and gates shall comply with 309.4. Operable parts of such hardware shall be 34 inches (865 mm) minimum and 48 inches (1220 mm) maximum above the finish floor or ground. Where sliding doors are in the fully open position, operating hardware shall be exposed and usable from both sides.

Yeah, but ADAS doesn't mean much in CA, at least in terms of construction accessibility. CBC 11B is the 2010 ADAS with amendments. Unfortunately for that hardware, one of those amendment just so happens to have reduced the hardware mounting height to 44".

I'm a CASp, I see this often. I can't tell you how many products say "complies with ADA and ICC A117.1" that don't comply with California accessibility requirements.

 

[user_pc_9876]

Got it, thanks @arwat23 .

Anyone know the history of the "locks used only for security purposes and not used for normal operation" exception and why it may not have made it into the CBC (I can't seem to find it)?

 

[arwat23]

Anyone know the history of the "locks used only for security purposes and not used for normal operation" exception and why it may not have made it into the CBC (I can't seem to find it)?

The 2022 CBC is based off the 2021 IBC.

That exception you reference in IBC 1010.2.3 wasn't added until the 2024 IBC.

Since the state uses the 2021 IBC, it hasn't made it's way to the CBC yet. It'll likely be added in the 2025 CBC.

 

[Yikes]

Got it, thanks @arwat23 .

Anyone know the history of the "locks used only for security purposes and not used for normal operation" exception and why it may not have made it into the CBC (I can't seem to find it)?

The 2022 CBC is based off the 2021 IBC.

That exception you reference in IBC 1010.2.3 wasn't added until the 2024 IBC.

Since the state uses the 2021 IBC, it hasn't made it's way to the CBC yet. It'll likely be added in the 2025 CBC.

There is an exception in 11B-205.1 for "operable parts used only be service or maintenance personnel". The USDOJ further clarifies that "security systems" are included in the controls covered by 205.1, so therefore the exceptions would also apply to security systems, and locks are but one component of a system for security.




So the main difference between IBC 1010.2.3 and this exception #1 in 11B-205.1 is that the CBC would only allow it where it can be determined that the lock controls will be utilized solely by service or maintenance personnel. There are facilities where it is solely the job of the maintenance personnel to unlock the doors in the morning and lock them up again at night (especially with the "this door to remain unlocked during business hours" signage); likewise for operable window parts.

I have seen CASp inspections where operable windows in a public corridor had passed inspection because they had the following sign next to the window latch: "FOR USE BY AUTHORIZED MAINTENANCE PERSONNEL ONLY".

I've also seen the argument that an "authorized personnel only" component is a type of "employee workstation":


The biggest problem with this approach is that people do not always read or follow signs, or the signs often go missing after a while. Next thing you know, the project is (or is perceived to be) out of compliance due to operational policy changes.

 

[user_pc_9876]

The 2022 CBC is based off the 2021 IBC.

That exception you reference in IBC 1010.2.3 wasn't added until the 2024 IBC.

Since the state uses the 2021 IBC, it hasn't made it's way to the CBC yet. It'll likely be added in the 2025 CBC.

Got it, this makes a lot of sense. Thank you!