Appeal 15090

OSSC 1008.1.9.9

1008.1.9.9 Electromagnetically locked egress doors. Doors in the means of egress in buildings with an occupancy in Group A, B, E, M, R-1 or R-2, and doors to tenant spaces in Group A, B, E, M, R-1 or R-2, shall be permitted to be electromagnetically locked if equipped with listed hardware that incorporates a built-in switch and meet the requirements below:

1. The listed hardware that is affixed to the door leaf has an obvious method of operation that is readily operated under all lighting conditions.
2. The listed hardware is capable of being operated with one hand.
3. Operation of the listed hardware directly interrupts the power to the electromagnetic lock and unlocks the door immediately.
4. Loss of power to the listed hardware automatically unlocks the door.
5. Where panic or fire exit hardware is required by Section 1008.1.10, operation of the listed panic or fire exit hardware also releases the electromagnetic lock.

This proposed residential building design includes a parking garage where we propose to use Electromagnetically Locked Egress Doors, serving as the required exit access doors from the parking areas (S-2 occupancy) in to the elevator lobby and exit stairs (R-2 occupancy). Although permitted in R2 occupancy, these doors are serving the S2 parking garage. The following mitigating measures are proposed:

1. Use of the parking garage will be limited to residents who have access control fobs or other means to open the doors during normal use.
2. An alarm pull station will be provided adjacent to the doors.
3. The doors will unlock without access controls in the event of an alarm or loss of power.

The doors will meet all other requirements of section 1008.1.9.9.
See Plan for more information.

The parking garage access is restricted to building residents. Controlled access ensures that only building residents can enter the building. This is essential to maintain a secure environment for building residents.
The code allows for an Electronically Locked Egress Door in Group A, B, E, M, R-1 or R-2 uses. Although the parking garage is classified as S2 occupancy it is serving the R2 occupancy, which is the primary occupancy of this building. All building residents will be intimate with the parking area and will use building provided access controls for entering the stairs from the S-2 parking area. In case of a power failure or an alarm the doors will unlock and occupants will be able to exit the area without the need to use access controls.
Since the parking garage is restricted to the building tenants they will always have access to passage through the doors. Any person that is not a resident will be accompanied by a building resident or will not be able to get into the garage in the first place. The IBC commentary clarifies that the code intent is to permit these types of locks in occupancies, where there is an overriding security concern, which is the case here. It further clarifies that these doors are permitted in low hazard occupancies. An S2 occupancy is the lowest hazard occupancy. The garage is not a public garage. Building Residents will be familiar with the layout; the potential hazard level is further reduced. Therefore, the proposal to use an electronically locked door in this situation does not conflict with the code intent and provides equivalent protection. We request that the proposed design be approved.