Life Safety- Whats more important than getting out? __~NOTHING

ISAC SPEECH

CHANGES AND CLARIFICATIONS IN LIFE SAFETY
REQUIREMENTS AND ENFORCEMENT FOR MEANS OF EGRESS
AND SCIF DOORS AND LOCKS

Harry O'Haver
President
Maryland Industrial Security Inc.

That's a mouthful! Let's simplify that description to something like this: The rules are the same but which doors and locks must comply has been clarified. Also clarified is which locks are considered to be part of the "releasing mechanism" and also must comply.

Finally, on the topic of enforcement, I have had many Security Directors, Facilities Directors, and even the occasional Life Safety Director say to me, "We just had the Fire Marshall finish his inspection and he gave us a clean bill of health." My answer is: "If I were you, I would rush out and buy a lottery ticket." Times are changing. The training of Fire Marshals Nationwide is accelerating. The rules for Means of Egress and Single Release Motion are prominent in this program. A pilot project on this new training will be beginning this spring in Baltimore County. Perhaps even more important is the fact that architects, specifiers, customers and fire marshals are presently requiring that these codes are observed in order to have new construction and even space modifications certified.

NFPA 101 has been the "Bible" of Life Safety codes and regulations for as long as I can remember - and that's a very long time.

As long as I have been a locksmith I have tried to follow the rules set out by NFPA 101 as they applied to what locks were allowed, what I had to do if I did use two locks on a door, rules on chains, padlocks, etc.

Over the years many of these rules have changed-always stricter-never more lenient. Whenever I tend to grumble about these changes, I am reminded of a Life Safety saying I heard somewhere.

Life Safety Question: What's more important that getting out?
Answer: "NOTHING."

There are two paragraphs in NFPA 101 that I consider, as a locksmith, to be of maximum importance. If you will look at the blackboard behind me, you will see both of them.

7.2.1.5.9.2
The releasing mechanism "shall open the door with not more than one releasing operation."

7.2.1.5.9
A latch or other fastening device on a door shall be provided with a releasing device that has an "obvious method of operation" and that is "readily operated" under all lighting conditions.

Of the two I consider the first paragraph 7.2.1.5.9.2 to be the most important.

Many of us remember the Coconut Grove Night Club fire in Boston in 1942 in which 492 people died. Many people think this tragedy caused the formation of the National Fire Protection Association (NFPA) for short. Not true. The association was first formed in 1913 and has been the leader in fire protection ever since. All the tragedies, including the Coconut Grove tragedy, could have been prevented if those responsible for fire safety had only followed the NFPA rules.

There isn't anyone in this room that is going to use padlocks and chains to meet security requirements, however, these paragraphs on the blackboard are really trying to help you meet security requirements without endangering lives.

Everything I have said so far is background to What's New.

What's New #1
Which doors must comply with NFPA 101 Codes regarding Means of Egress?

The "Means of Egress" which I like to call "The Road of Life," has three parts. There has
never been a question about which doors must comply with the middle part, called "the exit," or the last part, called the "exit discharge." The answer is all "identified" doors must comply.

The question remaining is what about the "exit access?" the first part of the Means of Egress.

The clarification is:

7.2.1.2
Every door and every principal entrance that is required to serve as an exit are to be considered as part of the exit access.

There aren't any exceptions to this clarification. In simple terms, it means that the door from any room where people are or might be at the time of an emergency is classified as a part of the exit access. It can be a marked exit door from a room housing 50 or more people, an office or even a room with no regular occupants that is used intermittently by several different people (e.g. communications room, copier room, lunchroom.)

It is commonly thought that an office or a communications room is not part of the Means of Egress because they seldom have a lighted emergency exit sign and sometimes aren't occupied on a regular basis. This couldn't be farther from the truth . NFPA 101 states "every door" and every "principal entrance" that is required to serve as an "exit" are to be considered a part of "the exit access." The key words here are "principal entrance" and "serve as a principal exit."

This is the first, and one of the most important recent clarifications of NFPA 101 Codes.

The next clarification regarding doors answers the question:

Can an "in swinging" door be a part of the means of egress?

The answer is yes. If the room with the in swinging door has 49 or less occupants, then it is allowed to remain "in swinging."

The NFPA 101 Code States:

7.2.1.4.2 Doors required to be of the side-hinged or pivoted-swinging type shall swing in the direction of egress travel where serving a room or area with an occupant load of 50 or more .

This is particularly important when such a door is part of the exit access, since the "single motion egress lock" must be capable of working on an in swinging door.

What's New #2
What are the additional "recent" clarifications to NFPA 101 that refer to locks on
doors in the means of egress?

The original NFPA 101 codes stated:

• The releasing mechanism "shall open the door with not more than one releasing operation."

This means that:

• You cannot have two locks on a means of egress door unless they can be opened from the egress side with one motion.

• You cannot have a combination lock and a leverset on a means of egress door, whether or not the combination lock is normally open.

NOTE: This represents a major shift from the "old philosophy" that combination locks are always considered to be unlocked when a room is occupied, or when the "safety pin" on the combination lock is used.

• The same rules apply to a deadbolt and a leverset on a means of egress door.

• In addition to the two releasing motions prohibition, any door that has two locks either inside or outside of the means of egress must have "locks that have an obvious method of operation and that are readily operated under all lighting conditions." As an example, an X09 combination lock clearly does not have an obvious method of operation from the egress side regardless of lighting conditions.

7.2.1.5.9
A latch or other fastening device on a door shall be provided with a releasing device that has an "obvious method of operation" and that is "readily operated" under all lighting conditions.

Last but not least are the specifications for open storage of classified information. This requirement applies primarily to SCIF's.

Simply stated, any lock used on a SCIF door must not only comply with the NFPA 101 codes for Single Motion Egress but also with the DOD (or customer) rules requiring those locks to be deadbolts not dead latches.

NOTE: By "open storage" FF-L-2740A and FF-L-2890 means any "unprotected" classified information in open view. This could include classified information on an office desk, information on a white board in a meeting room, nor an office, or any similar situation where the "wrong people" might view classified data.