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Department of Safety and Professional Services
Department of Safety and Professional Services

Door Locks Educational Occupancies

The Department of Safety and Professional Services Fire Prevention and Commercial Building Inspection teams regularly receive inquiries regarding school safety and door locks, barricades, and specialized aftermarket hardware.  Each inquiry receives specific review related to the details provided and applicable codes.  The Department has previously provided a FAQ response to this.  The Department’s interpretation of the current adopted and referenced code requirements has not changed; however, reviews of inquiries are ongoing as technology continues to evolve and each inquiry is unique.

https://dsps.wi.gov/Documents/Programs/CommercialBuildings/FAQSecurityLocksSchools.pdf

Are door security or barricade devices that separate devices from the typical door hardware and latching mechanism, permitted to be used to secure doors in public buildings and places of employment, particularly classrooms in educational occupancies, during lockdown events? 

Answer: No. 

Door Operation and Locks. While there are many innovative devices currently on the market for securing doors, if they operate independently of the typical door hardware and latch, they are likely not permitted by Wisconsin Building and Fire Codes. SPS 361.03(13) requires existing public buildings and places of employment to be maintained in compliance with the building code provisions that applied when the building was constructed or altered except when required by subsequent editions of the building code. The building code has a long history of consistent requirements for exit or exit access door hardware. For example, the 1970 Wisconsin Commercial Building Code contained the following requirement in s. 51.15(3) for door hardware. “A standard exit door shall have such fastenings or hardware that it can be opened from the inside without using a key, by pushing against a single bar or plate, or turning a single knob or handle. It shall not be barred or bolted at any time while the building is occupied.” Under the current Wisconsin Commercial Building Code (IBC 1010.2.8), egress doors from classrooms, offices, and other occupied rooms equipped with intruder-resistant locking mechanisms must remain unlockable from the outside using a key or other approved method. From within the room, the door must be openable at all times in accordance with standard IBC door operation requirements. Additionally, remote locking or unlocking from an approved location is permitted alongside the exterior key-unlocking method. Modifications to listed panic hardware, fire door hardware, or door closers are prohibited, and any modifications to fire door assemblies must comply with NFPA 80.

The Wisconsin Fire Prevention Code, SPS 314, contains requirements for the operation, maintenance, and use of public buildings and places of employment. SPS 314.001(1) adopts the National Fire Protection Association, NFPA 1, Fire Code 2012 edition. NFPA 1 s. 14.4.1 requires “Means of egress shall be continuously maintained free of all obstructions or impediments to full instant use in the case of fire or other emergency.” There are many unintended consequences that might occur from barricading egress doors serving occupied rooms and therefore such devices are generally prohibited by Wisconsin Building and Fire Prevention Codes. There are code compliant door hardware solutions, such as a classroom security lockset, that will allow egress doors to be locked from the classroom side, while at the same time allowing egress through normal operation of the door hardware on the classroom side, which will automatically release the latch and any accompanying dead bolt in a single operation.

Existing and New Construction, Classroom Security, and Hardware Retrofits. Schools frequently ask whether older classroom hardware must be replaced immediately, or if upgrades can wait until remodeling occurs. In accordance with current Wisconsin codes, unapproved standalone barricade devices are strictly prohibited on any door at any time. Under SPS 314 (NFPA 1) and the Wisconsin Commercial Building Code (Chapters SPS 361–366), which also includes the International Building Code (IBC) and NFPA 101 (Life Safety Code), unapproved devices violate life safety mandates. Specifically, they fail to meet the requirements for single-motion egress (requiring more than one releasing operation to exit), violate accessibility standards (ADA compliant hardware cannot require tight grasping, pinching, or twisting), and void the fire door listing because they are unlisted modifications to a rated assembly. Schools are generally not forced to replace older, pre-existing mechanical locksets, solely due to code updates, provided those locks were legally approved and installed under the code in effect at the time. Upgrading to current, code-compliant classroom security locksets, which allow school staff to lock the door securely from the inside without opening it, while maintaining single-motion free egress from the classroom side is officially triggered and required during new construction projects, major building alterations or renovations (governed locally by the Wisconsin Commercial Building Code and the International Existing Building Code) and routine hardware replacements when worn-out or broken locksets are replaced for new ones.

Annual Inspections for Fire-Rated Doors. Another common oversight involves the maintenance of fire-rated doors. Schools install fully compliant hardware during initial construction, only to overlook the fact that door components naturally degrade under heavy, daily student and faculty traffic. Under NFPA 80 (Standard for Fire Doors and Other Opening Protectives), which is incorporated by reference and enforced under SPS 314 for the inspection and maintenance of existing fire safety features in public buildings, all fire-rated door assemblies must undergo a physical inspection and operational test at least annually. These required inspections verify that latches, hinges, and closing devices operate properly without binding, sagging, or failing to latch securely into the frame. Routine annual checks ensure that rated corridor and stairwell doors will perform as vital smoke and fire barriers during an emergency.

Additional questions regarding SPS 314, NFPA 1, and NFPA 101 requirements, please contact your Fire Prevention/Health and Safety Coordinator.

Current Code References

IBC 2021- 1010.2 Door Operations. Except as specifically permitted by this section, egress doors shall be readily openable from the egress side without the use of a key or special knowledge or effort.

IBC 2021- 10.2.1 Unlatching. The unlatching of any door or leaf for egress shall not require not more than on motion in a single linear or rotational direction to release all latching and all locking devices.

Exceptions:

  1. Places of detention or restraint

  2. Where manually operated dead bolt locks are permitted by Section 1010.2.5

  3. Doors with automatic flush bolts as permitted by Section 1010.2.4, Item 4.

  4. Does from individual dwelling and sleeping units of Group R occupancies as permitted by Section 1010.2.4, Item 5.

IBC 2021- 1010.2.2 Hardware. Door handles, pulls, latches, locks and other operating devices on doors required to be accessible by Chapter 11 shall not require grasping, tight pinching or twisting of the wrist to operate.

IBC 2021- 1010.2.8, In Group B Educational occupancies and Group I-e occupancies, egress doors from classrooms, offices, and other occupied rooms with locking arrangements designed to keep intruders from entering the room shall comply with all of the following:

  1. The door shall be capable of being unlocked from the outside of the room with a key or other approved means.

  2. The door shall be openable from within the room.

  3. Modifications shall not be made to listed panic hardware, fire door hardware, or door closers.

  4. Modifications to fire door assemblies shall be in accordance with NFPA 80.

Remote locking or unlocking of doors from an approved location is permitted in addition to the unlocking operation in item 1.

  • NFPA 1, 2012- 14.5.2.1 Door leaves shall be arranged to be opened readily from the egress side whenever the building is occupied. [101:7.2.1.5.1]

  • NFPA 1, 2012- 14.5.2.3 Locks, if provided, shall not require the use of a key, a tool, or special knowledge or effort for operation from the egress side. [101:7.2.1.5.3]

Code compliant door locking options referenced in the NFPA 101 code must ensure:

  • Unlocking and unlatching from the egress side does not require the use of a key, tool, or special knowledge.

  • The locking means are capable of being engaged without opening the door.

  • The releasing mechanism for unlocking or unlatching is at a height between 34” and 48”.

  • Locks if remotely engaged are capable of being unlocked without the use of a key, tool, or special knowledge.

  • The door is capable of being unlocked and opened from outside the room with the necessary key or credential.

  • The locking means does not modify the door closer, panic hardware, or fire exit hardware, or impair their function.

  • Modifications to fire door assemblies and hardware follow NFPA 80.

  • Staff have training in the engagement of the mechanisms from both sides of the door, and the emergency action plan addresses the locking and unlocking use of the mechanisms.

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