# Need input on IBC 2018 1010.1.4.3 and locks as per 1010.1.9.4



## Leo Taylor (Apr 7, 2020)

We have a grocery store as a client who has sliding front doors at the entrance.  Typical operations is to unlock the doors with a key or a thumb turn which is located on the inside.  Section 1010.1.4.3 allows for these doors in all types of applications but we typically see them on grocery stores.  All over the country we see these doors locked at night when the store closes.  Most locations lock them by either a thumb turn or a key cylinder on the inside. It is really up to the AHJ which they prefer.  Some prefer the thumb turn so the doors can be unlocked whenever needed, others want a key turn so the doors can't be easily locked during business hours. 

At the moment, we have one Fire Marshal who is following 1010.1.9.4 to an extreme.  Basically they way they read the code is that no door can be locked when the building is occupied which means after close of business and while employees are inside stocking shelves or cleaning up.  That is code section 1010.1.9.4 section 2.2  with the part "This door to remain unlocked when this space is occupied"  This code is referring the "main" doors.  So, now the grocery store is stuck between a rock and a hard place.  How can they keep the building secure when closed for business?

The other issue the client has is that the fire marshal allowed them to lock the doors as long as they used a specially designed lever instead of a thumb turn or a key cylinder. Even that had issues as the Fire marshal wanted it to operate a certain way, and no one makes a product to work the way want. EG. The fire marshal wanted it to operate with only 90 degrees of rotation. Due to the current design the locks can be operated by a lever with 180 rotation or 360 with a thumb turn that takes wrist turning action.  So, at the moment this client is getting frustrated as they appear to be the only company being put through this strict set of rules. The Malls and other group M stores in the area don't have to have this for some reason. We are trying to determine why.  

 Our company has worked on a lot of storefront doors and have never seen this kind of restriction. For now it seems the choices comes down to never locking the door, or using specialty hardware that does not exist or is prone to failure. (The levers that have been installed break a lot)  The other issue, and I just learned this today, is that none of this is in writing. It is via emails to the store telling them to call the fire marshal, who then tells them what to do without putting it in writing.  That's when we get the call. 

Is anyone familiar enough with storefront sliding doors, adams rite locks, break-way panels, and the code to know what kind of push back we can give to this inspector?  In one way of reading the code, the inspector is correct, but something must be off because very few stores in the US leave their main doors unlocked when the building is occupied by the night crews, and very few use special lever locks rather than thumb turns and/or keys.

Here is a link to the lever

https://www.adamsrite.com/en/products/trim/4550-ms-deadlock-lever/


 and here is a link with a picture of the type of door.

https://www.pinterest.com/pin/455848793505317472/?autologin=true


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## cda (Apr 7, 2020)

Welcome Leo

Hope Wa. is recovering


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## RLGA (Apr 7, 2020)

What is the occupant load when it's only employees in the building? If there are still two exits that meet all the requirements, then the sliding doors are irrelevant. If there is one door, the occupant load is less than50, and the travel distance to the one door is 75 feet or less, then having the sliding doors are also irrelevant.


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## cda (Apr 7, 2020)

Suggest you email your entire question to this person::;


https://idighardware.com/about-2/

Email is about half way down. She is our door guru


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## cda (Apr 7, 2020)

Ok my take

Inspector should and is supposed to put it in writing.

One option turn power off, and employees can still get out.

Yes exits are required to be one operation and get out... the sign is only required when there is a key cylinder on the inside.

If there is no local code change a thumb turn should be allowed, and not “this is the one I want”

If there are other exits, easy to get to, not storeroom, the employees can use those.

How about the key left in door, I don’t like it and I would not suggest it to a store.


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## cda (Apr 7, 2020)

Yep a little hard to balance code and security


a little reading

https://idighardware.com/2018/08/decoded-deadbolts-in-a-means-of-egress-october-2018/


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## cda (Apr 7, 2020)

This is out of NFPA 101

You can try to argue it:::


7.2.1.1.3 Occupied Building.
7.2.1.1.3.1 
For the purposes of Section 7.2, a *building shall be considered to be occupied* at any time it meets any of the following criteria:


(1)
It is open for general occupancy.


(2)
It is open to the public.
*
*
* 
(3)

It is occupied by more than 10 person*s.


7.2.1.1.3.2 
Where means of egress doors are locked in a building that is not considered occupied, occupants shall not be locked beyond their control in buildings or building spaces, except for lockups in accordance with 22.4.5 and 23.4.5, detention and correctional occupancies, and health care occupancies.

Many industrial, storage, and business occupancy buildings are never open to or accessible to the public; the only occupants are employees and authorized visitors. Therefore, the term _occupied_ in 7.2.1.1.3.1 also includes the condition of being open for general occupancy. That is, the facility is _operating_ or_functioning_.

The intent of permitting a building with 10 or fewer occupants to be considered unoccupied — if it is not open for general occupancy and not open to the public — is to allow small security details or small cleaning crews inside a building without applying all the _Code_ requirements. This will allow door assemblies to be locked and lights to be turned off without violating the _Code_. The limited number of occupants will use lights as they need them and then turn them off. In the case of security personnel, they will carry their own lights and keys. For example, see the criterion of 7.2.1.5.5.1(4) for making a key available to occupants, which is applicable to a special type of key-operated dead bolt lock.

The wording of 7.2.1.1.3.2 reiterates that it is not the intent to allow people, no matter how few the number, to be locked in a building without a ready means of egress. Even in detention and correctional facilities, where locked door assemblies are permitted, 24-hour staffing must be provided in sufficient numbers to start the release of locks necessary for emergency evacuation or rescue and initiate other necessary emergency actions within 2 minutes of alarm. See 22.7.1.1(2) and 23.7.1.1(2).


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## cda (Apr 7, 2020)

Option, costs money, Maybe do one door???




*1010.1.4.4 Security Grilles*

In Groups B, F, M and S, horizontal sliding or vertical security grilles are permitted at the main _exit _and shall be openable from the inside without the use of a key or special knowledge or effort during periods that the space is occupied. The grilles shall remain secured in the full-open position during the period of occupancy by the general public. Where two or more _means of egress _are required, not more than one-half of the _exits _or _exit access doorways _shall be equipped with horizontal sliding or vertical security grilles.


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## steveray (Apr 8, 2020)

I think Ron is on the correct track as far as working with the FM....If your OL is handled with the "other" exits, show that.....CDA has a good point with the <10 OL per 101 also, but getting the code section form the FM in a nice and respectful way is essential to compliance. I do not think there is any section that speaks to that type of lock functioning , so I would certainly push back on that....


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## cda (Apr 8, 2020)

steveray said:


> I think Ron is on the correct track as far as working with the FM....If your OL is handled with the "other" exits, show that.....CDA has a good point with the <10 OL per 101 also, but getting the code section form the FM in a nice and respectful way is essential to compliance. I do not think there is any section that speaks to that type of lock functioning , so I would certainly push back on that....




Problem  is the FM is right in away, IBC has no allowance for securing *certain type* doors, with people in the building

Kind of stuck with 

*1010.1.9 Door Operations*

Except as specifically permitted by this section, egress doors shall be readily openable from the egress side without the use of a key or special knowledge or effort.



AND


*1010.1.9.5 Unlatching*

The unlatching of any door or leaf shall not require more than one operation.


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## ICE (Apr 8, 2020)

Leo Taylor said:


> At the moment, we have one Fire Marshal who is following 1010.1.9.4 to an extreme.  Basically they way they read the code is that no door can be locked when the building is occupied which means after close of business and while employees are inside stocking shelves or cleaning up.  That is code section 1010.1.9.4 section 2.2  with the part "*This door to remain unlocked when this space is occupied*"  This code is referring the "main" doors.  So, now the grocery store is stuck between a rock and a hard place.  How can they keep the building secure when closed for business?
> 
> The other issue the client has is that the fire marshal allowed them to lock the doors as long as they used a specially designed lever instead of a thumb turn or a key cylinder.



A door that is latched with a thumb turn or lever is not locked from the side with a thumb turn or lever.  It is latched but not locked.

The requirement for a lever instead of a thumb turn is a reasonable request in that not everyone would recognize a thumb turn as a means to open the door.  A lever may also be a feature of accessibility which is indicated by the requirement that only 90° rotation of the lever is allowed.

The 90° rotation could also come from the common code requirement that no special knowledge be required to operate a latch.  Most if not all people would not realize that 180° rotation is required for a lever.....a thumb latch yes....a lever no.


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## Leo Taylor (Apr 8, 2020)

ICE said:


> A door that is latched with a thumb turn or lever is not locked from the side with a thumb turn or lever.  It is latched but not locked.



This might be for a latching lock but not a deadbolt lock. As a locksmith we differentiate between latched and locked. Especially on fire doors where latching simply means the door cannot be pulled or pushed open but can be opened by using the lever handle or panic bar from either side.    A latch is a very different part than a bolt, and sliding storefront doors do not use latches, they use flip up deadbolt locks. So in this case, when engaged, the doors are locked.  This is different than a swing type door where the door can be both latched and locked.   Sliding doors need Hook deadbolts that hook both leafs of the door so they cannot slide apart, and that is where the FM is having some issues and trying to apply codes meant for different types of hardware. 

 I think the definition of occupied will help.  I'll verify if the store has more than 10 people when closed. Most likely not, and if not then they can lock those doors at close.



This code might also help

7.2.1.1.3.2
Where means of egress doors are locked in a building that is not considered occupied, occupants shall not be locked beyond their control in buildings or building spaces, except for lockups in accordance with 22.4.5 and 23.4.5, detention and correctional occupancies, and health care occupancies.


So, in this case I wonder what is considered beyond their control.  If we install standard thumb turns or key cylinders and can show that the employees can operate the thumb turns or have a key then they might be fine.

Either, way this is good info and will give me some push back on this Fire Marshall.


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## cda (Apr 8, 2020)

Leo Taylor said:


> This might be for a latching lock but not a deadbolt lock. As a locksmith we differentiate between latched and locked. Especially on fire doors where latching simply means the door cannot be pulled or pushed open but can be opened by using the lever handle or panic bar from either side.    A latch is a very different part than a bolt, and sliding storefront doors do not use latches, they use flip up deadbolt locks. So in this case, when engaged, the doors are locked.  This is different than a swing type door where the door can be both latched and locked.   Sliding doors need Hook deadbolts that hook both leafs of the door so they cannot slide apart, and that is where the FM is having some issues and trying to apply codes meant for different types of hardware.
> 
> I think the definition of occupied will help.  I'll verify if the store has more than 10 people when closed. Most likely not, and if not then they can lock those doors at close.
> 
> ...




Your problem is the references for 10 and under come out of NFPA 101....

If a city has not adopted that, they do not have to recognize it. 

If a city has adopted the I codes, than that is what is enforced, unless you can convince them to accept 101, or other alternative plan.


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## classicT (Apr 8, 2020)

Mostly the same info in a previous discussion...

https://www.thebuildingcodeforum.com/forum/threads/mercantile-night-egress.5852/


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## my250r11 (Apr 9, 2020)

Might be able to use motion sensors and put the outside (sensors) ones on a timer to shut down when store is not open. Then the ones inside stay active and will open from inside only no matter the time.


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## cda (Apr 9, 2020)

my250r11 said:


> Might be able to use motion sensors and put the outside (sensors) ones on a timer to shut down when store is not open. Then the ones inside stay active and will open from inside only no matter the time.




Still can pull the doors open


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## Sifu (Apr 10, 2020)

RLGA said:


> What is the occupant load when it's only employees in the building? If there are still two exits that meet all the requirements, then the sliding doors are irrelevant. If there is one door, the occupant load is less than50, and the travel distance to the one door is 75 feet or less, then having the sliding doors are also irrelevant.



This is an interesting discussion.  I never thought about a building having two different occupant loads and calculations.  How would the exit signs be handled?  Generally, I operate under the assumption that if a door is marked as an exit by a sign, then it must function as one.  So even at night, with no customers, an employee sees an exit sign and runs to it, but its blocked?
I'm gonna check out Wal-Mart and see what they do!


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## cda (Apr 10, 2020)

Sifu said:


> This is an interesting discussion.  I never thought about a building having two different occupant loads and calculations.  How would the exit signs be handled?  Generally, I operate under the assumption that if a door is marked as an exit by a sign, then it must function as one.  So even at night, with no customers, an employee sees an exit sign and runs to it, but its blocked?
> I'm gonna check out Wal-Mart and see what they do!





Depending on set up and hours


ones with two entrances lock or shut one down early at night and do not open it till later after they open


Same as some other major grocery people 


Post covid 19::


See picture above


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## Sifu (Apr 13, 2020)

My Walmart has a keyed cylinder outside the sliders, but even after hours while employees are on site they leave one of the sliders unlocked and operable.  Not sure how this would work in a more sketchy area, but in the country I guess it works.  I am not super comfortable with that set of from a security viewpoint, especially now, with reduced access and desperate toilet paper bandits.  Next time I am there I will look for alternate exits to see if the distance might allow the alternate occupant load strategy.
Also, located inside the sliders is a switch at the top jamb which, as far as I can tell turns them on or off so from the outside the proximity reader wouldn't operate, but you can still manually pull them apart, so only the dumbest criminals would be locked out.


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## ADAguy (Apr 13, 2020)

Oh the web we weave, if you have the required number of exits and the sliders are for the public and you have mandoors to either side with panic bars then just put in roll downs over the sliders?


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## Leo Taylor (Apr 15, 2020)

looks like the newest thing is that the Fire Marshal is making them install signs that say "emergency exit only" which makes no sense as these are the front doors.  For now we are going to politely request that the FM send us everything in writing and to cite the code they are following. This will help because the Marshal keeps changing their minds on what they want.  One of the pushbacks that has been effective is that we have in writing from them the demand for the the hardware currently installed.  This has been a little effective as the Fire marshal once again wants to change things.  

For now, it looks like the client will look into changing out the active doors with leafs that have an integrated panic bar.  Very expensive, but might be the only option.

Oh, and i love that pic of the Wal mart.  Seems like a lot of places are doing things like that.


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