NOTE: My good friend Lori Greene from Ingersoll Rand Security Technologies had this comment posted on her website /blog: www.idighardware.com last August 15th, addressing the testing requirements for delayed egress locks. I know some of you readers are already subscribers of Lori’s blog and probably have already read this comment. But I thought this was such a well-researched answer by Lori, that those individuals who are not yet regular readers of ‘I Dig Hardware’ might benefit from her knowledge. It is a very relevant subject to the healthcare setting, so with Lori’s permission, I am repeating her answer to the question: “What are the testing requirements for delayed egress locks?” Brad Keyes
Testing Delayed Egress Hardware- What are the Requirements?
( by Lori Greene)
The 2009 International Building Code (IBC) doesn’t include testing guidelines in section 1008.1.9.7 Delayed Egress Locks, but that makes sense because the IBC is used during construction and not for ongoing maintenance. I checked the 2009 International Fire Code, and the section for delayed egress locks is exactly the same as the one in the IBC. But since a delayed egress lock requires immediate release upon fire alarm, I thought I might find something in Chapter 9 of the IFC – Fire Protection Systems. In the section on Testing, Inspection, and Maintenance (907.9), I found this statement: “Testing. Testing shall be performed in accordance with the schedules in NFPA 72 or more frequently where required by the fire code official.”
NFPA 72 is the National Fire Alarm and Signaling Code. There were some changes in the 2010 edition relative to this question, so I used that edition in my research. According to NFPA 72-2010, “door unlocking” falls into the category of “emergency control functions”: “Emergency control functions (i.e., fan control, smoke damper operation, elevator recall, elevator power shutdown, door holder release, shutter release, door unlocking, etc.) shall be tested by operating or simulating alarm signals. Testing frequency for emergency control functions shall be the same as the frequency required for the initiating device that activates the emergency control function.” (Table 220.127.116.11).
Here’s some related information from Annex A – Explanatory Material:
Table 18.104.22.168, Item 23. Initiating devices configured to operate an emergency control function are required to be tested per the test methods listed in Table 22.214.171.124, Item 14 and the test frequencies listed in Table 14.4.5, Item 15. Whenever an emergency control function is observed to not operate properly during a test of an emergency control function initiating device, the problem should be reported to the building owner or designated representative. The failure of the emergency control function should be reported as a possible failure of the fire safety feature and not necessarily of the fire alarm system.
Here’s what NFPA 72-2010 says in the inspection/testing section about emergency control functions:
14.2.6 Interface Equipment and Emergency Control Functions.
126.96.36.199* Testing personnel shall be qualified and experienced in the arrangement and operation of interface equipment and emergency control functions.
188.8.131.52 Testing shall be accomplished in accordance with Table 184.108.40.206.
And finally, Table 14.4.5 says that emergency control functions must be tested annually, as well as upon acceptance/reacceptance. So a delayed egress lock must be tested when it is installed, repaired, or replaced, and then annually after that. Since NFPA 72 deals with fire alarm systems, the testing requirement is probably more related to whether the fire alarm unlocks the doors, but I think it makes sense to test the 15-second release at least annually too. I don’t know of a specific requirement for testing that part of the delayed egress lock, other than the NFPA 101 – Life Safety Code requirement for certain egress doors to be inspected annually, depending on the occupancy type. Local jurisdictions may require more frequent testing / inspection, and facilities may choose to increase the required frequency of testing and establish a specific process to ensure the safety of building occupants
From a healthcare facility point of view, I think Lori nailed the issue straight on top of the head. I agree 100% with what she said and would not have anything to add to your code search.
My experience tells me that currently, few Joint Commission surveyors or CMS inspectors actually request to see documentation on testing delayed egress locks, although it is clear the 1999 edition of NFPA 72 requires testing all interface devices connected to the fire alarm control panel. In order for a delayed egress to operate correctly, it must have an interface device between the delayed egress locks and the fire alarm control panel.
I believe surveyor and inspector awareness will improve when the CMS finally adopts the 2012 edition of the LSC, as the 2010 NFPA 72 explains the testing of emergency control functions much better.
Thank you Lori, for a well thought-out answer. Brad Keyes