Mar 25 2016

Fire Alarm System in a Business Occupancy?

Category: BlogBKeyes @ 12:00 am
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Q: We have a physician practice that currently has fire extinguishers and a “panic button” that contacts 911. We do not have fire alarms, smoke detectors or a sprinkler system. Are we required to have any of those in the practice?

A: The answer is… maybe yes and maybe no. Sorry; that’s not much of an answer, but not all offsite small business occupancies actually require a fire alarm system.

If the physician practice is truly a business occupancy, meaning there is no procedures being conducted where patients are rendered incapable of self-preservation, then section 39.3.4.1 of the 2000 Life Safety Code says this for existing conditions:

A fire alarm system in accordance with section 9.6 shall be provided in any business occupancy where any one of the following conditions exists:

  • The building is two or more stories in height above the level of exit discharge
  • The occupancy is subject to 100 or more occupants above or below the level of exit discharge
  • The occupancy is subject to 1,000 or more total occupants.

For new construction in business occupancies (meaning new construction or renovation documents approved by local authorities after March 11, 2003), section 38.3.4.1 of the 2000 Life Safety Code says this:

A fire alarm system in accordance with section 9.6 shall be provided in any business occupancy where any one of the following conditions exists: 

  • The building is two or more stories in height above the level of exit discharge
  • The occupancy is subject to 50 or more occupants above or below the level of exit discharge
  • The occupancy is subject to 300 or more total occupants.

 

The occupant capacity is calculated by taking the total gross area of the floor (or building) in square feet, and dividing it by 100 square feet per person. So, a 5,000 square foot story would have an occupant load of 50 persons.

So, as you can see, if the physician practice is a business occupancy and meets the requirements for a new or existing occupancy, then a fire alarm system is not required, according to the Life Safety Code.

Sprinkler systems are not required in business occupancies, whether they are new construction or existing construction.

Now, there may be other codes or standards that you need to comply with, so please check with your local and state authorities to determine what their requirements are.

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Jan 15 2016

Visual Inspection of Fire Alarm Devices

Category: BlogBKeyes @ 12:00 am
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Q: A question came up recently on the NFPA 72 semi-annual visual inspections required for fire alarm system devices. Would the printed records from an intelligent fire alarm system suffice for the visual inspections on devices such as smoke detectors, pull stations and heat detectors?

A: I would say no, the printed records from an intelligent fire alarm system would not suffice for a visual inspection on the fire alarm system devices. Items such as the following must be visually inspected twice a year on a semi-annual basis:

Initiating Devices

  1. Duct Detectors
  2. Electromechanical Releasing Devices
  3. Fire-Extinguishing System(s) or Suppression

System(s) Switches

  1. Fire Alarm Boxes
  2. Heat Detectors
  3. Radiant Energy Fire Detectors
  4. Smoke Detectors

The reasoning for this decision is found in the NFPA 72 handbook, which states: “The visual inspection is made to ensure that there are no changes that effect equipment performance. Equipment performance can be affected by building modifications, occupancy changes, changes in environmental conditions, device location, physical obstructions, device orientation, physical damage, improper installation, degree of cleanliness, or other obvious problems that might not be indicated through electrical supervision.”

It is not uncommon to find ancillary hospital equipment placed or installed in such a way as to affect or obstruct the normal operation of some of these devices. Semi-annual visual inspections will find these issues before they affect the performance of the fire alarm system.

Generally speaking, the printed records from an intelligent fire alarm system would only suffice for documentation on the 2-year sensitivity testing requirement. Everything else would have to be confirmed through direct observation.

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Jan 01 2016

Visual Inspection of Fire Alarm Devices

Category: BlogBKeyes @ 12:00 am
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Q: A question came up recently on the NFPA 72 semi-annual visual inspections required for fire alarm system devices. Would the printed records from an intelligent fire alarm system suffice for the visual inspections on devices such as smoke detectors, pull stations and heat detectors?

A: I would say no, the printed records from an intelligent fire alarm system would not suffice for a visual inspection on the fire alarm system devices. Items such as the following must be visually inspected twice a year on a semi-annual basis:

Initiating Devices

  1. Duct Detectors
  2. Electromechanical Releasing Devices
  3. Fire-Extinguishing System(s) or Suppression

System(s) Switches

  1. Fire Alarm Boxes
  2. Heat Detectors
  3. Radiant Energy Fire Detectors
  4. Smoke Detectors

The reasoning for this decision is found in the NFPA 72 handbook, which states: “The visual inspection is made to ensure that there are no changes that effect equipment performance. Equipment performance can be affected by building modifications, occupancy changes, changes in environmental conditions, device location, physical obstructions, device orientation, physical damage, improper installation, degree of cleanliness, or other obvious problems that might not be indicated through electrical supervision.”

It is not uncommon to find ancillary hospital equipment placed or installed in such a way as to affect or obstruct the normal operation of some of these devices. Semi-annual visual inspections will find these issues before they affect the performance of the fire alarm system.

Generally speaking, the printed records from an intelligent fire alarm system would only suffice for documentation on the 2-year sensitivity testing requirement. Everything else would have to be confirmed through direct observation.

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Sep 23 2015

Heat Detector Spacing From an Air Diffuser

Category: BlogBKeyes @ 12:00 am
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Heat Detector imagesALEXIFM2A reader recently asked me where in NFPA 72 does it say that heat detectors have to be a minimum of 36 inches away from an air diffuser. He could not find the standard reference and asked if I could point him in the right direction.

Well…. I think he had a point, since there is no requirement in NFPA 72 that says heat detectors have to be 36 inches away from air diffusers. Section 2-3.5.1 and section A-2-3.5.1 of NFPA 72-1999 says spacing for detectors from air diffusers (supply and return) must be 3 feet. This section (NFPA 72 2-3) is referring specifically to smoke detectors, and section NFPA 72 2-2 refers specifically to heat detectors and there is no similar language in section 2-2 concerning minimum distance from air diffusers for heat detectors.

Therefore, one can conclude that heat detectors do not have to comply with the 3 foot spacing from air diffusers like smoke detectors. But that is not how all of the AHJs interpret this. The actual spacing (3 feet) for smoke detectors is found in the Annex section of the standard which is explanatory information and not part of the enforceable standard. But AHJs are free to use this information in the Annex section in determining compliance with the standard. Therefore, AHJs can interpret this section how they want, and many of the AHJs interpret that you need to maintain 3 feet from air diffusers for both smoke and heat detectors.

If you get cited, you can fight the finding by pointing out the reference in the Annex section is only for smoke detectors, but ultimately the AHJs get to interpret this the way they want, and you may end up losing anyway.

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Feb 26 2015

Expert Witness

Category: BlogBKeyes @ 5:00 am
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imagesXLH1EQVPI received a telephone call recently from a lawyer that asked me if I would be willing to serve as an expert witness in a pending litigation suit. The situation of the lawsuit is a patient who was admitted to the inpatient psychiatric unit of a hospital busted the protective cover over the fire alarm manual pull station, and activated the fire alarm system. The entrance doors to the psychiatric unit unlocked on the fire alarm, and the patient ran out, climbed to the roof of the facility and jumped off.

Now the family of the patient is suing the hospital and the fire alarm company who installed the interface between the door locks and the fire alarm system. The plaintiff’s lawyer is arguing that the interface should never have been installed and the doors should not have unlocked upon activation of the fire alarm system. I agree with the plaintiff’s lawyer, but the problem is, it was the defense’s lawyer who contacted me.

The two major codes and standards that apply in this situation are the NFPA 72 National Fire Alarm Code (1999 edition), and the NFPA 101 Life Safety Code (2000 edition). The Life Safety Code (LSC) allows clinical needs locks on doors in the path of egress, but only 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: 19.2.2.2.4, Exception No. 1, 2000 edition of the LSC].

But when it comes to connecting those clinical needs locks to the fire alarm system so they automatically unlock on a fire alarm activation, the codes are not so clear. Other permissible locks, such as 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, NFPA 72 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 section on clinical needs locks is very silent on the subject. When a code is silent on a subject that means it is open for interpretation. Therefore, section 3-9.7 of NFPA 72 does not apply to clinical needs locks in a hospital, because the interpretation Life Safety Code permits it. It is documented that psychiatric patients are astute enough to actuate a fire alarm to unlock the exit doors. Therefore, the code is available to be interpreted 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.

But who makes that interpretation? Usually the authorities having jurisdiction (AHJ) makes that interpretation. Section 4.6.1.1 of the 2000 LSC says the AHJ shall determine whether the provisions of the LSC are met. But when the AHJ does not issue an interpretation, then it is up to the individual organization’s to decide. As far as I know, there is no national AHJ for healthcare that has it written in their standards that clinical needs locks should not be connected to the fire alarm system. Therefore, the hospital needs to ask the question: Based on the potential risk to patient safety, is it best to connect the door locks on the psychiatric unit to the fire alarm system so they unlock upon activation of the fire alarm system?

I declined the offer to be an expert witness for the defense, and suggested they settle the lawsuit out of court.

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Oct 16 2014

Fire Alarm System Interface Relays

Category: BlogBKeyes @ 6:00 am
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Fire Alarm Interface RelayOut of sight is out of mind. It is the master illusionist’s greatest asset. He gets you looking at something that is distracting your attention away from the object at hand, and before you know it he makes it seem that through a magical intervention, something appears. Or disappears. Or… whatever. The point is, while your attention is located elsewhere, something else happened that you did not notice.

When I was a kid they called that a trick. Actually, it still is a trick, but now they call it something else, like an illusion. Harry Houdini was first called a magician before he was called an escape artist. But I don’t remember seeing anything in print where they called him an illusionist. The word “illusionist” sounds so much nicer and professional for today’s environment than “magician”. But, I digress… That seems to have very little to do with what I want to share today.

A review of the survey deficiency reports indicates surveyors are looking for documentation that the hospital has tested the interface relays and modules on the fire alarm system. I guess that’s the bridge between the illusions and the interface relays: You can’t see them. The interface relays are “out-of-sight and out-of-mind”. If you can’t see them, you tend to forget they are there, and then they are not included in the fire alarm testing report.

Many facility managers rely on the fire alarm contractor to provide a complete test report without actually checking what was tested. This is a grave mistake. No offense to fire alarm testing contractors, but you should never rely on their advice or opinion on the level of testing. You (as the facility manager) have to be smarter than the fire alarm testing contractor to ensure they did everything correctly. They don’t necessarily know what codes and standards (or what editions) you need to comply with, but you should know. That makes you the expert.

Not long ago I was consulting in a hospital and reviewing their fire alarm test report. The report failed to indicate that they tested their interface relays. I asked the facility manager about it and he called the sales representative from the fire alarm testing contractor who happened to be nearby. He stopped in while I was there and I asked him why they did not test the interface relays. He said he knew they were supposed to be tested, but told me (and this is a direct quote): “The hospital would not let me test them”. This surprised the facility manager and myself, and the sales rep explained further.

“We had to bid our services to the hospital based on a request for proposal. Nothing in the request indicated that the interface relays were included. We submitted a bid strictly based on what was requested in the proposal. Had we added anything that was not requested, we would not have been awarded with the contract.”

Some would say that the fire alarm testing contractor was unethical for not informing the hospital of all the items that needed to be tested that were not included in the RFP. I don’t know if that is unethical or not, but I will tell you this: That hospital got exactly what it asked for in the RFP. Unfortunately.

So, back to the point: Get those fire alarm interface relays included in the fire alarm testing process and document each one individually, with a “Pass” or a “Fail” notation. Here is a list of the most common interface relays used in hospital fire alarm systems:

  • Magnetic hold-open devices
  • Air handler shutdown
  • Kitchen hood suppression system
  • Elevator recall
  • Magnetic locks
  • Fire pump
  • Smoke dampers
  • Clean agent suppression systems
  • Sprinkler dry pipe/pre-action systems
  • Overhead rolling fire doors

Take a look at your latest fire alarm test report. Does it include interface relays? If not… better get on the phone to the company or individual conducting the testing for you.

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May 15 2014

Fire Alarm Test Reports

Category: BlogBKeyes @ 5:00 am
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fire-alarm-system-detects-protects-24-x-7-250x250[1]Fire alarm test reports are the number one item that surveyors look at during the document review session. It is also the number one document that draws the most findings and citations, mainly because there are so many devices connected to the fire alarm system. A typical 200 bed hospital may have over 2,000 devices connected to the fire alarm system that need to be tested.

Nearly all of the requirements for the frequency of the tests performed on fire alarm systems can be found under NFPA 72 (1999 edition), section 7-3.2. The one exception would be the requirement for the water-flow switch testing which is found under NFPA 25 (1998 edition), section 2-3.3. (NOTE: This does not take into consideration the recent CMS categorical waivers.)

Often times a contractor performing the fire alarm testing will not test all of the devices listed below, even if your hospital has them in your system. The reasons may differ but the bottom line is the hospital facility manager must review the contract and determine what is actually required. Many times the standard contract (or signed proposal) will state something to the effect the fire alarm system will be tested in accordance with NFPA 72, although it doesn’t always refer to the proper edition (most hospitals are on the 1999 edition of NFPA 72). If the contract says it will test to NFPA 72, then you must hold them accountable for testing everything on the list below.

Make sure the test report lists the complete inventory of each and every device connected to the fire alarm system. All of the initiating devices, all of the occupant notification devices and all of the interface relays must be listed in an inventory complete with their location and whether they passed or failed their test. And don’t forget all of the batteries in the fire alarm system, not just those in the fire alarm control panel. There may be other batteries involved such as those in a remote panel or a Notification Appliance Circuit (NAC) extender panel.

Here is a list of devices that could be connected to the typical fire alarm system in a hospital:

Device/Test

Frequency

Initiating   Devices

Water-flow switches

Quarterly

Smoke detectors

Annually

Heat detectors

Annually

Duct detectors

Annually

Manual pull stations

Annually

Supervisory   Signal Devices

Low air pressure switches

Quarterly

Low water level switches

Quarterly

Tamper switches

Semi-annually

Notification   Devices

Strobes

Annually

Horns

Annually

Bells

Annually

Chimes

Annually

Interface   relays and modules

Magnetic hold-open

Annually

Air handler shut-down

Annually

Kitchen hood suppression sys

Annually

Elevator recall

Annually

Magnetic locks

Annually

Fire pump

Annually

Smoke dampers

Annually

CO2/Clean agent suppression

Annually

Sprinkler dry-pipe/pre-action

Annually

Overhead rolling fire doors

Annually

Control   panel batteries

Charger test

Annually

Discharge test

Annually

Load voltage test

Semi-annually

Smoke   detector sensitivity test

2-years

Off-premises   monitoring transmission equipment

Quarterly

Here are some basic requirements about the fire alarm test report:

  • Make sure the report is dated and signed by the service technician and you (the owner’s representative)
  • Make sure all the devices connected to the fire alarm system are accounted for and inventoried in the report
  • Make sure resettable heat detectors are ‘tested’ rather than ‘inspected’. Lazy technicians may not want to get out the hot-air guns to test the heat detectors so they just ‘inspect’ them
  • Make sure the heat detectors are tested with heat, and not with magnets. Only the one-shot non-resettable heat detectors are permitted to be tested with magnets.
  • When items on the report are identified as having ‘failed’ their test, make sure there is follow-up action to resolve the issue
  • Don’t forget to assesse the failed devices for Interim Life Safety Measures (ILSM)
  • Resolve all deficiencies and staple copies of the paperwork that demonstrates the repair was completed, along with a re-test, to the test report
  • Ensure that the technician performing the fire alarm testing, service and repairs meets the qualifications for certification or licensing. This applies to in-house staff or contracted staff. Have the qualifying documents on file.

Maintain your fire alarm test report at this level of documentation and you should not have any troubles with the surveyors.

 

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Mar 13 2014

Fire Alarm Monitoring of the Generator

Category: BlogBKeyes @ 6:00 am
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imagesFWTL2IM2Does your fire alarm system monitor the emergency power generator? It may have to. Section 1-5.8.7 of NFPA 72 (1999) requires the fire alarm system to monitor the primary and secondary power supplies for the presence of voltage at the point of connection to the fire alarm system. Failure to monitor either connected power supply should result in a ‘Trouble’ signal. Under normal power conditions, the emergency power from the generator is not connected, and therefore is not monitored. But when the emergency power is connected, it must be monitored, according to NFPA 72. However, there is an exception to 1-5.8.7 that says:

“The power supply of an engine-driven generator that is part of the secondary power supply, provided the generator is tested weekly in accordance with chapter 7”.

So, that means if the generator is tested weekly, then the generator is not required to be monitored. But Table 7-3.2 of NFPA 72 (1999) says engine driven generators must be tested monthly, not weekly. So is this a conflict in the standard? I looked at the 2010 edition of NFPA 72, and apparently the technical committee thought it was, as they corrected their table (Table 14.4.5 which is comparable to Table 7-3.2 of the 1999 edition) which now says the generator must be tested weekly, and Table 14.4.2.2 (of the 2010 edition) on Test Methods, says the test must be in accordance with NFPA 110.

But NFPA 110 does not require weekly operational tests, only weekly inspections. They do require monthly tests of the generators. Again, is this another conflict? Perhaps not, as the frequency of the generator test (weekly) is determined by NFPA 72, but the methods and parameters of the test are determined by NFPA 110.

This is what is apparent to me: NFPA 72 requires the fire alarm system to monitor the voltage at the point of connection on both primary and secondary power supplies. The exception to this requirement for monitoring is if the generator is being tested weekly, but not many organizations are testing their generators weekly. If you are not testing the generators weekly, then make sure your fire alarm system is monitoring the voltage output of the generators when they are connected to the fire alarm system.

Is any national AHJ currently enforcing this issue at the moment? I am not aware that any of them are, but it is a NFPA requirement and healthcare organizations are required to be compliant with all NFPA standards referenced by the Life Safety Code. Better to be on top of this and have your fire alarm system compliant before one of the AHJs asks to see your documentation.

 

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Sep 12 2013

Standy Power Source for Fire Alarm Systems

Category: BlogBKeyes @ 5:00 am
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imagesCAGH53PCFor obvious reasons, fire alarm systems are required to have two sources of electrical power sources according to NFPA 72 (1999 edition), section 1-5.2; a reliable primary source and a standby secondary source. There is an exception to this requirement for two sources, where the primary source is connected to an emergency power system where a person specifically trained in its’ operation is on duty at all times. This could be an emergency power generator used to deliver the primary power full time such as co-generation with the commercial utility company.

Where a standby power supply is provided, it is required to provide power to the fire alarm system for a minimum of 24 hours when the fire alarm system is functioning in a non-alarm condition. At the end of the 24 hour period, the standby power supply must provide power to the fire alarm system operating in emergency mode for 2 hours, and the notification appliances (strobes, horns, chimes, etc.) for 15 minutes.

You can use batteries to meet this 26 hour power supply requirement, or you can use the emergency power generator, life safety branch already provided in your hospital or nursing home. If you choose to use the emergency generator power as your standby source, then you must have batteries that are capable of operating the fire alarm system in a non-alarm condition for four (4) hours, then operate the system in an emergency mode for 15 minutes.

That is why you may observe smaller batteries in the hospital fire alarm control panel as compared to the batteries in a non-healthcare occupancy location, such as a clinic or office building. Those batteries would have to be sized to operate the fire alarm system for 26 hours, as compared to the 4 hours if the system had emergency generator power as a standby source.

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Apr 18 2013

Door Locks in Healthcare Occupancies

Category: BlogBKeyes @ 6:00 am
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exit_mag_lock_hospital_10662932[1]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

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: 7.2.1.6.1, 2000 edition of the LSC]

 Access Control

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: 7.2.1.6.2, 2000 edition of the LSC]

 Clinical Needs

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: 19.2.2.2.4, 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: 7.2.1.5.4, 2000 edition of the LSC]

 

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