Padlocks, Fire Code snags

[Brothers Vilgalys Spirits]

We've run into a catch-22 beween the security requirements and our fire code. The TTB has some pretty specific requirements about padlocks to go on entrances to storage areas, or for large tanks. They go into detail about what sort of padlocks to get here:

http://ecfr.gpoacces...1.1.15.7.171.12

(CFR 27.19.192)

However as our locksmith and local fire inspector both pointed out, we can't padlock our front door because of the potential for someone to be locked inside. Our facility has a roll-up door and a side office door. The only fire exit is through that front door.

The locksmith recommended a storeroom-type lock that locks automatically and always requires a key to open. I'm also planning on installing a security system.

Has anyone else had experience finding a compromise here? I'm intending to specify a variance on the application explaining my "unusual" lock, but wanted to check and see what y'alls thought are about this were.

Thanks!

Rim Vilgalys

[Ralph at Tuthilltown]

Your obligation is to "protect the revenue". Padlocking doors which serve as fire escapes is obviously an issue. We have rolling garage doors which are secured by only the locks which came with the doors. Our bottling room in another building is secure the same way. One answer may be to install motion detectors in your bonded spaces. Our storage areas are padlocked. You may be able to meet the regulatory requirement by padlocking only the spirits storage areas since those are where the spirits (the "revenue") is located. Offices and shop spaces containing tax paid goods may not require the specified padlocks. They are mainly concerned with the "tax unpaid" goods and ensuring no one has unauthorized access.

[porter]

These are the key points.

(2) Indoor tanks used to store spirits, or the door from which access may be gained from the outside to the rooms or buildings in which such tanks are housed; and

(3) Any doors from which access may be gained from the outside to rooms or buildings containing spirits stored in portable bulk containers.

Put up a wall with a lockable door for the 'padlock' to satisfy the untaxed storage requirements. They don't care what you do with the stuff once the tax is paid.

'Ralph' is correct.

[Brothers Vilgalys Spirits]

Thanks for the responses!

I should be more specific about the space we're working with -- essentially we have one of those concrete box industrial condos with an office and bathroom in the front corner. I'm planning on painting a line dividing the bonded space from the regular space, so that I'll have a shipping/receiving area next to the loading dock.

Even padlocking the door from the office to the bonded space, we run into the issue of fire egress because our only fire exit is through that door. And we can't create a situation where someone could potentially be locked inside.

I do have a security system on the way with motion detectors and those doodads that detect when a door is open.

[porter]

Venturing into grey area here, but I don't believe the 'painted line' for bonded/unbonded space will not fly. Bonded has to be a controlled area. In your case the entire space will need to be bonded, or a secure wall constructed to partition a bonded space off.

Again......a little grey but I think the TTB will require a hard partition.

As for your locking problem, build a small room in a corner with 2 interior walls and a door, using the 2 exterior walls, and put a padlock on it with the unbonded bulk product in the small room. Unless you simply want a single open room, this is an easy fix and should still allow a padlock without any fire reg problems. Find out how large a room you have a padlock entrance on. There are many industrial rooms that don't allow exit from within, but most areas only allow a certain size.

I'm through....nothing further.................

[bluestar]

We have just run into the same problem. The local fire protection entity makes the final decisions on what is required for safety, and they can require that all occupiable space be free to exit, and they can define almost any space as occupiable. So, in our case, they have not accepted the use of the padlocks for this purpose. The only way around this as far as we know is to ask for the exception. The biggest issue with the exception might be the requirement for key retention in the lock, if you are planning to use standard door locks.

[Brothers Vilgalys Spirits]

At least I'm not the only one who's run up against this. We're probably also going to try and get a variance on the TTB application, as I think fire safety is arguably more important than picking a specific type of lock.

"Storeroom-type" locks are what we're probably going to put in, they stay locked from the outside all the time. This one also has a key-capture feature, and I'm trying to get an answer about how many pins the lock has:

http://www.iqhardware.com/yale_yh_cs_79_cascade_storeroom_lever.asp

Plan B is to padlock the inside door with big letters that say "This door to remain unlocked when the building is occupied." It's not quite up to code fire-wise, as you're supposed to be able to unlock it from the inside, but we might be able to come to terms with our fire inspector if the TTB won't budge.

[leftturndistilling]

I know its been a while for this ..But I see you recieved your DSP.... How did you resolve this issue????.... thanxxx in advance...

[Brothers Vilgalys Spirits]

We ended up with the storeroom lever linked above. It's 6-pin and key-retaining but only needs a key from the outside. I submitted a scan of the lockset specifications with our statement of security. We also have an alarm system with motion and entry detection, along with a smoke alarm, that will call me if anything happens. And it may have helped that we have pretty much a 'concrete box' with no other entry / exit.

I also had a padlock that met those specs for the garage door.