G88-25: When Will We Make Our Schools Safer? Part II

by Thom Zaremba, shareholder at Roetzel & Andress

Last month, I reported that an International Code Council (ICC) Committee responsible for approving and disapproving the building code proposed adding ASTM F3561. Adopting ASTM F3561 would provide school designers with an objective, reproducible, mechanical test to evaluate the ability of glass windows, doors and other types of glass in entryways to resist a gunman’s efforts to enter our schools.

The main testimony opposing adding ASTM F3561 to the building code came from a former fire code official and an Ohio building code official. The fire code official testified that because only a “few” assailants had shot their way through glass entryways to get into schools, the building code didn’t warrant “forced-entry resistant” glazing requirements. The Ohio building code official testified that “hardened” or “forced-entry resistant” glazing would slow law enforcement from breaking into schools in an emergency.

Are these valid reasons for not adding ASTM F3561 to the building code? Let’s take a closer look.

First, let’s look at the argument that not enough assailants have shot their way into schools – yet -to warrant protecting schools by adding “forced-entry resistant” glass to the building code. That argument shocked me, especially coming from a former fire code official! My initial reaction was, “How many gunmen shooting their way into our schools is enough to warrant protecting them with ‘forced-entry resistant’ glass? Is 10 times enough? How about only five? Or is just once enough?”

Let’s look at two mass shootings where the assailants entered the school by shooting out glass from locked entryways.

The first—and one of the worst in American history—is Sandy Hook Elementary School. There, a 20-year-old shot out a window next to the school’s locked front entry door and walked in. Once inside, he shot and killed 26 people, 20 first graders and six school employees. The second is Covenant School in Nashville. A security camera recorded a 28-year-old armed individual walking right into Covenant School after shooting the glass out from two locked double glass entry doors. Once inside, the assailant shot and killed six people, three children and three adults.

These two school shootings resulted in the deaths of 23 children and nine adults, not including the shooters. If 32 school deaths don’t warrant the use of “forced-entry resistant” glass to protect school entries from gunmen, then I’m forced to ask if the building code is powerless to help prevent school shootings. I firmly believe that building codes can and must help protect our schools.

Let’s turn to the Ohio building code official’s argument that hardening the entry glass would slow law enforcement’s response to emergencies inside the school. Is that argument valid?

You may remember from some of my earlier blogs that the building code jurisdiction ends when an occupancy permit is issued. Because emergency evacuations and school lockdowns only occur after occupancy permits have been issued, the fire code, not the building code, is vested with post-occupancy jurisdiction over school emergency planning. For that reason, the Ohio building code official who testified against adding ASTM F3561 to the building code may not have known that the fire code enables police and first responders to enter schools without breaking the glass out of locked entry doors.

The fire code requires every school to have emergency evacuation procedures and a “lockdown plan.” That lockdown plan must be approved by the fire service and updated annually, and the “procedures” necessary for unlocking doors throughout the school must be spelled out.

In short, school entrances can be protected from entry by armed shooters without interfering with the need for police and first responders to enter in emergencies. While approved “lockdown plans” required by the fire code can assure school access by first responders, unless the building code authorizes the use of ASTM F3561, the glass used in entry areas will remain a weak link for active shooters looking for a way to harm our kids. The mass shootings at Sandy Hook Elementary and Covenant School prove that.

In my next blog, we’ll discuss glass recycling and its impact on the resiliency of our existing building stock. Until then, however, I’ll continue pushing for safer schools and the adoption of ASTM F3561 by the building code!