OHIO LEGISLATIVE SERVICE COMMISSION
Office of Research Legislative Budget
www.lsc.ohio.gov and Drafting Office
S.B. 112 Final Analysis
135th General Assembly
Click here for S.B. 112’s Fiscal Note
Primary Sponsor: Sen. Rulli
Effective date: October 24, 2024
Effective date:
Carla Napolitano, Attorney
SUMMARY
▪ Requires protective door assemblies in certain school buildings to comply with the
standards of the National Life Safety Code (NFPA 101) developed by the National Fire
Protection Association in effect at the time the protective door assembly was installed
or the building code standards in effect at the time of installation.
▪ Requires school governing authorities to verify compliance of those protective door
assemblies by causing an annual inspection to be conducted by a qualified inspector.
▪ Requires school governing authorities to maintain records of those inspections.
▪ Requires the authority having jurisdiction to annually inspect those records to monitor
compliance with the act’s requirements.
▪ Requires the authority having jurisdiction to issue a citation to a school governing
authority if a protective door assembly in a school building remains noncompliant for
more than 18 months after the first failed inspection, or more than 180 days following a
subsequent failed inspection.
▪ Prohibits a citation if the school governing authority is taking steps to achieve
compliance.
▪ Prohibits assessing a civil penalty or fine with the citation but requires the school
governing authority to post the citation on its website.
▪ Allows a school governing authority to appeal a citation under the act in the same
manner as other Ohio Fire Code citations and penalties.
▪ Specifies that a temporary door-locking device in compliance with rules adopted by the
Fire Marshal is compliant for the purposes of the act, regardless of any contrary
standards of NFPA 101.
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▪ Requires the State Fire Marshal to adopt rules necessary to implement the act’s
requirements.
▪ Names the act the “Ohio Childhood Safety Act.”
DETAILED ANALYSIS
Overview
The act requires all protective door assemblies in school buildings to comply with the
National Life Safety Code (NFPA 101) developed by the National Fire Protection Association or
other similar standards. If the protective door assembly was installed in 2015 or after, it must
comply with the 2015 NFPA 101, or other standards required by the Board of Building
Standards under the Ohio Building Code (OBC). If the protective door assembly was installed
prior to 2015, it must comply with the NFPA 101 that was in effect on the date the protective
door assembly was installed or, if it was installed before the NFPA 101 was published and in
effect, the OBC in effect at the time of installation.1
The NFPA 101 is not referenced in, or incorporated into the OBC or Ohio Fire Code (OFC)
for new school buildings, except for a life safety evaluation that is required for certain assembly
occupancies. Therefore, while there may be some overlap between NFPA 101 and the existing
OBC and OFC, the act mandates a new standard for compliance for protective door assemblies
in school buildings.
The act defines “protective door assemblies” as:
▪ Doors with panic hardware or fire exit hardware;
▪ Door assemblies in exit enclosures;
▪ Electricity controlled egress doors; and
▪ Door assemblies with special locking arrangements, such as delayed egress, sensor
release egress doors, and elevator lobby doors.2
The act requires annual inspections of protective door assemblies in school buildings
and requires the authority having jurisdiction to issue a citation to school governing authorities
that do not, within a specified time after a failed inspection, either achieve compliance with the
applicable standards or demonstrate active steps towards achieving compliance. 3
1 R.C. 3737.07(B)(2).
2 R.C. 3737.07(A)(3).
3 R.C. 3737.07(B), (H), and (I).
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School buildings
The act applies to structures used by a school governing authority for the instruction of
students (“school buildings”). Under the act, a “school governing authority” is the board of
education of a school district, the governing authority of a chartered nonpublic school, the
governing authority of a community school, the governing body of a STEM school, or the board
of trustees of a college-preparatory boarding school.4
Inspections
The act requires all school governing authorities to have each protective door assembly
in their school buildings inspected every 12 months by a qualified inspector. The act defines
“qualified inspector” as a person with the requisite degree, certification, professional standing,
skill, knowledge, training, and experience to evaluate compliance of a particular protective door
assembly with NFPA 101 or other applicable standards. Following the inspection, the inspector
must provide a report to the school governing authority that indicates whether the protective
door assembly is in compliance with those standards and, if not, whether the noncompliance
poses a serious risk of a fire or life safety hazard.
If the protective door assembly is compliant, the school governing authority need not
take further action until the next inspection. If the protective door assembly is not compliant,
the school governing authority must take all necessary steps to achieve compliance. After
completing those steps, the act requires the school governing authority to cause another
inspection of the protective door assembly. If the protective door assembly fails the subsequent
inspection, the process repeats until the assembly fully complies with the applicable standards.5
Depending on the size of the school building, the areas of expertise of an inspector,
scheduling, and numerous other factors, a school governing authority may choose to hire one
qualified inspector to inspect all protective door assemblies in the school building or it may
divide the work among multiple qualified inspectors. The act specifies that a qualified inspector
who inspects more than one protective door assembly in the same school building may
combine the results of the inspections into one report. However, the report must clearly
indicate which protective door assemblies are in compliance with the applicable standards and
which, if any, are not.6
Records
The act requires school governing authorities to maintain records that verify the
protective door assembly inspections. Annually, beginning in April 2026, the authority having
4 R.C. 3737.07(A)(5) and (6).
5 R.C. 3737.07(A)(4), (B), (C), (D), (F), and (G).
6 R.C. 3737.07(J).
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jurisdiction must inspect those records to assess the school governing authority’s compliance
with the act and, if merited, issue citations.7
Citations
The act requires the authority having jurisdiction to issue a citation if it determines,
based on the records of a school governing authority, that a protective door assembly in a
school building is not fully compliant with the applicable standards within 18 months after the
first failed inspection, or within 180 days after a subsequent failed inspection, if the assembly
poses a serious risk of fire or a life safety hazard, and the school governing authority is not
actively taking steps to achieve compliance. Each noncompliant protective door assembly that
meets those criteria is a separate violation and subject to an additional citation. However, the
act explicitly requires that no citation be issued to a school governing authority that is actively
taking steps towards compliance, regardless of whether the protective door assemblies in the
school building have actually achieved compliance. Furthermore, the act prohibits any civil
penalty or fine from being assessed with the citation.8
A school governing authority that receives a citation for a noncompliant protective door
assembly must post the citation on its public website. It may remove the posting once the
protective door assembly is made compliant and this is confirmed by an inspection.9 The act
prohibits the authority having jurisdiction from issuing a notice in lieu of citation. A notice in
lieu of citation is an option available to the Fire Marshal under continuing law for de minimis
violations that have no direct or immediate relationship to safety or health.10
Appeals
Under continuing law, a person my appeal a citation or penalty issued by the Fire
Marshal, an assistant Fire Marshal, or a certified fire safety inspector to the State Board of
Building Appeals within 30 days after receiving notice of the citation. If the person does not
receive a favorable outcome under the appeal with the Board of Building Appeals, the person
may appeal the order of the Board to the Court of Common Pleas within 30 days after the
Board’s decision. Under the act, a school governing authority may appeal a citation issued by
the authority having jurisdiction in this same manner.11
7 R.C. 3737.07(E) and (H)(1).
8 R.C. 3737.07(H)(1) and (I), 3737.42, and 3737.51.
9 R.C. 3737.07(H)(2).
10 R.C. 3737.42(C).
11 R.C. 3737.07(M); R.C. 3737.43, not in the act.
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Authority having jurisdiction
The act defines “authority having jurisdiction” as “the organization, office, agency, or
individual responsible for enforcing [the act’s] requirements.” This seems to include the Fire
Marshal, an assistant Fire Marshal, or a fire safety inspector.12
Temporary door-locking device
The act specifies that a temporary door-locking device in compliance with rules adopted
by the Fire Marshal is compliant for the purposes of the inspections, regardless of any contrary
standards of NFPA 101 or other applicable standards.13
Rules
The act requires the State Fire Marshal to adopt rules that are necessary to implement
the act’s requirements. The Fire Marshal must work in conjunction with the board of building
standards to implement such requirements 14
Name
The act names itself the “Ohio Childhood Safety Act.”15
HISTORY
Action Date
Introduced 04-25-23
Reported, S. Education 06-12-24
Passed Senate (32-1) 06-12-24
Reported, H. Commerce and Labor 06-25-24
Passed House (96-2) 06-26-24
24-ANSB0112EN-135/sb
12 R.C. 3737.07(A)(1); R.C. 3737.01, not in the act.
13 R.C. 3737.07(L).
14 R.C. 3737.07(K).
15 Section 3 of the act.
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Statutes affected:
As Reported By Senate Committee: 3737.42, 3737.51
As Passed By Senate: 3737.42, 3737.51
As Reported By House Committee: 3737.42, 3737.51
As Passed By House: 3737.42, 3737.51
As Enrolled: 3737.42, 3737.51