Do you ever have a building code question that should be easily answered, but instead you have to wade through the codes and standards? Don’t you wish you had a resource to help quickly explain code requirements?

I’m Lori Greene, the Manager of Codes and Resources with Allegion, and I’m here to help. I’ve used my 35 years of experience in the door and hardware industry to provide quick code answers in columns for numerous industry publications and through my blog, iDigHardware.com.

In these quick Q+A blog posts, I’ll field frequently asked questions about doors and hardware to help those installing these systems ensure code compliance. In last month’s blog on panic hardware, I mentioned that sometimes key-operated locks might be allowed instead. This month’s Q+A will focus on the codes around this easily misinterpreted exception about using key-operated locks instead of panic hardware.

If you have a code-related question you would like answered, please send it to jhuff@glass.com.

Where Can Key-Operated Locks be Used on Doors as a Means of Egress?

Panic hardware may be required when doors in certain occupancy types must facilitate a fast and easy exit during an emergency. With that said, the International Building Code (IBC) has historically allowed key-operated locks to be used on exterior doors in certain cases in lieu of panic hardware. In the 2015 edition of the IBC, a change was made that was intended to extend this exception to entrance doors serving tenant spaces, such as retail stores in malls. The word “exterior” was removed from this section of the IBC, which caused confusion about where the exception could be applied.

The exception for allowing a key-operated lock, such as a double-cylinder deadbolt, was never intended to apply to interior doors serving a room where the lock could restrict egress. In addition, specific criteria are listed in the code that must be met to install these locks. The section that applies to key-operated locks will be amended in the 2024 model codes to clarify the extent of the requirements. While the amendment clarifies that key-operated locks are permissible on the main exterior doors or main doors to a tenant space in certain types of buildings, there are important criteria a space must also meet to be eligible for this exception.

Eligibility Requirements for Key-Operated Hardware

National model codes list the following criteria for determining if a key-operated lock can be installed:

• Signage on the egress side of the door or adjacent to the door must state “THIS DOOR TO REMAIN UNLOCKED WHEN THE BUILDING IS OCCUPIED” or “THIS DOOR TO REMAIN UNLOCKED WHEN THE SPACE IS OCCUPIED.”  The letters on the sign must be at least 1 inch high on a contrasting background.
• The locking device must be readily distinguishable as locked.

The model codes indicate that an Authority Having Jurisdiction (AHJ) or building official may revoke these provisions for cause. In addition to the above criteria, the I-Codes and NFPA codes have slight variations, another reason to check with an AHJ to determine which code and edition governs a project.

Another important consideration is the building’s user group or occupancy classification, as these locks are only allowed on certain types of facilities.

I-Codes

• The building’s use group must be one of the following: Assembly occupancy with an occupant load of 300 people or less, business, factory, mercantile, or storage occupancy, or a place of religious worship.

NFPA Codes

• Key-operated locks must be specifically allowed by the applicable occupancy chapter.
• In addition, the NFPA codes require that a key be readily available to all occupants inside the building when locked.

How This Affects Glaziers

Because these provisions cover retail tenant spaces, they are often a component in glass storefronts or openings that incorporate glazing. Understanding panic hardware requirements and this exception can help glaziers know the entire assembly will likely meet requirements, reducing the potential need to rework door hardware.