Lockdown Plans
From the ICC’s “Chapter 4 — Emergency Planning and Preparedness,” Section 404 requires fire safety, evacuation, and (where applicable/approved) lockdown plans.
Here are the key elements (summarized) of what the IFC 2024 Edition requires:
| Subsection | What it requires / key points |
|---|---|
| 404.1 General | Where a fire safety & evacuation plan is required by Section 403, that plan must also comply with the provisions in 404.2–404.4 (fire safety, evacuation, and lockdown where applicable) |
| 404.2 Plan Contents & Lockdown | The plan must include: |
| • Identification of individuals who can issue lockdown (and terminate it). | |
| • Security measures in regular (normal) operations that could interfere with egress or fire department operations. | |
| • Description of emergency/security threats addressed and associated lockdown procedures. | |
| • Means and methods for initiating lockdown for each threat, including: a distinct notification method (different from fire alarm), which doors/access points will be secured, how they will be secured, and how locking complies with egress/accessibility (§404.2.3.1). | |
| • Procedures for reporting to fire department any lockdown condition that affects egress or fire operations. | |
| • Procedures for determining and reporting who is onsite / absent during the lockdown. | |
| • Two-way communication between “central location” and each area that may be secured during lockdown (with some occupancy-type exceptions). | |
| • Identification of the pre-arranged signal for terminating lockdown and who can issue the termination. | |
| • Procedures to unlock doors and verify that egress has been restored to normal after lockdown. | |
| • Training procedures and frequency of drills for lockdown plan. | |
| 404.3 Maintenance | The fire safety, evacuation, and lockdown plans must be reviewed/updated at least annually, or sooner if there are changes in staff assignments, occupancy, or layout of building. |
| 404.4 Availability & Distribution | Plans must be kept available in the workplace; copies given to the fire code official upon request. Also, distributed to tenants, building staff; relevant parts given to employees so they know their roles. |
It is important to note that Tennessee has not yet adopted the 2024 edition of the IFC; the statewide minimum code is still the 2021 IFC, plus Tennessee has specific amendments.
Here’s what that means for lockdown plans in Tennessee:
| Requirement | In Tennessee under the adopted 2021 IFC + amendments | Notes / Differences vs. model 2024 IFC |
|---|---|---|
| Lockdown Plan Requirement | Under 2021 IFC (Section 404), lockdown plans are permitted (or required if used) only where approved by the fire code official and in compliance with specific contents. | |
| Contents | The 2021 version requires many of the same items as the 2024 model: who can order lockdown; how doors/access points will be secured; etc. | |
| Drills & Training | Required under the 2021 code; drills must be conducted according to the approved plan. Training is required. | |
| Maintenance, Distribution, Availability | The 2021 IFC in Tennessee mandates that fire safety, evacuation, and lockdown plans be reviewed/updated annually or when needed; that the plan be available; that parts be distributed to staff/tenants. | |
| Locking Means & Egress / Accessibility | Tennessee’s code requires compliance with existing rules for egress and accessibility (doors, locking methods etc.), similar to the model code. |
Key Differences & What to Watch For
When comparing the model 2024 IFC requirements vs what Tennessee has right now, here are some things to pay special attention to:
- Adoption Date
- Since Tennessee has not yet universally adopted IFC 2024 for all jurisdictions, some places still enforce the 2021 version. So if you are dealing with a facility in Tennessee, check which code version the local fire code official enforces.
- Local Amendments
- Tennessee may have specific amendments (for example, in how locking devices are allowed, stipulations for school or classroom doors). These can modify or restrict what the model code says.
- Scope & Approval
- Under Tennessee’s 2021 code, the lockdown plan must be approved by the fire code official. It may not be acceptable to simply write a plan without obtaining that approval.
- “Permitted” vs “Required”
- Model 2024 IFC suggests that lockdown plans are required when certain threat conditions are identified. Under Tennessee’s 2021 code, they are allowed/permitted and required if used or if required by the jurisdiction. So usage may be less mandatory in places unless specified.
- Notification Methods
- Having a notification method distinct from the fire alarm signal is emphasized in the model. Tennessee’s 2021 edition also requires that.
What You Should Do / Implement Given Both
To be compliant (both with model code expectations and what Tennessee requires), here are recommended steps:
- Check whether your facility is governed under the 2021 IFC or whether your jurisdiction has adopted 2024, or has amended versions. Ask your local fire marshal.
- Ensure you have a written plan that covers both fire safety & evacuation, and—if you decide to or are required to—lockdown procedures.
- Use the model list of required contents (as listed above) as a checklist. Make sure to include who can order lockdown / end lockdown, door locking/access, communication, etc.
- Make sure the plan is approved by the fire code official if required in your area.
- Conduct drills and training per the plan; update it annually or when changes occur.
- Provide copies or parts of the plan to staff, building service employees, and tenants; keep the plan available for review.