Q: Are dead-bolt locks permitted on patient room doors, to keep unauthorized people from entering the rooms? We have dead-bolt locks on the patient room doors in our behavioral health unit which can be unlocked from the corridor side with the use of a key, and the dead-bolt can be unlocked from inside the room with a thumb turn device. These locks are separate from the door latch and are mounted about 60 inches above the floor.
A: While dead-bolt locks on patient room doors that require two actions to operate the door are not permitted in most applications, dead-bolt locks for clinical needs as you described would be allowed by some authorities having jurisdiction (AHJ). Section 22.214.171.124.2 in the 2000 edition of the LSC does allow locks on patient room doors provided they are operable by staff from the corridor side and the lock does not restrict egress from the room. So far that does describe your arrangement, but we need to take a look at section 126.96.36.199.4 that describes the latch or other fastening device (i.e. the dead-bolt lock) is required to be located not less than 34 inches and not more than 48 inches above the floor, and the door must be operable with not more than one releasing operation. In your situation the dead-bolt lock that is separate from the door latch mechanism does not meet this requirement because the lock is mounted more than 48 inches above the floor.
However, the National Fire Protection Association (NFPA) Healthcare Interpretations Task Force (HITF) made an interpretation in June, 2008 that allows dead-bolt locks that require two actions to operate the door where clinical needs locks are used, which included behavioral health units. The problem with this interpretation is they did not address the dead-bolt lock that is mounted more than 48 inches above the floor, as referenced in 188.8.131.52.4. Joint Commission is on record as saying they will abide by whatever the HITF decides, but CMS does not have the same endorsement. They have said they will abide with the decisions of HITF when it is consistent with their own interpretations. In addition, there is no representation of state AHJs from the department of public health (or other similar agency) on the HITF, so each state AHJ has their own interpretation on this issue that may be different than the HITF. My advice, in order to be in compliance with door locking requirements, you will have to consider using the combination door latch / dead-bolt mechanism typically found in hotel rooms, that meets all of the requirements found in 184.108.40.206.4.