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BCA D2.21 Exit Door and Fire Door Lock Regulations (Building Codes of Australia)

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.

Locks used on Exit Doors – which also include Fire Doors and Path of Travel Doors - are governed by Building Codes of Australia (BCA) Ordinance D2.21. Mostly (but not always) these doors are identified by an illuminated green "EXIT" sign above (or leading to) the Exit Door.

Exit safety is paramount, and includes not only fires, but all manner of emergency situations. Situations such as (but not limited to) fires, gas leaks, toxic chemical spills, personal safety, and even bomb threats.

Local Council Building and Fire Inspectors, and the Fire Brigade, are the most common authorities that police compliance of this regulation. The regulation is complex, with numerous legal grey areas, with the ultimate interpretation falling with the inspecting authority.

There are also requirements within workplace OH&S policy to meet this regulation.Local councils also require compulsory annual fire safety certificates, which also encompass compliance with regulation D2.21.

There are three main categories of Exit Doors:

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 used.

EXIT Door: An Exit Door is a door that allows an emergency exit from a building. Dependant on its location, it need not necessarily be fire rated, or steel framed.

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 egress 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 perspiring or wet 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 floor level

In the case of Fire Doors, the lock must be self-latching and be fire rated in accordance with AS1905.1. A fire rated automatic door closer must also be fitted. Only fire rated hardware may be fitted to fire rated doors.

It is a duty of care to ensure that all exit doors are safe and functional and BCA code compliant.

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 in Childcare facilities, which may be 1500mm-1650mm high as necessary.

Fire Door Hardware

Fire Doors must only be fitted with door hardware fire rated in accordance with AS1905.1

Fire Door locks must be self-latching and are not permitted to have a hold open feature. It is an offence to prop open or otherwise interfere with the automatic closing action of a Fire Door. Fire Doors must also be fitted with a fire rated automatic (non hold open) door closer. An automatic closing door is essential in controlling smoke, heat, and destrictive back drafts, which could potentially feed the fire.

Locks or hardware that are replaced must be brought up to current BCA compliance. Ie: If a knob style lock is currently fitted, it must be upgraded to lever action when replaced.

Safety

Personal safety comes before security. Security cannot be upgraded beyond the point of a single D2.21/AS1905.1 compliant lock. Non-complaint deadlocks, multiple locks, locking bolts, padlocks or padbolt type fittings, are all considered dangerous, and are not permitted to be used. The BCA code specifically states that personal safety takes precedence over security.

Panic Bars

Panic Bars, also known as crash bars or exit devices, are deemed necessary where large volumes of people collect, such as in halls or theatres, where there is a high risk of "Crowd Crush".

Crowd Crush is where a uncontrolled volume of people surge against an exit door in an emergency evacuation situation, preventing the door from being opened, and people being crushed or killed in the process. To prevent this from happening, panic bars burst open in an outwards direction when force is applied,

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Comments (10)

Dec 02, 2010
Michael Collins said...
Your comment on the height of locks on Emergency Exits was very informative and cleared up my query. Thank you.
Aug 22, 2011
Latif said...
Do ALL buildings require exit doors ? Say for arguements sake that I have a building with a large roller door entrance and the building is used to store spare parts only and does not contain explosive or flameable goods. Would this building require an additional door for emergency exit ?
Oct 21, 2011
Norma said...
In a domestic home, where there is a glass sliding door, and also a security flyscreen door, is there a regulation height of the lock/snib of the security door ?
Thank you for your assistance.
Oct 24, 2011
David Birds said...
Norma, D2.21 relates to commercial buildings, but for domestice use, it is still good practice to follow their recommendations of 900mm to 1100mm high.
Nov 09, 2011
Ernest Chiu said...
Please clarify -"In the case of Fire Doors, the lock must be self-latching and be fire rated in accordance with AS1905.". Can you show me some details of self-latching? Thanks.
Dec 14, 2011
matt kostos said...
just wanted to know a few things, what website did you get this info from? could you please send me the link via email? do you know if there are special rules for a classroom? and have you ever heard of a classroom ever being to small to need a fire exit?
cheers, Matt
Mar 30, 2012
Roger said...
If a unit has a fire rated door with a rated handle set, can an electronic lock system be installed in addition and still maintain a fire rating?
Apr 03, 2012
David Birds said...
Roger, An electronic lock (or strike) on a fire door is perfectly ok, provided it is fire rated, and it doesn't compromise the mechanical fail safe opening action of D2.21 (eg: magnets)
May 26, 2012
Robert Wood said...
The front door to my unit is a fire door. It is fitted with a lever style Lockwood 3572. Ther is also a modern Lockwood 001 fitted above. Is the 001 permitted under the act?
Regards Rob W
May 26, 2012
Robert Wood said...
The front door to my unit is a fire door. It is fitted with a lever style Lockwood 3572. Ther is also a modern Lockwood 001 fitted above. Is the 001 permitted under the act?
Regards Rob W

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