Access, Egress & Fire Door Locking/Latching Devices

The needs for building security and the requirements for life safety in a building are sometimes in conflict. This bulletin helps clarify how to achieve compliance with the B.C. Fire Code (BCFC) and the B.C. Building Code (BCBC) when addressing requirements for locks, window bars, access, and the installation of electromechanical and electromagnetic hardware on doors. A supplement to this bulletin is available for Electromagnetic Locking Devices.

In most cases, access doors may be locked to prevent entry, but must allow egress for exiting. There are some exceptions allowed in the BCBC, which will be explained below. There is an understanding that the building may be occupied at any time. Although the term “occupied” is not defined in the codes, this assumption reflects a concern for the safety of anyone unintentionally trapped in a building. For this reason, all exit doors must permit egress to the outside at any time, unless alternative measures approved/permitted by the local Building Official, are provided.

Permit Application/Installation Requirements

A specific/separate building permit, and/or an electrical permit, may be required prior to any installation/replacement of exit door hardware.  Consult your local Building Official for clarification.

The installation, replacement or alteration of hardware on new and existing exit doors must comply with the BC Fire and Building Codes. Refer to Building Code Appeal Board (BCAB) decision #1498. The following is a summary of the requirements.

Fundamental Requirements

There are three underlying requirements captured by the BCBC, all of which must be satisfied for the acceptance of locking devices.

1. Unrestricted Exiting

  • Doors with double cylinder and/or captive key locks are not permitted.
  • If a door divides a floor area, and egress is required in both directions through the door, “unrestricted exiting” is required in both directions.
  • Electromechanical devices which affect only the access side door handle (unrestricted egress) and maintain a positive latch even when unlocked (such as some electric mortise locks), are acceptable.
  • Electric operated strikes used to restrict access are considered to not restrict egress, provided a mechanical release for the door is installed on the egress side.
  • An electric operated bolt engaging a fixed receptacle (strike plate) is not permitted under any circumstance, since it may fail locked in a position which prevents egress.
  • Mag Locks - may temporarily delay egress when installed in complete conformance with the BCBC. Mag locks, which do not delay egress, may not need not comply with the BCBC. (Refer to BCAB decision #1483). Mag locks are intended for use as auxiliary locks. The combined use of a fail-secure electromechanical device and a mag lock would be required where there is a need for automatic locking security, such as in the event of a power failure and single motion egress. The use of a push-button switch is considered “specialized knowledge” and is not permitted to be the primary release of a mag lock.
  • For installations that delay egress, a push-button can be used by security personnel for operating a mag lock. In installations that do not delay egress, and where acceptable to the authority having jurisdiction, the use of other devices such as motion sensors or pressure sensitive pads maybe incorporated to facilitate unimpeded egress. However, they must be certified to a ULC standard or equivalent to ensure reliability because they are not controlled by a fire alarm system. In a fire separation, a latch and strike are required on a closure to facilitate automatic positive latching. 
  • Electric Mortise Locks - and other electromechanical devices that only affect the access side door handle and that use only mechanical means to control the latchbolt (there is no deadbolt) are permitted. The latchbolt and the egress side handle shall not be controlled by electromechanical means.
  • Electric Bolts - and other devices that restrict egress when they fail are not permitted.
  • Labeling of all hardware and electronic components used in a fire separation is required in fire separations requiring a fire protection rating.

Exceptions to Unrestricted Exiting (BCBC)

  • The BCBC address remote or locally released locking devices in a contained use area or impeded egress zone. In these circumstances, specialized knowledge or devices may be permitted because the building will be occupied by security personnel with the training to operate these specialized devices.
  • The BCBC also addresses the requirements for mag lock installations.
  • The BCBC applies to unrestricted egress doors in buildings that are fully sprinklered throughout, and identifies the criteria necessary in banks and mercantile occupancies for locked exit doors. Full compliance to all applicable sentences, as well as an active and approved Fire Safety Plan, with exiting procedures, and requirements specified for bank and mercantile occupancies with locked doors, is required.
  • The BCBC applies to unrestricted egress doors in buildings that are fully sprinklered throughout, and identifies the criteria necessary in banks and mercantile occupancies for locked exit doors. Full compliance to all applicable sentences, as well as an active Fire Safety Plan, with exiting procedures, and requirements specified for bank and mercantile occupancies with locked doors, is required.

2. Latching Maintained

  • In fire separations, a positive latch is required to hold the door in the closed position after each use. (Access control systems must not affect latching).
  • Labeled doors and frames equipped with closers help identify fire separations in existing situations.

3. Door, Frame and Hardware Labeling

  • In fire separations which have a fire-resistance rating, all parts of a closure will be labeled. This includes door, door frame, and hardware. Closures permitted to be modified must maintain their rating. Fire door hardware will normally have a fusible link incorporated in the design. See the Fusible Links bulletin for more information.
  • The door, frame and hardware must be listed for use with each other and be installed in conformance with their listing.
  • A manufacturer’s stamp on a door or frame does not confirm fire rating under the Building Code.  A label from a recognized product testing and certification agency is required on the door and frame AFTER they are machined for the hardware (i.e. “prepared” for the hardware).
  • Defective door assemblies shall be repaired/ replaced in conformance with the BC Fire Code. (For preparation of new fire rated assemblies, the labeling occurs prior to the door and frame arriving on site).
  • For preparation of existing fire rated doors and frames, the existing assembly shall be replaced with a new assembly (which is prepared and labeled before coming to the site); OR written confirmation shall be provided to the authority having jurisdiction from the fire door manufacturer, stating that the specifically named hardware installed per the manufacturer’s instructions will not void the door and/or frame label; OR the assembly may be re-labeled by a recognized product testing and certification agency.
  • When shipping the existing assembly offsite to a location that is under the label’s service for preparation, (such as the manufacturer’s location or a machinists’ or pre-hanger’s shop which is licensed to apply labels), the existing fire separation must be maintained.
  • Electric Strikes - there are restrictions for the use of electric strikes, and if used with hardware for a door located in a fire separation and the electric strike will be labeled for use in a fire separation.

Exceptions

  1. If the new hardware does not require any alteration (drilling, cutting) to the existing frame or door, the respective frame or door is not required to be re-labeled. Of course, the hardware must be listed for use in the door assembly: for example, listed for wood doors if used on wood doors and have the specific required fire rating.
  2. If the preparations are within those permitted as “job site preparation” in NFPA 80¹ and written confirmation from the fire door manufacturer is provided to the authority having jurisdiction, stating that the specifically named hardware installed per the manufacturer’s instructions will not void the label, the assembly is not required to be re-labeled.
  3. Preparation that is permitted on-site for fire rated door assemblies is only for assemblies intended to receive this preparation (hence the requirement for confirmation from the door manufacturer for existing doors and frames) as permitted in NFPA 80.

This means that, with written confirmation from the door manufacturer, surface-applied mag locks may be installed on-site without re-labeling, but recessed mag locks (or any other recessed hardware) shall have their preparation work done at a location which is under the label’s service.

¹NFPA 80 allows job site preparation for surface-applied hardware, function holes for mortise locks (for the door handles and key receptacle), holes for labeled viewers, undercutting of wood and composite doors and installation of protection plates (NFPA 80 specifies measurements). Preparation means round holes drilled through one or both faces of the door. The holes must not exceed a maximum of 2.5 cm.

Access to and through Cross-over Floors (and into Areas of Refuge)

  • Consult your local Building Official for modifications in cross-over floors.

Fire Department Access

  • Access panels or windows (as required by Building and Fire Codes) provided to facilitate access for fire fighting operations shall be maintained free of obstructions.
  • To provide Fire Department access into high-rise buildings without providing keys, one may install a wired glass panel within 300 mm of the door opening hardware. Note: if the glass panel is installed in a required fire rated door, the panel must be installed in accordance with NFPA 80 (ie: the panel may not be installed on-site).
  • Required access panels or windows are not permitted to be obstructed by window bars. An alternative is to allow window bars that are removable with the use of a key.  A tagged copy of that key shall be kept in a lock box in a location approved by the Authority Having Jurisdiction.
  • Window Bars - Although there is no standard for window bars, the BCBC identifies certain windows to be used for egress in times of emergency. For example, a bedroom window required to provide egress must release from the inside without the use of tools (keys), or specialized knowledge. If window bars are put over these windows, the bars must open from the inside as easily as the window hardware.

Other Hardware Considerations

The BCBC addresses exit requirements. Other things to consider when designing the door hardware are

  1. panic hardware requirements. Note that panic hardware in rated fire separations is required to be labelled as fire exit hardware and not just labelled as panic hardware
  2. head room clearance
  3. amount of force to open
  4. direction of the door swing
  5. no automatic locking devices on doors between residential suites and public corridors
  6. accessibility of the door opening hardware for persons with disabilities. For example, door opening hardware must be operable without tight grasping, pinching, or twisting of the wrist
  7. turn pieces which release a locking bolt on a building main entrance door or on exit doors should release the bolt with not more than a 90 degree turn
  8. although the BCBC allows another releasing device in addition to the main door release hardware of a dwelling unit, there are BCBC requirements for fire rated hardware to be used for suite doors in some multifamily dwellings. Therefore, a deadbolt lock, with a fire resistance rating, conforming to the ULC standard or equivalent, is the only recognized device allowed in addition to the main door release hardware

Access to the BCAB decisions online is available via the Office of Housing and Construction Standards.

Terminology

The following terminology used in the door hardware industry is provided for clarification.

  • Captive Key Locks are double cylinder locks that have a removable thumb turn.
  • Double Cylinder Locks are devices that require a key to unlock the device from either the egress side or the access side. This includes lockable thumb turns and locks which have no method of release from the egress side.
  • Electric Bolt is an electromechanical dead bolt, latchbolt, pin or other similar device, which retracts and /or extends electro-magnetically to lock or unlock a door.
  • Electric Mortise Lock is a recessed lock that electromechanically disables or enables the levers/knobs capability to retract the latchbolt.
  • Electric Strike is an electromechanical strike plate which can be released so that it does not retain the latchbolt in the door frame. There are two types of electric strikes, fail-secure and fail-safe.
    • Fail-Secure - If the door is pushed/pulled in the direction of swing against an electric strike that is energized (released), the keeper (or lip) part of the strike plate folds back and releases the latch, allowing the door to open. This device always provides positive latching when it is de-energized.
    • Fail-Safe - If the door is pushed/pulled in the direction of swing against an electric strike that is not energized, the keeper (or lip) part of the strike plate folds back and releases the latch, allowing the door to open.  This device does not provide positive latching when it is de-energized.
    • Both types of electric strikes are permitted where the door assembly is not in a fire separation. When a labeled electric strike is installed in a door assembly in a fire separation, the electric strike must fail-secure.
  • Electromagnetic Lock “Mag Lock” has an electromagnet body and an armature plate held together by an electromagnetic force.  There are no moving parts. (The armature plate is usually mounted on the door. A mag lock is not an electromechanical device).
  • Electromechanical Devices incorporate latches or pins and use an Electro-magnetic field to move a mechanical component. Electric strikes, and electrified hardware including knob sets, lever sets, shear locks, mortise, and panic hardware are examples of Electro­mechanical locking devices. These devices are usually available fail-secure (locked) or fail-safe (unlocked) in the event of a power failure.
  • Electromechanical Releasing Devices use a mechanical action to release an electrically activated component which is integrated into the mechanical portion of the device. Pressure sensitive pads, door paddles, touch bars, pushbuttons, and micro-switch equipped panic hardware are examples of electromechanical releasing devices. These devices are available in Normally-Closed (circuit opens on activation) or Normally-Open (circuit closes on activation) configuration, or they may be configured as a combination of both (one circuit opens and one circuit closes on activation).
  • Labeled means equipment or materials to which has been attached a label, symbol, or other identifying mark of a recognized testing facility that is responsible for product evaluation/testing in Canada.
  • Mortise means fully recessed. A mortised device is flush mounted or concealed.
  • Strike Plate is a plate on a door frame with a cut-out that receives the door latch when the door is closed.
  • Window Bars are fixed and or movable screens or partitions, such as grills, mesh, posts, lattice, or sheeting, and may be fabricated out of materials such as metal, wood, or plastic. Window bars create an obstruction of an opening when installed.