Under the Deemed-to-Satisfy provisions of the Building Regulations 2006 there are three important concessions in the Building Code of Australia (BCA) for exit doors and doors in the path of travel. These concessions permit doors to be provided with non-lever door furniture and dead-latching (Clause D2.21):
- Apartments, flats or the like within Residential buildings;
- Sole-occupancy units in Office, Retail, Warehouse or Factory type occupancies where the floor area is not more than 200m2; and
- “A space which is otherwise inaccessible to persons at all times when the door is locked”
At a practical level these concessions recognise some common security concerns for store rooms etc and also mean strip type shops, offices, lockups etc can use non lever door furniture and non escape type latching. Let’s look at these concessions in more detail.
The concession for Residential buildings is consistent with the concept of a domestic dwelling where there occupier has control over the space.
The concept of a sole occupancy unit within a “commercial or industrial” type occupancy is not immediately clear. Probably the best way to explain it is to think of a commercial tenancy which occupies all of a (relatively small) floor (< 200m2) versus a floor occupied by multiple tenancies (each < 200m2. The floor with multiple tenancies is going to have an area to provide public access (or common property) for people to access any of the tenancies. Doors in this space outside the tenancies which can be accessed by any occupant of any of the tenancies or the public must be fitted with lever door furniture and openable without a key.
The third case means we can issue a building permit to allow a deadlock, deadlatch even a nightlatch for a room with only one access point. This concession means that any space like a person’s office, plant room, cleaner’s room, store room etc where there is only one entry and no other way for a person to enter the room and find themselves unable to get out a door is permitted to have door furniture other than a lever and non-escape type latching.
These concessions are certainly permitted for compliance with the mandatory performance requirements by using the BCA Deemed-to-Satisfy provisions, but there may be circumstances where the use of the space under other legislative and common law frameworks may require a higher duty to be exercised. Architects and Building Designers certainly need to be aware of their duties as a designer under S28 of the Occupational Health and Safety Act 2004. For rooms with a single access e.g. store rooms for dangerous goods, hazardous substances, plant rooms, areas occupied by children etc, where there is an increased risk to the occupier by the nature of the use, strong consideration should be given to providing escape type latching with lever type door furniture.
Tags: BCA, Building Permits, Building Regulations 2006, Door furniture, Escape Latch, OH&S, S28

