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A guide to Commercial Door Lock Regulations for Fire and Exit Doors

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Includes Building Codes of Australia BCA D2.21, and Australian Standards AS1905.1 and AS1428.1

Exit Doors are a critical part of the fire and safety infrastructure of a building. By law there are very specific locking requirements required for Exit Doors.

In years gone by, Fire/Exit Doors were viewed solely for use as emergency Fire Exits, but that view has changed. Exit Doors are now used for emergency egress of all kinds, not just fire emergencies. Exit safety is paramount and includes not only fire exit but all manner of emergency situations. Situations such as fires, gas leaks, toxic chemical spills, threats to personal safety, and even terrorist threats - to name but a few.

Accordingly, Exit Doors must comply with multiple codes and requirements.

  • BCA D2.21 (Emergency Exits)
  • AS1905.1 (Fire Rating)
  • AS1428.1 (DDA / Disabled Discrimination Act)  

Locks used on Exit Doors, which also include Fire Doors and Path of Travel Doors, are governed by multiple authorities. These doors are generally - but not always - identified by an illuminated green "EXIT" sign above the Exit Door, or directing the evacuation path of travel towards an Exit Door.

Local Councils and the Fire Department are the most common authorities that police compliance of this regulation. The regulation is complex, ambiguous, with the ultimate interpretation falling with the inspecting authority.

Local Councils also require compulsory annual fire safety certificates, which also include mandatory compliance with D2.21.

There are three main categories of Exit Doors:

  1. Fire Door: A Fire Door is a door that enters a fireproof stairway or tunnel. The door itself is made from a special fire resistant material, and has a fire rating compliance tag fitted to the hinge edge of the door. A steel fire resistant door frame is also fitted. Automatic doors closers are also mandatory.
  2. Exit Door: An Exit Door is a door that allows an emergency exit from a building. Dependent on its location, it need not necessarily be fire rated, or steel framed.
  3. Path of Travel Door: A path of travel door is a door in the egress pathway leading to, or between, a Fire Door or Exit Door.

D2.21 Compliance

  • The opening action of a lock must be a single handed downward lever action. A pushing action is also allowed, and is preferred.
  • Internal knobs or turn snibs are not permitted. This provision takes into account the need for an emergency opening mechanism to be operable by people with hand or arm related disabilities, burns to their hands, with wet or perspiring hands, or the aged or infirm.
  • The opening mechanism should be capable of being operated by a "nudging action" whilst dragging an injured or unconscious person to safety.
  • Key locking in not permissible on the egress side (inside) of the door.
  • Only one lock per door is permissible.
  • Locks must be fitted at a height of between 900mm and 1100mm from the finished floor level

Fire Door Hardware

Fire Door locks must be self-latching and be fire rated in accordance with AS1905.1. Fire Doors must also be fitted with an AS1905.1 fire rated automatic door closer. It is not permissible to have a hold open feature on either the lock or door closer. Any additional door hardware must also be appropriately fire rated.

Lock Heights

Door lock heights on Exit Doors, Fire Doors, Path of Travel Doors, and Disabled Access Doors now have a standardised lock height of 900mm-1100mm. The exception being locks fitted in Childcare facilities, or swimming pools, which may be fitted 1500mm-1650mm high as deemed necessary.

Safety

The BCA code specifically states that personal safety takes precedence over security. Security cannot be upgraded beyond the point of a single compliant lock. Non-complaint deadbolts, multiple locks, locking bolts, padlocks, padbolt fittings or chains, are all considered dangerous, and are not permitted to be used. It is an offence to prop open or otherwise interfere with the automatic closing or latching action of a Fire Door. An automatic closing and latching door is essential in controlling fire, smoke, and dangerous "back drafts", which can potentially feed the fire.

Panic Bars

Panic Bars (also known as crash bars or exit devices) are deemed necessary in areas where large crowds can collect, such as in halls or theatres where there is a high risk of "Crowd Crush". Crowd Crush is a situation where a uncontrolled gathering of people surge towards an exit door in an emergency evacuation situation. This prevents the door from being opened, and people being crushed or possibly killed in the process. To prevent this life threatening situation from happening, outward opening doors with panic bars are fitted, which safely burst open in an outwards direction when force is applied.

Disability Discrimination Act Compliance (AS1428.1 DDA)

All commercially fitted doors, internal and external, including Emergency Exit Doors, must comply with DDA/AS1428.1 

  • The locks must have a DDA compliant Lever handle (or push bar)
  • A distance of 35mm to 45mm between the lever handle and door face
  • A 20mm return on the end of the lever to stop the hand slipping off
  • Knobs are forbidden

*Please note that this document is to be used as a guide only, and that authoritative direction must be sought from the relevant governing authorities.

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