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Playground Egresses in a School Courtyard

sutefamily

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Joined
Apr 15, 2024
Messages
1
Location
Michigan
I am interested in finding out about the egress code for a school playground that is in a courtyard, surrounded on three sides by the school and the 4th side by a 6 foot high fence. We recently had our policy changed so that all of the doors that exit from the playground back into the school remain locked from the inside at all times. Just one door is accessible from the playground by a key card system. The 6 foot fence has 2 gates that remain padlocked at all times.

The public school houses all children under the age of 4 and is a licensed childcare center in Michigan. They are responsible for following Michigan childcare code as well as any public school or other codes, as far as I know.

My concern stems from the fact that if there is a fire, or active shooter at the only means of egress from the playground (the one door that is accessible with the key card) then we would be trapped on the playground with no means of escape. If the staff happens to forget the keycard, there is literaly no means of egress.

Is it legal for all means of egress to be locked like this? I have attached a diagram of the courtyard here.
 

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1. Is the playground used as a means of egress path from the adjacent buildings? If there is a fire in those buildings, is the approved exit strategy to go out onto the playground?
2. If #1 is “yes”, then what are the dimensions of the playground? In that scenario, people need to be at least 50’ away from the buildings on fire if they are not otherwise allowed to egress to the street.
3. Is the playground used for assembly purposes?

At this time, the IBC is mainly concerned with fire/life safety. It does not necessarily consider active shooter situations. Except for “I” (institutional) occupancies where occupants are restrained against their own volition, it generally does not contemplate locked exits.
If you have card readers and electric locks, check and see if they can be tied into a central system that can remotely unlock them in an emergency.
 
Please also check out this guide prepared by the state architect here in California. Not sure if Michigan has something similar:

1713297214771.png
If would appear that Michigan is on an older code than the 2018 IBC.

Here's 2019 CBC, based on the 2018 IBC:

1010.1.11 Group E Lockable Doors From the Inside​


New buildings that are included in public schools (kindergarten through 12th grade) state funded projects and receiving state funding pursuant to Leroy F. Green, School Facilities Act of 1998, California Education Code Sections 17070.10 through 17079, and that are submitted to the Division of the State Architect for plan review after July 1, 2011 in accordance with Education Code 17075.50, shall include locks that allow doors to classrooms and any room with an occupancy of five or more persons to be locked from the inside. The locks shall conform to the specification and requirements found in Section 1010.1.9

Exceptions:
  1. Doors that are locked from the outside at all times such as, but not limited to, janitor's closet, electrical room, storage room, boiler room, elevator equipment room and pupil restroom.
  2. Reconstruction projects that utilize original plans in accordance with California Administrative Code, Section 4-314.
  3. Existing relocatable buildings that are relocated within same site in accordance with California Administrative Code, Section 4-314.
 
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At this time, the IBC is mainly concerned with fire/life safety. It does not necessarily consider active shooter situations. Except for “I” (institutional) occupancies where occupants are restrained against their own volition, it generally does not contemplate locked exits.
If you have card readers and electric locks, check and see if they can be tied into a central system that can remotely unlock them in an emergency.

In fact, except for specific I occupancies the IBC clearly states that all means of egress must be unlocked from the egress side at all times a building is occupied. (Limited exception for delayed egress devices.) While the building code hasn't done much (as yet) about events such as active shooter situations, I can't imagine how a building code would address that. I'm old enough that when I went to grammar and high school all we had was fire drills, when the goal was to get everyone OUT of the building and a safe distance away from it.

Now kids also have to worry about active shooters and shelter-in-place drills. In fact, the town where I work had such a drill for town employees last year. Mock shooter with a nerf gun. I'm dead -- I got caught in a corridor. But the basic principles in the building code don't change. In an active shooter situation, there's no need or reason to lock doors against egress -- the goal is to prevent INGRESS. The industry responded over twenty years ago with a new classroom lock function that allows teachers to lock classroom doors without having to enter the corridor, and then with electronic, central locking systems.

To evaluate the situation in this question, we need to know a lot more about the building, the courtyard, egress plans for the facility, and whether or not there are firewalls.
 
The problem with a playground situation is a kid running out of the normally egress gate.

I had an after-school daycare project where that happened - -kid almost got hit by a car.
Even if they don't get hit, if they run down the road, what is the daycare supervisor supposed to do: leave the 99 unsupervised to find the one lost sheep?
 
Please also check out this guide prepared by the state architect here in California. Not sure if Michigan has something similar:

If would appear that Michigan is on an older code than the 2018 IBC.

Here's 2019 CBC, based on the 2018 IBC:

1010.1.11 Group E Lockable Doors From the Inside​


New buildings that are included in public schools (kindergarten through 12th grade) state funded projects and receiving state funding pursuant to Leroy F. Green, School Facilities Act of 1998, California Education Code Sections 17070.10 through 17079, and that are submitted to the Division of the State Architect for plan review after July 1, 2011 in accordance with Education Code 17075.50, shall include locks that allow doors to classrooms and any room with an occupancy of five or more persons to be locked from the inside. The locks shall conform to the specification and requirements found in Section 1010.1.9

Exceptions:
  1. Doors that are locked from the outside at all times such as, but not limited to, janitor's closet, electrical room, storage room, boiler room, elevator equipment room and pupil restroom.
  2. Reconstruction projects that utilize original plans in accordance with California Administrative Code, Section 4-314.
  3. Existing relocatable buildings that are relocated within same site in accordance with California Administrative Code, Section 4-314.

This doesn't mean the doors can be locked so that egress isn't possible.

The traditional "Classroom" lock function for classroom doors only had a keyway on the corridor side. A teacher would unlock his/her classroom door in the morning, and the door remained unlocked until the teacher locked it again -- with the key -- from the corridor side. Even if it was locked, it was only locked on the corridor side; the lock always allowed egress from the classroom side.

In the aftermath of the Columbine school shooting, it was recognized that forcing a teacher to go out in the corridor to lock their classroom door wasn't a great idea if there was a shooter prowling the corridors. So the hardware industry added a keyway on the classroom side of classroom locks, and the new function is now standardized as the "Classroom Security" lock function. This allows a teacher to lock the door from inside the classroom, without having to open the door or step into the corridor. BUT ... even when locked, egress is always possible from the classroom side; it only locks the outside knob/lever.

The code section above doesn't allow classrooms to be locked against egress. It mandates when the classroom security lock function must be used.

 
he public school houses all children under the age of 4 and is a licensed childcare center in Michigan.
Probably functions as an I-4 under the code and not an E occupancy. Therefore I think a delayed locking system would work for the padlocked gates.

Something like this would prevent the door from being opened from outside the fence.

1713361507295.png
 
I am interested in finding out about the egress code for a school playground that is in a courtyard, surrounded on three sides by the school and the 4th side by a 6 foot high fence. We recently had our policy changed so that all of the doors that exit from the playground back into the school remain locked from the inside at all times. Just one door is accessible from the playground by a key card system. The 6 foot fence has 2 gates that remain padlocked at all times.

The public school houses all children under the age of 4 and is a licensed childcare center in Michigan. They are responsible for following Michigan childcare code as well as any public school or other codes, as far as I know.

My concern stems from the fact that if there is a fire, or active shooter at the only means of egress from the playground (the one door that is accessible with the key card) then we would be trapped on the playground with no means of escape. If the staff happens to forget the keycard, there is literaly no means of egress.

Is it legal for all means of egress to be locked like this? I have attached a diagram of the courtyard here.
As others have noted, the building code doesn't address active shooter scenarios. Generally, once you're out of the building, they don't want you to re-enter if there's a fire, etc. Picture a typical door with panic hardware. You usually can't go back in once you've left. If this was a standalone playground it could be treated like outdoor concerts, festivals, etc are treated. I believe there's an NFPA standard for setting occupant loads and egress for outdoor venues, mainly for the purpose of first responders being able to access someone who might be having a medical issue. I can't remember if it was in NFPA 101 or if they have a stand-alone standard. There might be something in there that addresses your situation.
 
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