Building Safety (Door Release) - 922-1-IPG-044

1. Subject

Door Release Hardware - Electromagnetic Locks

2. Application

This policy applies to:

1. departments and agencies listed in Schedules I and II of the Financial Administration Act (FAA) with the exception of the Department of National Defence;
2. branches designated as departments for the purposes of the FAA; and
3. those departments and other portions of the Public Service as defined in Part I of Schedule I of the Public Service Staff Relations Act .

3. References

• Canada Occupational Health and Safety Regulations - Part II, Section 2.1
• 1985 National Building Code of Canada - Subsection 2.5.1. & Sentence 3.4.7.12.(15)
• 1990 National Building Code of Canada - Sentence 3.4.6.15.(4) and
• Treasury Board Policy, PMM - Vol. 12, Chap. 7(7-2).

Section 2.1 of the Canada Occupational Health and Safety Regulations requires the design and construction of every building to meet the standards set out in Parts 3 to 9 of the 1985 National Building Code (NBC) to the extent that is essential for the safety and health of employees.

Subsection 2.5.1. of the 1985 NBC permits the use of equivalents to satisfy one or more of the requirements of the NBC where there is sufficient evidence to demonstrate that the proposed equivalent will provide the level of performance required by the NBC.

Sentence 3.4.7.12.(15) of the 1985 NBC and Sentence 3.4.6.15.(4) of the 1990 NBC permit the use of electromagnetic locks that do not incorporate latches, pins or other similar devices to keep the door in the closed position on exit doors other than doors leading directly from a Group F, Division 1 occupancy provided:

1. the building is equipped with a fire alarm system;
2. the locking device releases immediately
   • upon initiation of a fire alarm signal,
   • in the event of a power failure, and
   • upon actuation of a manually operated switch accessible only to authorized personnel;
3. a force of not more than 90 N applied to the door opening hardware initiates an irreversible process that will release the locking device within 15 s and not relock until the door has been opened;
4. upon release, the locking device must be reset manually by the actuation of the switch in Subclause (b)(iii); and
5. a legible sign is permanently mounted on the exit door to indicate that the locking device will release within 15 s of applying pressure to the door-opening hardware.

4. Background/Situation

Electromagnetic locking devices are intended for use where there is a need for access control or security in addition to that provided by traditional exit hardware. They are not intended for indiscriminate use as alternative locking devices. It is important to note that the design and installation of these locking devices require careful evaluation to ensure that their operation will be fail safe in allowing exiting in the event of foreseeable emergencies.

There have been many requests to accept electromagnetic lock designs that do not fully comply with the NBC. Many design features that are not adequately covered by the NBC are being suggested.

Some of the problems and issues that have been raised are:

• Under certain conditions, the NBC permits the use of electromagnetic locks on exit doors, but is silent on other egress doors. The implication is that they are not permitted on other egress doors.
• The NBC does not address the cumulative delay resulting from more than one door being locked in the path of egress.
• The NBC does not reference the CAN/ULC-S533 standard, and consequently there is no quality control over the type of hardware being used.
• The NBC does not address the issue of "nuisance" activation of the door hardware in public areas.
• The NBC appears to require all doors in the building to be released upon activation of the fire alarm system, regardless of the building size.
• The NBC does not address the extended time delay that can be introduced into the release by certain types of fire alarm systems.
• There are no inspection and maintenance requirements in the NBC or the National Fire Code for these devices.

5. Requirements

6. Terms and Conditions

This policy, including the requirements, is based upon a technical evaluation of the subject matter from a fire safety point of view, and is a reflection of professional opinion. This policy is not to be interpreted as permitting practices prohibited by the Canada Labour Code Part II, the Canada Occupational Health and Safety Regulations or, provincial or other legislation.