Outside of the healthcare setting, locks on doors are utilized nearly everywhere we go, and we don’t give it much of a thought. But in the highly regulated industry of healthcare, we must be very vigilant and astute to what the codes and standards will and will not permit. Unfortunately, locks on doors that are in the path of egress are greatly misunderstood by hospitals, and therefore are widely abused.
Ordinarily, you are not permitted to lock a door in the path of egress in a healthcare occupancy however, there are three exceptions:
- Delayed egress locks
- Access-control locks
- Clinical needs locks
Delayed egress locks are a lock when a person pushes on the horizontal crash bar of the locked door, a local buzzer will sound, and the door will automatically unlock within 15 seconds. This effectively allows a person to egress through the door, but just delays their egress, hence the name. The requirements for a delayed egress lock are:
- Delayed egress locks are only permitted in buildings which are fully protected with smoke detectors or automatic sprinklers
- The delayed egress locks must unlock upon activation of the sprinkler system or a heat detector or a smoke detector, and remain unlocked until manually reset. Notice that activation of a manual pull station is not required to unlock a delayed egress lock.
- The delayed egress locks must unlock upon loss of power to the mechanism controlling the lock
- Upon 3 seconds of activating the releasing device (horizontal crash bar) a local buzzer must actuate (to alert staff someone is attempting to exit), and within 15 seconds of activating the releasing device, the lock shall automatically unlock. The locks must reset manually, not automatically.
- The code allows for the delayed egress lock to automatically unlock within 30 seconds if approved by the AHJ, but HFAP does not approve of this option.
- A sign, in 1 inch letters, must be posted on the door which reads:
PUSH UNTIL ALARM SOUNDS
DOOR CAN BE OPENED IN 15 SECONDS
- Only one delayed egress lock may be installed in the path of egress to the public way.
These types of locks are not uncommon in hospitals, but are not used very much. The most common deficiency observed with delayed egress locks is they are installed in a building that is not 100% protected with sprinklers or smoke detectors. [Code reference: 220.127.116.11.1, 2000 edition of the LSC]
Access Control locks are very common in hospitals, and most likely are misunderstood on their correct operation by the facilities staff. An access control lock usually utilizes a magnetic lock (mag-lock) assembly, and is often integrated with the badge swipe reader to control access into a department. The requirements for an access control lock, are:
- A motion senor must be mounted on the egress side of the door, that will detect a person approaching and will automatically unlock the door in the direction of egress
- A loss of power to the device controlling power to the access control lock must unlock the doors in the direction of egress
- A manual release device must be mounted within 5 feet of the door, and between 40 to 48 inches above the floor which, when depressed, will automatically unlock the door in the direction of egress, and must be identified with a sign that reads:
PUSH TO EXIT
- When depressed, the “Push to Exit” button must directly interrupt power to the lock, independent of the access control system electronics, and the doors must remain unlocked for a minimum of 30 seconds
- Activation of the building sprinkler system or the building fire alarm system must unlock the door in the direction of egress
The most common deficiency with access control locks is the absence of the required motion sensor and/or the “Push to Exit’ button on the egress side of the door. When properly installed, access control locks are not a lock for people trying to get out of the building, but they serve as a lock on doors for people trying to get into the area controlled by the lock. [Code reference: 18.104.22.168.2, 2000 edition of the LSC]
Clinical needs locks are only permitted in healthcare occupancies (hospitals). They are not permitted in any other occupancy. These types of locks are permitted where the “clinical needs of the patients require specialized security measures for their safety, provided that staff can readily unlock such doors at all times”. Clinical needs locks are permitted for Behavioral Health units, such as psychiatric and Alzheimer units, to prevent patients from leaving the unit unauthorized, and potentially harming themselves or others. Clinical needs locks requires all staff who work on that unit (which includes physicians, nurses, aids, clerical, maintenance, foodservice, housekeeping, etc.) to have a key or device to unlock the door on their person at all times. [Code reference: 22.214.171.124.4, Exception No. 1, 2000 edition of the LSC]
Fire Alarm Connection
Delayed egress locks and access control locks are required by code to be connected to the fire alarm system and automatically unlock the door whenever there is an alarm. However, there is no such similar language for clinical needs locks to unlock on an alarm. In addition to the Life Safety Code, NFPA 72 National Fire Alarm Code, (1999 edition) section 3-9.7.1 and 3-9.7.2 says if you have a lock on an exit door it must be connected to the fire alarm system, and it must unlock the door on a fire alarm. HOWEVER, the exception to 3-9.7.2 essentially says this is not required if an AHJ says so, or if another code says so. So, we go back to the Life Safety Code, and we see that delayed egress locks and access control locks are required to unlock on an alarm, but the clinical needs locks is very silent on the subject. When a code is silent on a subject that means it permits it. Therefore, section 3-9.7 does not apply to clinical needs locks in a hospital, because the Life Safety Code permits it. The code writers understand that psych patients are smart enough to actuate a fire alarm to unlock the exit doors. Therefore, they wrote the code in such a way to not require clinical needs locks to unlock the doors in the path of egress on activation of the fire alarm system PROVIDED all staff carry a key to unlock the door in case of an emergency. That is the trade-off: They will not require the locks to unlock on a fire alarm, as long as all staff can unlock the doors in the event of an emergency.
Dead Bolt Locks
Generally speaking, dead bolt locks are not permitted on a door in the path of egress in a healthcare occupancy. The only exception would be a dead bolt lock which automatically retracts when the door handle is twisted but other than that, they are not allowed. The reason for this is the LSC only permits one releasing action to operate the door. So if a dead bolt lock is installed on a door in the path of egress and the lock is not part of the latch-set, then it would require two actions: one to unlock the dead bolt and another to turn the door handle, to operate the door. Please note that pulling or pushing is not considered one of the actions to operate the door. [Code reference: 126.96.36.199.4, 2000 edition of the LSC]