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BCC Ruling No. 96-20-503

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BUILDING CODE COMMISSION DECISION ON B.C.C. #96-20-503

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

AND IN THE MATTER OF Sentences 3.4.6.15.(1) and 3.4.6.15.(4) of the Revised Regulation of Ontario 1990, Regulation 61, as amended by O.Regs. 400/91, 158/93, 160/93, 383/94 and 20/95 (the "Building Code").

AND IN THE MATTER OF an application by Mr. Bruce Barnett, North York Public Library for the resolution of a dispute with Mr. Yaman Uzumeri, Chief Building Official, City of North York, concerning whether electromagnetic locking devices on two exit doors must release immediately upon activation of door release hardware in accordance with Sentences 3.4.6.15.(1) and 3.4.6.15.(4) of the Building Code at the Downsview Regional Library, 2793 Keele Street, North York, Ontario.

APPLICANT

Mr. Bruce Barnett
Plant and Facilities Manager
North York Public Library
North York, Ontario

RESPONDENT

Mr. Yaman Uzumeri
Chief Building Official
City of North York

PANEL

Mr. Roy Philippe, Chair
Mr. Michael Steele
Mr. Michael Lio

PLACE

Toronto, Ontario

DATE OF RULING

June 12th, 1996

APPEARANCES

Mr. Richard Kowalski, Architect
Makrimichalos Cugini Architects
Toronto, Ontario
For the Applicant

Mr. Melvin Ramkissoon
Construction Plan Examiner
City of North York
For the Respondent

RULING

  1. The Applicant

Mr. Bruce Barnett, Plant and Facilities Manager, North York Public Library is an applicant for a permit under the Building Code Act, 1992 to construct alterations and an addition to the Downsview Regional Library, 2793 Keele Street, North York, Ontario.

  1. Description of Constrution

The subject library is a one storey noncombustible building with a building area of approximately 1,176 m². The building is classified as an Assembly Occupancy, Division 2 (i.e. A-2). The building is provided with a fire alarm and detection system, but is not provided with neither an automatic sprinkler system nor a standpipe and hose system.

Electromagnetic locking devices (EMLD) are proposed on three doors, two of which are exit doors equipped with panic type hardware. One of the subject exit doors is an exterior door and the other is a door providing access to an exit shaft.

  1. Dispute

The dispute between the Applicant and Respondent concerns an interpretation of Sentences 3.4.6.15.(1) and 3.4.6.15.(4) of the Building Code. At issue is whether electromagnetic locking devices on two exit doors must release immediately upon activation of door release hardware.

  1. Provision of the Building Code

Sentence 3.4.6.15.(1) 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

    1. every exit door from a floor area containing a Group A occupancy having an occupant load of more than 100 persons,
    2. 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
    3. every exit door from a floor area containing a Group F, Division 1 Occupancy.

Sentence 3.4.6.15.(4)

  1. 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

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

    1. 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,

    1. 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,

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

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

    1. 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.)

  1. Applicant's Position

The Applicant submitted that the proposed installation of electromagnetic locking devices in the desired locations conforms with Sentence 3.4.6.15.(4) of the Building Code.

The Applicant submitted that the buildings security system would be compromised if the electromagnetic locking devices release immediately upon activation of the door release hardware. Also, the level of safety intended by the Building Code is not compromised because the EMLD's are deactivated upon activation of the building's fire alarm system.

The Applicant stated that activation of the door release hardware does not include a 15 second time delay to deactivate the EMLD.

  1. Chief Building Official's Position

The Respondent submitted that Sentence 3.4.6.15.(1) of the Building Code requires exit doors to open when door release hardware is activated.

The Respondent submitted that Sentence 3.4.6.15.(4) of the Building Code permits an electromagnetic locking device on exit doors provided the electromagnetic locking device is immediately deactivated when the door release hardware is activated. This is due to the independence of Sentence 3.4.6.15.(1) & (4). Therefore, conformance with both requirements is required.

The Respondent submitted that Section 813 of the BOCA National Building Code recognized special locking arrangements for security purposes, but these arrangements are not permitted in assembly occupancies due to higher occupant loads and the greater possibility of mass panic. The Occupant load of the subject building is 350 people as determined by NFPA 101.

  1. Commission Ruling:

It is the decision of the Building Code Commission that providing electromagnetic locking devices (EMLD's) on the required exit doors equipped with panic type hardware in the library building does not provide sufficiency of compliance with Sentence 3.4.6.15.(1) of the Building Code.

  1. Reasons:

i. No additional compensating features have been provided to enhance the provision for life safety.

ii. The position of the Housing Development and Buildings Branch, Ministry of Municipal Affairs and Housing is that EMLD's installed on the required exit doors of the library equipped with panic type hardware must not negate the normal operation of the panic hardware on those doors, i.e. operation that will allow the doors to swing wide open immediately when a force of not more than 90 N (20 lb) is applied to the panic hardware in the direction of exit travel.

iii. The Housing Development and Buildings Branch, Ministry of Municipal Affairs and Housing submitted that the entire Article 3.4.6.15. will be reviewed for the next edition of the Building Code and it is not expected that the philosophy regarding the use of EMLD's will change.

Dated at Toronto, this 12th day, in the month of June, in the year 1996, for application number 1996-17.

Roy Philippe, Chair

Michael Steele

Michael Lio