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Apr 24 2017

QQ: Can fire exit hardware be installed on a non-fire-rated door?

There has been quite a bit of discussion about this lately – fire doors installed where they are not required, listed components used on openings that are not fire door assemblies, products with different labels in the same assembly (for example, a 20-minute door in a 90-minute frame).  I think the reason behind this increased focus is the enforcement of annual fire door inspections in health care facilities.  I wrote about a possible conflict between the NFPA requirements and the Joint Commission’s procedures back in November, and I still haven’t received notice of a resolution.

So we’ll keep chipping away at this issue until we are all clear on the intent of the model codes and standards.  Today’s “chip” is the question of using fire exit hardware on a door that is not fire rated.  Is this acceptable?  Would the hardware or the entire assembly then have to be inspected annually?

Fire exit hardware is a type of panic hardware which is tested in accordance with UL 10C for use on fire doors, in addition to being listed to UL 305 for panic hardware.  Typically, fire exit hardware would not be installed on a non-fire-rated door because fire exit hardware usually costs a bit more and does not include the dogging feature.

But what if a facility locksmith has fire exit hardware in stock and considers installing it on a non-fire-rated door?  Or maybe a fire door is no longer needed in a specific location and the door label has been removed…can the fire exit hardware remain in place?  As with so many questions like this, the codes and standards don’t specifically state the answer.  Sometimes we just have to attempt to understand the intent of the codes and hope that the AHJ agrees.

I found something in the 2015 edition of NFPA 101 that may help us understand NFPA’s position on this issue.  Even though a previous edition of NFPA 101 (the 2012 edition) is being enforced for most health care facilities, the language added in the 2015 edition is more of a clarification than an actual change.

This paragraph is included in the 2012 and 2015 editions of NFPA 101:* Only approved fire exit hardware shall be used on fire protection-rated door assemblies. New panic hardware and new fire exit hardware shall comply with ANSI/UL 305, Standard for Safety Panic Hardware, and ANSI/BHMA A156.3, Exit Devices.

This line was added in Annex A of the 2015 edition:

A . The presence of fire exit hardware on a door does not imply the door is required to be a fire protection–rated door.

The Annex A language indicates that it is possible to have fire exit hardware on a non-rated door.  In my opinion, the language in NFPA 101 would prevent panic hardware without the UL 10C listing to be installed on a fire door assembly, but does NOT prevent fire exit hardware with the UL 10C listing to be installed on a non-fire-rated door.

I checked with NFPA staff to make sure I wasn’t missing something, and the staff member confirmed that neither NFPA 101 nor NFPA 80 prohibit the use of fire exit hardware on a non-fire-rated door, and also that the use of fire exit hardware would not prompt a need for annual inspection of the non-fire-rated assembly.  The inspection requirements apply to opening protectives in locations where fire door assemblies are required.  The installation of an individual listed component in a location that is not required to have an opening protective does not result in a need for annual inspections.

As always, I welcome your thoughts on this…whether you agree or disagree!  This is my opinion, along with the NFPA staff opinion – an AHJ may or may not agree.

Apr 21 2017

FF: Do Not “Prop” This Door Open

Category: Fixed-it Friday,Hold-OpensLori @ 12:09 am Comments (9)

Rick Jermain of Allegion sent me this Fixed-it Friday photo.  Very cute.  Nice panic hardware too.  😀


Apr 20 2017

2-Operation Follow-Up

Category: Code Development,Egress,School SecurityLori @ 1:34 pm Comments (1)

A couple of weeks ago, I wrote a post about a proposed change to NFPA 101 – The Life Safety Code, which would allow existing classroom doors to have hardware that required 2 operations to release the latch, instead of the 1 operation that is currently required.  I’m working on a couple of articles about this topic, and during my research I found some things that really surprised me.

To give a little background…there are 6 NFPA 101 change proposals in the works that affect classroom security – 3 for new occupancies and 3 for existing buildings.  The proposals for the new occupancy chapters are consistent with the changes that will be included in the 2018 editions of the International Building Code and the International Fire Code, but the proposed changes for the existing occupancy chapters would allow 2 operations to release the latch instead of 1.  While this may not seem like a big deal, it’s a major change from past editions of NFPA 101, and is inconsistent with other codes and standards.

~~~ Surprise #1 ~~~

There are 3 occupancy chapters where this language regarding 2 operations would be inserted: Chapter 15 – Existing Educational Occupancies, Chapter 17 – Existing Day Care Occupancies, and Chapter 39 – Existing Business Occupancies (see pages 31, 36, and 79 of this document).  Many college and university classroom buildings are considered business occupancies, so the proposal for Chapter 39 would cover these facilities.  BUT – the proposal for this chapter does not reference classrooms or colleges/universities, so the language could actually be applied to any room in any business occupancy – where approved by the Authority Having Jurisdiction.  We have already seen AHJs being pressured to allow security devices that are not compliant with the model codes; this is a difficult position for any code official.

The current and past editions of NFPA 101 allow 2 releasing operations for residential dwelling units and for existing hardware on rooms with an occupant load of 3 people or less.  In these locations, the occupants are likely to be familiar with locking/unlocking the door and the risk is low.  What is the justification to go from these limited exceptions to allowing 2 operations for all classroom doors and any approved doors in a business occupancy?

~~~ Surprise #2 ~~~

The various chapters of NFPA 101 are the responsibility of different technical committees.  The committees that are considering approval of the classroom-related changes are made up of different members than the Technical Committee on Means of Egress.  When Chapter 7 – Means of Egress states a requirement, and one or more occupancy chapters include an exception to that requirement, language must be added to Chapter 7 referencing these exceptions.  When a proposal was made to add a reference in Chapter 7 to the exceptions for 2 operations, the Technical Committee on Means of Egress almost unanimously opposed this change (see page 6 of 13 in this report).

The technical committee made this statement:  “It is the position of the TC on Means of Egress that increasing the number of latch/lock releasing operations is dangerous and could create a hazard to occupants. Technology exists that will meet the current code requirement for not more than one latch/lock releasing operation. The need for multiple operations is contrary to decades of experience resulting in fatalities in schools and other buildings. Single-action egress is an important aspect of life safety for all emergencies.”


This proposal will be discussed at NFPA’s technical meeting in June, and will be voted on by the eligible members.  I hope the voters will carefully consider this change and the inconsistencies that will be created if it is approved, as well as the historical basis for the requirement for a single releasing operation.

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