Q: I have heard you state that once the 2012 edition of the Life Safety Code is finally adopted hospitals will be allowed to have more than one delayed egress locks in the path of egress. I understand that the 2000 LSC only allows one delayed egress lock in the path of egress, but I cannot find it written in the 2012 edition that more than one delayed egress lock is permitted in the path of egress. Can you explain this to me?
A: You won’t find it written in the 2012 LSC that more than one delayed egress locks can be used in the path of egress because it is not written in the LSC anywhere. In the world of the Life Safety Code, unless it is otherwise stated, you are permitted to do something as long as the code does not prohibit it. This concept may be contrary to some people who look to the LSC for permission to do something. But, this method of interpreting the LSC will get you in trouble if you are not familiar with the entire content of the code, because the reference that prohibits something may be located in a different chapter or section than the one you are looking at.
But, getting back to delayed egress locks: Section 18.104.22.168.1 of the 2000 and the 2012 editions of the LSC discusses the requirements you must follow to utilize delayed egress locks. Nowhere in section 22.214.171.124.1 does it prohibit more than one delayed egress locks in the path of egress. But to fully understand the issue, we must look at section 18/126.96.36.199.4 of the 2000 LSC, which has Exception No. 2 which says: “Delayed-egress locks complying with 188.8.131.52.1 shall be permitted, provided that not more than one such device is located in any egress path.”
So, there is this exception in the healthcare occupancy chapters of the 2000 LSC that limits delayed egress locks to just one in the path of egress. As section 184.108.40.206 of the 2000 LSC states, where specific requirements in the occupancy chapters differ from the general requirements contained in the core chapters, the requirements of the occupancy chapters shall govern. That is why multiple delayed egress locks are not permitted in the path of egress in a hospital.
The 2012 edition of the Life Safety Code changed all that, but not by writing something new into the code. They did it by deleting the substance of the exception that limited the number of delayed egress locks in the path of egress. Take a look at section 18/220.127.116.11.4 (2), which says: “Delayed-egress locks complying with 18.104.22.168.1 shall be permitted.” The reference that limited delayed egress locks to just one in the path of egress in healthcare occupancies was deleted.
So, that is why when the 2012 edition of the Life Safety Code is finally adopted, you will be able to have more than one delayed egress locks in the path of egress in hospitals, provided you meet all of the requirements.
If you want to start using the 2012 edition now on the issue of delayed egress locks, before the new code is adopted, CMS (and the accreditation organizations) will allow you to do so through the use of the categorical waiver, as outlined under the CMS S&C memo 13-58-LSC, issued August 30, 2013. For a full review of CMS S&C memo 13-58-LSC, click on this link: http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions.html