Multiple Delayed Egress Locks in the Path of Egress

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 7.2.1.6.1 of the 2000 and the 2012 editions of the LSC discusses the requirements you must follow to utilize delayed egress locks. Nowhere in section 7.2.1.6.1 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 18/19.2.2.2.4 of the 2000 LSC, which has Exception No. 2 which says: “Delayed-egress locks complying with 7.2.1.6.1 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 4.2.2.2 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 18/19.2.2.2.4 (2), which says: “Delayed-egress locks complying with 7.2.1.6.1 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

Testing of Delayed Egress Locks

Q.  We have delayed egress locks in our hospital and during a recent inspection a fire marshal said we had to test the locks on an annual basis. Is this true? If so, what are we supposed to be testing?

A.  Although the Life Safety Code occupancy chapters for healthcare (chapters 18 and 19) permits delayed egress locks in hospitals, section 7.2.1.6.1 explains how they need to be installed. One of the aspects of operation for the delayed egress locks is the requirement to be interfaced with the building fire alarm system or the automatic sprinkler system. The doors are required to unlock upon water-flow, or activation of a heat detector or no more than two smoke detectors. (Please note: This does not necessarily include the activation of a manual pull station.) While the LSC does not reference a specific requirement for testing the delayed egress locks, NFPA 72-1999 National Fire Alarm Code does have a written requirement for testing interface equipment. Table 7-2.2, paragraph 19 says interface equipment connections shall be tested by operating or simulating the equipment being supervised. Signals that are required to be transmitted must be verified at the control panel. Delayed egress locks are not necessarily supervised, but they do have an interface device (control relay) that unlocks the doors on a signal from the fire alarm control panel. NFPA 72 recommends the testing frequency of interface equipment to be conducted annually.

One could draw the conclusion that your delayed egress locks should be tested annually, to ensure that the power controlling the locks actually drops out upon water-flow, or activation of a heat detector, or no more than two smoke detectors.