Maintaining physical security for the health care environment is often a tricky proposition balancing best practices, regulations and available technologies.
The need for a secure hospital is recognized by most authorities having jurisdiction (AHJs) and keeping unauthorized persons from entering a facility clearly is addressed in the codes. However, the hospital's need to lock egress doors in the direction of exit travel remains a major code-compliance challenge.
While there are many different types of systems to secure a facility, until recently there has been little guidance from the International Building Code (IBC) or National Fire Protection Association's NFPA 101 Life Safety Code (LSC) on how to implement this technology.
New code criteria
The current 2009 edition of the LSC has added new code criteria to allow the locking of doors in the egress path in the direction of exit.
Prior to the 2009 edition of the LSC, the only egress doors allowed to be secured in health care occupancies were those that were locked for the clinical needs of the patients in areas such as psychiatric or Alzheimer's units.
These units are allowed to be locked at all times, provided they are staffed at all times and the staff has ready access to the door keys. Current and previous IBC editions have allowed locking of egress doors for the clinical needs of patients in "mental hospitals" similar to the LSC allowance. There were no requirements or allowances to lock doors to areas other than for the clinical needs of the patient.
Newborn nurseries are an example of a security need that falls outside the clinical requirements of the patient. Clearly the need to keep infants safe from abduction is unique to the nursery. But there is not a clinical need to secure the area. The new sections of LSC address the security needs of these patient areas.
The 2009 edition of the LSC differentiates between the clinical needs of a patient and the security needs of the patient and staff. Clinical needs are related to the treatment of the patient. Medical staff must evaluate and determine if special locking or access to a patient is required for clinical purposes.
The security needs address civil unrest, natural disasters, special detention and escapes. They are unique to many areas in a health care facility.
Emergency departments, for instance, may want the ability to lock down the department to control a civil disturbance or prevent patients, guests and staff from leaving the department if there is a contamination problem.
Other units and areas of the health care facility need to be secured as well. Pediatric units need to protect their patients from the general public, for example. Abduction and runaways are a major concern of facility operators.
Nurseries, pediatric units, emergency departments and similar areas under the current editions of IBC or 2000 to 2006 editions of LSC cannot be locked in the direction of egress. Facilities are securing these areas in a number of ways that may be state-of-the-art but do not provide a code-compliant way to secure an area.
To provide a code-compliant solution, using IBC or a pre-2009 edition of the LSC, an approved alternate method of compliance or equivalency is required to document the method of securing the doors. The equivalency must be approved by the local AHJ, the Joint Commission and the Centers for Medicare & Medicaid Services (CMS). This documentation must be maintained for the time the secured area exists.
Because there has been little guidance in LSC or IBC for secured doors in the egress paths, there are many ways the locks have been arranged. Some arrangements allow for emergency unlocking and some do not. To develop consistent criteria, LSC developed special locking configurations for health care occupancies. This configuration addresses the security needs of the facility staff, visitors and patients.
LSC 2009 provides two ways to secure egress doors in health care facilities. The clinical locking arrangements are described in Section 18.104.22.168.5.1 and 22.214.171.124.5.1. These requirements, which have been in the code for many years, include the following:
1. Staff can readily unlock the doors at all times.
2. Provisions shall be made for rapid removal by remote locks; keying all locks to keys carried by staff at all times; or other such reliable means available to staff at all times to open the locked doors.
Staff are required to have keys, access to keys or door-release codes for the secured area. The staff are an integral part of the egress plan for these secured areas. There are no special fire protection requirements for the secured area.
In the 2009 edition of the LSC, Sections 126.96.36.199.5 and 188.8.131.52.5 were rewritten to acknowledge the need for securing areas to confine and protect the building occupants. These changes set the general allowance for securing doors.
Sections 184.108.40.206.5 and 220.127.116.11.5 now have two options for securing doors in health care occupancies. Doors can be secured for the clinical needs of the patients per Section 18.104.22.168.5.1 or 22.214.171.124.5.1, as described previously. The second reason to secure health care doors or areas is for the security needs of the patients. This method must follow Section 126.96.36.199.5.2 or 188.8.131.52.5.2. Criteria for securing doors for the security needs include the following:
- Staff can readily unlock the doors at all times.
- Provisions shall be made for rapid removal by remote locks; keying all locks to keys carried by staff at all times; or other such reliable means available to staff at all times to open the locked doors.
- A total smoke detection system is provided throughout the locked space or locked doors can be remotely unlocked at an approved, constantly attended location within the locked space.
- The building is protected throughout by an approved supervised automatic sprinkler system.
- The locks are electrical devices that fail safely so as to release upon loss of power to the device.
- The locks release by independent activation of smoke detection described previously or water-flow switch activation for the automatic sprinkler system.
A code-compliant clinical locking arrangement relies on the staff to open the locked doors. This locking arrangement can occur in sprinklered or non-sprinklered buildings with or without smoke detection. LSC 2009 will allow the areas secured for clinical needs to follow the arrangements allowed for the secured needs in health care (Section 184.108.40.206.5.2 or 220.127.116.11.5.2).
Areas locked for the security needs of the patients are allowed to unlock by keys, but required to unlock by the activation of the secured area smoke detection or remote unlocking switch in the secured area or automatic sprinkler activation anywhere in the building. Loss of power will cause the locks to release. The unlocking required by Section 18.104.22.168.5.2 or 22.214.171.124.5.2 will happen automatically and could be done manually by the staff. The clinical secured doors only have to release by operation of the locking device by staff.
The major differences between the locking requirements for clinical needs and for security needs are that nonclinical involve added fire protection to the space. In the clinical setting there is an assumption that staff are in close proximity to the patients at all times. While that assumption holds for the security needs requirements, the system also will unlock without manual intervention.
The added requirements for smoke detection, remote unlocking from within and automatic sprinklers for the building address the NFPA technical committee's concerns over locking doors in the means of egress. The smoke detection or remote unlocking allows for the quick and automatic release of the doors in a fire emergency within the space. The automatic sprinkler requirements for the building will unlock the doors if there is a fire emergency in the building. The secured area will have access to an unlocked egress system through a robust configuration of the fire protection systems.
The new LSC locking criteria only apply to jurisdictions that have adopted the 2009 edition. CMS and the Joint Commission use the 2000 edition of LSC. A waiver or traditional equivalency approved by CMS or the Joint Commission would be required to use the locking configuration allowed by the 2009 LSC.
The IBC does not have an option to lock doors in the egress path similar to LSC. Compliance with IBC would require an alternate method of compliance and acceptance by the local building and fire officials. The alternate method of compliance can be based on LSC 2009 criteria, but would require the approval of local officials.
While there are nationally recognized methods of securing egress doors for health care facilities in LSC 2009, the installation of these normally low-voltage systems may not receive the same level of review and inspection as the main electrical system or fire alarm. The coordination needed between the fire alarm and security system may not be tested.
The LSC criteria necessitate the integration of fire alarm system, automatic sprinkler system and loss of power to properly release the locked egress doors. System testing should address all the required releasing configurations listed in the LSC 2009.
Nationally recognized code
There is now a recognized code to secure egress doors in the direction of exit travel in health care occupancies.
The LSC 2009 criteria may not be the adopted code for a hospital, but it can be used as a guide and justification for an equivalent way to secure a health care occupancy.
Michael A. Crowley, P.E., FSFPE, SASHE, is senior vice president at Rolf Jensen & Associates Inc., Houston. He can be contacted at firstname.lastname@example.org.