Last Friday I posted this photo and asked you to answer a few questions about what had happened here:
Here are the questions, and I’ve added my answers:
a) This is a 4′-wide stairwell door. What’s wrong with this picture?
Many of you figured out right away that someone has taken fire exit hardware designed for a 3-foot-wide door and installed it on a 4-foot-wide door. The original mechanism tube has been replaced with one from a 4-foot device, and a filler plate fills the area where the wider touchpad should be. The code issue here is that the actuating portion of panic and fire exit hardware is supposed to be at least half the width of the door. On the Von Duprin 98/99 series (shown in the photo), the touchpad for the 3-foot device is 18 inches, and on the 4-foot device it’s 24 inches. So this device now looks like it is designed for this 4-foot door, but the touchpad is not half the width of the door.
b) Is it a code issue if the door is serving a hospital unit that consists of patient rooms and support spaces?
NFPA 101 – Life Safety Code requires panic hardware for doors serving Assembly, Educational, and Day Care occupancies with an occupant load of 100 people or more. The International Building Code (IBC) requires panic hardware for High Hazard occupancies (any occupant load), and for Assembly and Educational use groups with an occupant load of 50 people or more; prior to the 2006 edition the IBC occupant load threshold was 100 people or more.
If this door is serving patient rooms and support spaces, neither of these codes technically require panic hardware. So does the touchpad have to be at least half the width of the door? Read on…
c) Does the answer to “b” change depending on whether the International Building Code is being enforced or NFPA 101 – The Life Safety Code is being enforced?
NFPA 101 says that the panic hardware criteria (including the length of the actuating portion, the mounting height, and the operating force) must be met “where a door assembly is required to be equipped with panic or fire exit hardware…”
The IBC says, “Where panic or fire exit hardware is installed, it shall comply with the following…”
The AHJ could go either way on this, but in my opinion, if NFPA 101 was the prevailing code, the short touchpad would not technically be a problem because panic hardware is not required for the occupancy type. If the IBC was the prevailing code, then the touchpad would be a problem because the IBC requires installed panic hardware to meet the criteria. In either case, the installer has likely created a problem with the UL listing of the fire exit hardware, because these products can’t be mixed and matched or field-modified in this way.
Interesting, right?! 🙂