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BCC Ruling No. 97-15-557

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BUILDING CODE COMMISSION DECISION ON B.C.C. #97-15-557

IN THE MATTER OF Subsection 24 (1) of the Building Code Act, 1992.

AND IN THE MATTER OF Article 3.4.6.15. of "the Building Code" (Ontario Regulation 419/89 as amended by Ont. Reg. 183/88, 581/88, 11/89 and 115/89).

AND IN THE MATTER OF an application by Mr. Richard Dixon, Vice President, Redevelopment, Mississauga Hospital, 100 Queensway West, Mississauga, Ontario, for the resolution of a dispute with Mr. Agris Robeznieks, Chief Building Official, City of Mississauga, concerning whether door release hardware should be installed in accordance with Article 3.4.6.15. of the Ontario Building Code (OBC) at the Mississauga Hospital, 100 Queensway West, Mississauga, Ontario.

APPLICANT
Mr. Richard Dixon
Vice President, Redevelopment
The Mississauga Hospital
100 Queensway West
Mississauga, Ontario

RESPONDENT
Mr. Agris Robeznieks
Chief Building Official
City of Mississauga

PANEL
Mr. Roy Philippe, Chair
Mr. Demir Delen
Mr. Lawrence Glazer

PLACE
Toronto, Ontario

DATE OF RULING
Thursday, June 12th, 1997

APPEARANCES
Mr. Richard Dixon
Vice President, Redevelopment
The Mississauga Hospital
For the Applicant

Mr. Roy Chalk
Manager, Building Engineering
& Inspection
City of Mississauga
For the Respondent

RULING

  1. The Applicant

Mr. Richard Dixon, Vice President, Redevelopment, Mississauga Hospital, is a person who has applied for a permit under the Building Code Act, 1992 to renovate an existing hospital facility by installing electromagnetic locking devices on the exterior exit doors at the Mississauga Hospital, Mississauga, Ontario.

  1. Description of Construction

The Mississauga Hospital is described as a 4 storey building constructed from noncombustible material, which is classified as a B2 occupancy under the OBC. The building area is 52,500 m2. The subject building has a fire alarm system, a sprinkler system, as well as a standpipe and hose system.

The applicant proposes to install electromagnetic locking devices on the exterior exit doors of the subject building. It is their desire to not equip these doors with panic mechanisms that when activated can result in an overriding of the electromagnetic locking hardware.

  1. Dispute

The issue under dispute between the Applicant and the Respondent is whether the proposed exterior doors at the Mississauga Hospital may be installed without panic devices to override the electromagnetic locks. Clause 3.4.6.15.(1)(b) states that every exit door in a building with an occupancy of more than 100 persons is required to have panic release hardware. Sentence 3.4.6.15.(4) permits electromagnetic locking devices on exit doors under certain conditions, one of which is that any locking device that may be installed is ancillary to the fire alarm system. Panic hardware is must also immediately override any electromagnetic locking system. It is the provision that requires panic hardware that the Mississauga Hospital seeks exemption from.

  1. Provisions of the Building Code

Article 3.4.6.15. - Door Release Hardware

(1) If a door is equipped with a latching mechanism, a device that will release the latch and allow the door to swing wide open when a force of not more than 90 N (20 lb) is applied to the device in the direction of exit travel shall be installed on

(a) every exit door from a floor area containing a Group A occupancy having an occupant load of more than 100 persons,

(b) every door leading to an exit lobby from an exit stair shaft, and every exterior door leading from an exit stair shaft in buildings having an occupant load of more than 100 persons, and

(c) every exit door from a floor area containing a Group F, Division 1 Occupancy.

(2) Every exit door shall be designed and installed so that, when the latch is released, the door will open under a force of not more than 90 N (20 lb), applied at the knob or other latch releasing device.

(3) Locking, latching and other fastening devices on any required exit door shall be such that the door can be readily opened from the inside without requiring keys, special devices or specialized knowledge of the door opening mechanism, except that this requirement does not apply to locking, latching and other fastening devices to be remotely released in conformance with Article 3.3.1.12. serving a contained use area or an impeded egress zone.

(4) An electromagnetic locking device that does not incorporate latches, pins or other similar devices to keep the door in the closed position is permitted to be installed on an exit door, other than an exit door serving an elementary or secondary school or leading directly from Group F, Division 1 occupancy

(a) if the building is equipped with a fire alarm system conforming to Subsection 3.2.4.,

(b) if the locking device is installed as an ancillary device to the fire alarm system and releases immediately

(i) upon activation of the fire alarm signal,

(i.1) where the exit door serves a hotel, upon activation of the alert signal where a two stage fire alarm system is installed or upon activation of the alarm signal where a single stage fire alarm system is installed,

(ii) in the event of a power failure or ground fault, and

(iii) upon actuation of a manually operated switch accessible only to authorized personnel,

(c) if a manual pull station for the fire alarm system is located on the wall not more than 600 mm (235/8 in) from the door,

d) if, upon its release, the locking device must be actuation of the switch referred to in Subclause (b)(iii),

(e) if a legible sign having the words EMERGENCY EXIT UNLOCKED BY FIRE ALARM is permanently mounted on the door, and

(f) if the lettering on the sign required in Clause (e) is at least 25 mm (1 in) high with a 5 mm (3/16 in) stroke. (See Appendix A.)

(5) Reserved

(6) Where an electromagnetic locking device conforming to Sentence (4) is installed, the device is also permitted to be released by a card identifier or microprocessor which may incorporate a time delay of not more than 15 seconds, provided the sign required in Clause (4)9e) has the additional words

(a) KEY PUSHING, where there is not time delay,

(b) KEEP PUSHING DOOR UNLOCKS IN 15 SECONDS, where there is a 15 second time delay, or

(c) as required in Clause (b), with the number of seconds corresponding to the time delay of the device instead of 15.

  1. Applicant's Position

The Applicant submitted that the proposed electromagnetic locking devices installed on the exterior exits should not be equipped with panic mechanisms that, when actuated, result in a release of the exit doors. The hospital has in the recent past experienced many breaches of security (e.g., theft, improper removal of patients, and assaults). In their opinion, the ease by which the electromagnetic locking devices can be overridden has contributed to these security infractions. Consequently, patient care and security has been compromised.

It is their view that an electromagnetically locking door that provides a manual pull station according to Article 3.4.6.15.(4) should be sufficient to allow adequate egress in an emergency situation. They believe that by equipping their exit doors with these manual pull stations (located on the wall within 600 mm), which would immediately override the electromagnetic locking system, safe and quick egress would be provided in any dangerous situation. At the same time, by not including the panic mechanisms, the security of the facility would be enhanced.

  1. Chief Building Official's Position

The Respondent submitted that the proposed installation of electromagnetic locking devices on exterior exit doors does not comply with OBC Article 3.4.6.15. In their view, panic hardware that overrides the electromagnetic locks and releases the exit doors immediately is required. As such, they believe they are not in a position to approve this proposal.

  1. Commission Ruling

It is the decision of the Building Code Commission that the installation of electromagnetic locking devices on the exit doors from stairwells to the exterior equipped with panic hardware provides sufficiency of compliance with Article 3.4.6.15. of the Building Code provided that the installation complies with Sentence 3.4.6.15.(4) and smoke detectors connected to the fire alarms system are installed at every third level and the top of the stairwell.

  1. Reasons:

i) The hospital facility is sprinklered throughout.

ii) Security staff in addition to hospital staff are available and experienced in the operation of the fire safety plan on a 24 hour basis.

iii) The electromagnetic locking devices will release as required by Article 3.4.6.15.(4) and additional smoke detection will be provided in the stairwells.

iv) Movement of patients in a fire emergency is normally horizontally to a safe zone before total evacuation.

v) The fire department is available in the immediate vicinity to respond to a fire emergency.

Dated at Toronto this 12th day in the month of June in the year 1997 for application number 1997-17.

Roy Philippe, Chair

Demir Delen

Lawrence Glazer