Model Code Comparison: Controlled Egress

Feb. 10, 2022
As is the case with delayed egress, not all codes are the same for the more-limited locking system.

A previous Locksmith Ledger article addressed the model code requirements for delayed-egress locks, which under normal operation delay egress for 15 seconds, or 30 seconds when approved by the Authority Having Jurisdiction (AHJ).

For many years, delayed-egress locks were the most restrictive hardware that could be used on the egress side of doors in healthcare facilities, but this application wasn’t feasible for every location. For example, in a memory-care facility, a patient who exhibits exit-seeking behavior could activate the lock repeatedly, initiate the audible alarm and possibly even leave the facility unaccompanied if a staff member didn’t respond in time.

Beginning with the 2009 editions of the model codes, sections were added to give certain types of healthcare facilities a more secure option for their egress doors. There were a few changes to these code sections over subsequent editions, and the term “controlled egress lock” since has become the commonly used term for this application.

These locks are allowed by the model codes in healthcare facilities where patients require containment for their safety or for security. During normal operation, the doors don’t allow free egress. If evacuation were necessary, the doors would be unlocked by one of the required emergency overrides or by facility staff. The release methods required by the model codes are intended to help to ensure a balance of life safety and security. 

This article will compare the requirements of the I-Codes, such as the International Building Code (IBC) and International Fire Code (IFC), with the NFPA codes such as NFPA 1 – Fire Code, NFPA 5000 – Building Construction and Safety Code and NFPA 101 – Life Safety Code. States and local jurisdictions may modify these model codes, and requirements can vary from one edition to the next. It’s crucial to check the adopted codes to verify the requirements for a specific project’s location.

Classifications

Remember that this application applies only to certain types of healthcare units and isn’t allowed by the model codes in other use groups or occupancy types. The model codes describe the locations for controlled-egress locks in different ways, but the intent is that they’re allowed in healthcare facilities where the clinical needs of patients require their containment. These locks aren’t allowed in every type of healthcare unit.

The purpose of this system is to prevent elopement, for example, to prevent a patient who has dementia from leaving a facility unaccompanied. The typical locations for controlled-egress locking systems are memory-care units, behavioral-health treatment areas, maternity wards and newborn nurseries, and possibly emergency departments or pediatric areas, depending on the AHJ’s interpretation.

I-Codes. The I-Codes allow controlled-egress locks in Institutional Use Groups I-1 and I-2, where the clinical needs of patients who receive care require their containment. Before the 2015 edition of the I-Codes, this section was limited to Use Group I-2. Use Group I-1 includes buildings where more than 16 people (excluding staff) reside in the facility on a 24-hour basis and receive custodial care in a supervised environment. Examples of these facilities are alcohol- and drug-rehabilitation centers, assisted-living facilities, congregate care facilities, group homes, halfway houses, residential board and care facilities and social-rehabilitation facilities.

Institutional Group I-2 includes buildings used for medical care on a 24-hour basis for more than five people who are incapable of self-preservation. Examples of I-2 occupancies are foster-care facilities, detoxification facilities, hospitals, nursing homes and psychiatric hospitals. 

NFPA. The NFPA codes address controlled-egress locks in the occupancy chapters related to new and existing healthcare occupancies and ambulatory healthcare. In these occupancies, controlled-egress locks are allowed where patient special needs require specialized protective measures for their safety. 

Both sets of model codes allow some of the automatic-release methods to be omitted on doors that serve areas where specialized security measures are necessary, including behavioral-health units and maternity areas where listed child-abduction systems are in use.

Fire Protection

I-Codes. For controlled-egress systems, the IBC requires the building to be equipped throughout with an automatic sprinkler system or approved automatic smoke- or heat-detection system.

NFPA. The NFPA codes require the facility to be protected throughout by a supervised automatic sprinkler system AND either a complete smoke-detection system throughout the locked space or the ability to remotely unlock doors from an approved constantly attended location within the locked space.

Action Upon Emergency

I-Codes. When the fire alarm or sprinkler system is activated, controlled-egress locks must unlock and allow free egress, but, as stated previously, there are exceptions for some types of units. The IBC doesn’t require the locks to release automatically upon fire-alarm or sprinkler-system activation when installed on doors that serve psychiatric or cognitive treatment areas or for units where a listed child-abduction system is in use. 

NFPA. The NFPA codes require controlled-egress locks to unlock for immediate egress upon activation of the smoke-detection system or upon waterflow in the automatic sprinkler system. NFPA doesn’t require the automatic release where patients require specialized security measures or pose a security threat. 

Action Upon Power Failure

I-Codes & NFPA. When power fails, both sets of model codes require controlled-egress locks to unlock immediately in the direction of egress, but again, some units are exempt from this automatic release — psychiatric or cognitive treatment areas and locations where a listed child-abduction system is used. The NFPA codes don’t require controlled-egress locks to unlock upon power failure in units where patients require specialized security measures or pose a security threat. And similar to delayed-egress locks, the codes aren’t specific about backup power, but separate battery backup in the power supplies for these locking systems isn’t recommended.

Remote Release

With the exception of psychiatric and cognitive treatment areas, locations that have child-abduction systems and units where patients pose a security risk, controlled-egress locks must be able to be released by a remote switch.

I-Codes. The IBC states that the switch must break power to the lock directly and specifies that the remote release must be located at the fire command center, nursing station or other approved location.

NFPA. The NFPA codes allow a remote release switch to be used as one of the options for rapid removal of occupants. In new occupancies, remote control of the doors must be from within the locked area.

Staff Release

I-Codes. Where controlled-egress locks are installed, the IBC requires all clinical staff to be able to release the locks. Staff members must carry the keys, codes or other credentials to unlock the doors, and these procedures have to be part of the emergency plan for the facility.

NFPA. The NFPA codes also require clinical staff to be able to unlock the doors at all times. Three options are allowed by NFPA to facilitate the rapid removal of occupants:

  • Remote control of the doors.
  • Keys carried by staff at all times.
  • Other reliable means always available to staff.

Emergency Lighting

I-Codes. As with delayed-egress locks, the IBC requires emergency lighting on the egress side of a door that has a controlled-egress lock.

NFPA. The NFPA requirements for controlled-egress locks don’t reference emergency lighting.

Quantity of Locks

I-Codes. The I-Codes state that building occupants must not be required to pass through more than one door that has a controlled-egress lock before entering an exitway — for example, before entering a stairwell. Again, psychiatric and cognitive treatment areas and units that have child-abduction systems are exempt from this limit.

NFPA. The NFPA codes limit new occupancies to one controlled-egress lock per door. The AHJ could approve additional locks for existing occupancies. However, these codes don’t limit the number of doors in an egress path that are equipped with controlled-egress locks.

Required Listings

I-Codes & NFPA. Both sets of model codes require controlled-egress locking systems to be listed to UL 294 – Standard for Access Control System Units. If a controlled-egress lock will be installed on a fire-door assembly, the lock also must be listed to UL 10C Positive Pressure Fire Tests of Door Assemblies or NFPA 252 Standard Methods of Fire Tests of Door Assemblies. In addition to the other listings, panic hardware that includes a controlled-egress feature must be listed to UL 305 – Standard for Panic Hardware (both I-Codes & NFPA) and in some cases BHMA A156.3 – Exit Devices (NFPA only).

Controlled Vs. Delayed

Although there are some similarities between the delayed-egress and controlled-egress codes, several requirements apply to delayed-egress locks that aren’t mandated for controlled-egress locks:

  • For controlled-egress locks, pushing on the doors or attempting to use the hardware doesn’t trigger a timer or signal, and the lock isn’t required to release after 15 seconds. The doors remain locked in the direction of egress until released by staff or an automatic release method. 
  • The model codes don’t specify how a controlled-egress lock must be rearmed. This normally is interpreted to mean that the doors are allowed to relock automatically after they’re released for egress.
  • An audible alarm isn’t required for doors that have controlled-egress locks. 
  • Signage that states how to operate the hardware isn’t required by the model codes for controlled-egress locks.  However, it could be beneficial to have signage explaining to building occupants what the exiting protocols are. 

Keep in mind that controlled-egress locks are allowed only in certain types of healthcare occupancies. They aren’t allowed by code in other use groups or occupancy classifications.

For more information about controlled-egress locks, refer to the adopted code(s) in the jurisdiction where the building is located, and consult with the AHJ if there are any questions. State or local codes might include modifications to the model code requirements, so it’s important to verify the specific requirements that apply to your project.

Lori Greene, DAHC/CDC, CCPR, FDAI, FDHI, is manager, codes and resources at Allegion. Visit her website, idighardware.com.

About the Author

Lori Greene, DAHC/CDC, CCPR, FDAI, FDHI

Lori Greene, DAHC/CDC, CCPR, FDAI, FDHI, is manager, codes and resources at Allegion. Visit her website, idighardware.com.