Grandfathering Old SCIF’s Will Not Last Forever

Converting Existing SCIF’s To Updated ICD705 Tech Specs, GSA FF-L-2890B and NFPA101 Life Safety Laws

There are probably ten times the number of old SCIF’s that don’t meet the new requirements then there are newer SCIF’s that do.  As long as the older SCIF’s are covered by grandfathering exceptions to the new requirements, you should not have any major new planning and budgeting to do for converting your old SCIF.  However, the current grandfathering does not cover spaces that are having at least one third of their perimeter changed or by spaces that have been deaccredited and are looking for reaccreditation.  The accrediting officer (AO) can also dictate when a SCIF upgrade is required. Perhaps more important is the certainty that grandfathering older SCIF’s will not last forever and it is something that you should be planning and budgeting for now.

This interpretation of the current grandfathering exception does not extend to the NFPA101 Life Safety Laws which require single motion mechanical egress on any door in the “means of egress”.  This means that any door in the means of egress, whether it be access doors, egress doors or exit doors that have two or more locks must be converted to meet the new laws.

You will have to consider the overall changes to SCIF walls, ceilings, floors, electrical and electronic security systems when you make your upgrade.  Information on this is available in another tutorial in this series.  We are going to treat the problem of SCIF doors specifically in this tutorial.

The most recently updated publication of ICD705 Tech Specs contains a number of significant modifications in requirements for SCIF doors and locks. One of the more significant changes deals with field STC ratings for acoustical doors and in fact, the construction of the doors themselves. Prior to the new requirements of ICD705 you could use wooden doors if they had a STC rating of 45 or above. Since the newest changes to ICD 705 Tech Specs became effective, only out-swinging metal SCIF doors are permitted.

This has also resulted in a different approach to sealing the primary sound gap between the four edges of the door, frame and threshold. In the old days using a wooden door you could install a sound resistant seal on both jambs and the header with an automatic door sound seal at the threshold. With the new regulations, it has become necessary to choose a metal door assembly that not only meets all of the requirements of ICD705 but also has an integral door, frame, sound seals and threshold as a package.

An example of such doors are those made by door manufacturers such as Overly Door Company, which markets metal acoustical doors that meet the general standards described so far.  Their doors use both magnetic and compression seals that will stand up to the new field STC requirements as well as the requirements of ASTM Designations E90-09 and E413-10, as well as other pertinent standards, which are the approved test methods for measuring airborne sound attenuation.

If you have not yet met the life safety requirements of NFPA101 for doors in the means of egress, this will have to be part of an immediate upgrade plan.  This means that you will need to replace the current locks on your SCIF doors, or, in fact, on any door, in the means of egress that has two locks with a single motion mechanical egress device.  This type of lock makes it possible to unlock all of the locks on a door with one mechanical motion.  Currently the only locks that are available in the marketplace that meet this requirement and are GSA approved are the Sargent and Greenleaf  S&G 2890B single motion mechanical egress locks.  These locks are not only GSA approved but also meet both the NFPA101 Life Safety Laws as well as UL rating requirements in both an exit bar and a handle version.

It is also important to be sure that all of the parts of a SCIF door package fit together into a cohesive operating system.  For example, it is a wise idea to use a metal acoustical door assembly that supplies magnetic seals or compression seals depending the type of GSA approved SCIF lock that you choose.  This is not only important because it gives you a better door operation but also meets the requirements for security and field STC ratings.

One more suggestion is to use installers for these locks who can give you evidence that they are factory trained and certified on all of the components of the SCIF door.  This includes not only the SCIF door itself but also GSA approved life safety locks and the combination lock that is mounted on the lock itself. Difficulties with both the immediate installation as well as the long-term performance of the SCIF door and locks, is dependent more on the quality of the installation than it is on the materials themselves.  It is very tempting, from a cost stand point, to select the installation company on the basis of lowest bid rather than demonstrated qualifications.  In most states there are laws that require licensed locksmiths to perform lock installation, repair and servicing.  Not only is it a good idea to follow the law, where required, but the additional benefit of using installers who are trained and licensed locksmiths who have experience in installing a broad variety of locking systems.  Our advice is to consider the long-term costs in your selection as well as the immediate cost including indirect costs such as staff required to deal with frequent periods of non-operation while repairs are being schedule and completed.  It is has also been our experience that if you use one contractor to the do the entire door from beginning to end, you will wind up with a more satisfactory situation.

 

This tutorial was written by Harry O’Haver,  President, Industrial Security Locking Systems,  LLC.  Mr.  O’Haver is recognized as an expert in the field of acoustical doors, high security locks and government requirements for SCIF’s including ICD705 Tech Specs, NFPA101, ADA, etc.  Mr. O’Haver is a master locksmith as well as a former two-term Chairman of the Chesapeake Chapter of the American Society for Industrial Security.

 Also contributing to this tutorial is Mark  Jones.  He has been involved in the secure space field since 2000.  He is a subject matter expert regarding UL681 alarms and UL2050 monitoring.  Mr. Jones helped develop and teach the first non-classified SCIF construction management class through Frederick Community College in Maryland.  He worked with the Maryland Department of Economic Development to start the SCIF construction tax credit program.  He currently consults on SCIF construction projects nationally and is involved with turnkey delivery of SCIF space in the mid-Atlantic region.

 Both Mr. O’Haver and Mr. Jones are founding members of the SCIF Technical Advisory Group (STAG) which is a consortium of companies that work and consult together on both new SCIF’s and old SCIF’s that require conversion.