Building Safety (Door Release) - 922-1-IPG-044
TB PMM - Vol. 12, Chap. 7(7-2) Canada Occupational Safety and Health Regulations - Part II - Building Safety - Section 2.1 - Canada Labour Code - Part II
Effective Date: March 20, 1992
Door Release Hardware - Electromagnetic Locks
This policy applies to:
- departments and agencies listed in Schedules I and II of the Financial Administration Act (FAA) with the exception of the Department of National Defence;
- branches designated as departments for the purposes of the FAA; and
- those departments and other portions of the Public Service as defined in Part I of Schedule I of the Public Service Staff Relations Act .
- Canada Occupational Health and Safety Regulations - Part II, Section 2.1
- 1985 National Building Code of Canada - Subsection 2.5.1. & Sentence 18.104.22.168.(15)
- 1990 National Building Code of Canada - Sentence 22.214.171.124.(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 126.96.36.199.(15) of the 1985 NBC and Sentence 188.8.131.52.(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:
- the building is equipped with a fire alarm system;
- 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;
- 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;
- upon release, the locking device must be reset manually by the actuation of the switch in Subclause (b)(iii); and
- 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.
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.
Electromagnetic locks that do not incorporate latches, pins or other similar devices to keep the door in the closed position are permitted to be installed on doors other than doors leading directly from a Group F, Division 1 occupancy provided:
- the building is equipped with a fire alarm system, and the lock is installed as an ancillary device;
all locking devices, except as permitted in e. and f., release immediately,
- upon initiation of an alarm signal in a single stage fire alarm system,
- upon initiation of an alert signal in a 2-stage fire alarm system
- in the event of power failure, and
- upon actuation of a single manually operated switch accessible only to authorized personnel;
- a force of not more than 90 N applied to the primary 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;
- except as permitted in c., upon release, the locking device must be reset by the actuation of a manually operated switch accessible only to authorized personnel;
- a legible sign is permanently mounted on the door to indicate that the locking device will release within 15 s of applying pressure to the door opening hardware;
- the total delay in egress time by electromagnetic locks from any point within the floor area to an exterior open space is not more than 15 s;
- the primary door opening hardware for the electromagnetic lock is mounted on the door; and
- the electromagnetic lock and the primary door opening hardware are designed and installed in conformance with CAN/ULC-S533, Standard for Egress Door Securing and Releasing Devices and the locks and the associated hardware are labelled and listed by a recognized testing laboratory.
Electromagnetic locks and all other associated components, including other supplementary unlocking devices, shall not incorporate mechanisms, which upon failure, would impede the door from opening.
Automatic resetting of the electromagnetic lock is permitted provided the primary door opening hardware releases the lock instantaneously when a force of not more than 90 N is applied to the hardware.
In areas likely to have accidental activations of the primary door opening hardware by the public, electromagnetic locks with a delay activation feature may be installed provided:
- the irreversible process is initiated if a force of not more than 90 N is applied to the primary door opening hardware for a continuous period of 3 s;
- the total time lapse from the moment the force is applied to the primary door opening hardware to the releasing of the locking device does not exceed 15 s; and
- a legible sign is permanently mounted on the door to indicate that the door opening hardware must be pressed for 3 s, and the locking device will be released within a specific time period.
In large buildings, the electromagnetic locking devices may be released only within the zone in which the fire alarm system is activated provided the area of each zone in a storey is not less than 2,000 m2 .
When a distributed type control unit is used in a fire alarm system, a manual pull station shall be provided adjacent to the door equipped with electromagnetic locking device so that the operation of the manual pull station releases the locking device immediately. The remaining locking devices within the building or within the zone as described in 5. shall be released upon the initiation of an alarm signal in a single stage fire alarm system and upon the initiation of an alert signal in a 2-stage fire alarm system.
The electromagnetic locking devices shall be tested monthly and records shall be kept of all tests for a period of 2 years.
All locking devices shall be kept deactivated during repair work on the locking system.
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.
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