A few years ago, an architect that I’ve worked with for over 20 years called me and indignantly asked, “Do you know the maximum height for a kick plate on a fire door?!” I answered that it was 16″ above the bottom of the door. The architect said, “Well! We tried to write our own hardware spec for a 15-door job. There were 11 hardware sets and there has been a problem with every set except one, and now there’s a problem with THAT set…the kick plate is too high!” As far as I know, they never tried to write their own hardware spec again.
This requirement is found in NFPA 80. If the top of the plate is 16 inches or less above the bottom of the door, the plate is not required to be labeled. Field installed plates larger than that must be labeled. The other option is factory-installed plates. I was recently asked if installing an armor plate in a distributor’s UL shop would qualify as “factory-installed”. According to that distributor’s UL procedure, they were allowed to install armor plates on fire-rated doors in their shop, so if you work for a distributor it may be worth checking your procedure to see if this would apply to you.
Here is the text from NFPA 80 2007:
6.4.5 Protection Plates.
220.127.116.11 Factory-installed protection plates shall be installed in accordance with the listing of the door.
18.104.22.168 Field-installed protection plates shall be labeled and installed in accordance with their listing.
22.214.171.124 Labeling shall not be required where the top of the protection plate is not more than 16 in. (406 mm) above the bottom of the door.
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What’s the purpose of this code?
Isn’t it the same armor plate except you pay more for the one with the label.
How often do you figure that people get away with not using a labeled armor plate on a rated door?
How would an inspector know if the plate was factory installed?
What exactly does this mean; “installed in accordance with the listing”?
I know – a lot of questions, but this has bugged me for a long time.
I am a healthcare saety officer and responsible for the inspection and compliance of these types of doors. I was told one day during a federal site inspection that a reason for the restriction on protective plate height is was to allow the transfer of heat through the door. Logic being that we train folks to “crawl or stay low” during a fire situation. If you were crawling and felt a door with a protective plate, the argument is that the plate could interfere with the occupants ability to feel the heat on the other side. Meaning the occupant could think the room on the other side of the door was cool, open the door, and be exposed to fire.
As this site has pointed out though there are very technical requirements for what is and what is not allowed in various environments.
Some info there.
Thanks for your insight, Anthony. I had not heard that as the reason behind the limitation on plate height. The labeled plates which are allowed to be up to 48″ tall are not constructed any different from the non-labeled plates so the heat transmission would be the same either way. I’m working on getting an official answer on the use of non-labeled 48″ plates on health care as allowed by NFPA 101, and I will report back on my blog when I have an answer.
I was told that if it is taller than 16 inches it could bend the door because of the difference in temp. but that would not explain why you could use a listed taller one of the same material. Also if you glue it on, does it become a sign and can only take up 5% of the door. I’m thinking you could glue a push plate on and call it a sign.
Hi Paul –
It’s possible that a larger plate could affect the performance of the door, but I don’t see much (or any) difference between the labeled plate and the non-labeled one. It’s definitely something that needs to be clarified in the standard.
What does “installed in accordance with the listing” mean? You can look up the product listing on UL’s website. The Ives listing GVUX.R22142 for kickplates states “Kick plates and armor plates are to be attached with screws and are not to exceed 48 in. in width or 48 in. in height.” This presents a possible penetration issue on fire rated lead lined doors with armor plates.
It’s interesting that we’ve all thought of different reasons for this rule! I think it’s too hard to predict how the mechanical stress of the protective plate will effect the door. The protective plate is a different material, and the force from the plate bending would be concentrated at the attaching screws, if you use screws. The plate could actually bend the door and make it fail the test. That’s hard to figure out on paper, and when the math gets too hard it’s best to build one and see what happens.
Thanks again for maintaining this site, it’s just a treasure of information.
Thanks Lloyd! It’s almost the 5-year anniversary of iDigHardware / iHateHardware!
I hope you’re well.
Are there any specific requirements mentioned in the codes related to the thickness of these plates on a fire rated door? Please let me know your comments ASAP.
Hi Maharoof –
No, NFPA 80 doesn’t limit the thickness, but if it’s a large plate that needs to be labeled, the manufacturer might offer a particular configuration. Here’s what NFPA 80-2013 says in Annex A:
“E.3 Protective plates are usually utilitarian in nature and are used to provide additional resistance to wear or impact. Protective plates are usually flat sheets of metal or plastic applied on one or both door faces and located within the lower 16 in.(406 mm) of the door. Plates above this height could affect the fire performance of the door but can be permitted to be used if tested and approved. Attachment of protective plates to the door faces is achieved by a variety of methods such as adhesives, screws, or other mechanical means that might penetrate the door face to achieve holding strength.”
What about the push plates? Should it be UL listed to use on a fire rated door?
Hi Maharoof –
The US codes don’t allow push plates on fire doors. I’ve seen some European fire doors with push plates but I don’t know if there is any sort of listing required.
Distributors that intend to mount armor plates should be very careful to refer to the label procedures called out in their manuals. The modification manuals define what is accepted and how it is to be done. Just because you are a labeled shop doesn’t allow you to do what ever you want. In my experence the procedures and modifications allowed vary by manufacturers.
I have just one problem here. Joint Commission allows the non-rated, factory- or field-applied protective plate on hazardous area doors, required to be one hour rated if no extinguishing system provided and corridor doors, but not on any other fire rated doors. What are we really trying to protect here. We are talking about a 1/4″ screw hole and yes while that may defeat the door faster in a fire, if a person is in that area near that door at the time of failure their probably not going to make it, just saying.
If you look at section 126.96.36.199, NFPA 101, 2000 Edition, the last sentence in the paragraph says, hazardous areas shall include, but shall not be restricted to. The exception also states, “Doors in rated enclosures shall be permitted to have non-rated, factory- or field-applied protective plates extending not more than 48” above the bottom of the door.
In the Life Safety Code we use every day, if used correctly, it will refer to another code if required. This can be seen in the 2000 edition, section 188.8.131.52.1 where it specifically states corridor doors not having to comply with NFPA 80 and in section 184.108.40.206.5 where it states Dutch doors must comply with NFPA 80.
I see no reason to pay the money to rate one “steel” plate for one fire door and not for the other. If NFPA 80 is used, all fire door protection plates greater than 16″ should be label as such.
Just the way I read it. Any thoughts?
It seems like some of the exemptions in the codes are due to the power of various groups who are looking at the associated expense. There are several door-related examples where the code is basically describing a fire door but not requiring an actual fire door, in locations where a fire door would be required if it was a different occupancy type. I don’t like this inconsistency…I would much prefer to have the same rules apply regardless of the location. If it’s a fire door, it’s a fire door. If it’s not, it’s not. From there, the rules are clear.
Lori, you have excellent material and knowledge of doors and hardware! I really appreciate your posts. I believe that part of the issue here lies in the fact that if they didn’t have this labeling requirement, you could have somebody put random armor plates on a door with edge to edge protection, rapidly expanding metals (aluminum), etc. This could cause many issues. We tend to think of the protective plates as being all the same thing, but you get some pretty creative things that people do…
Lori and Wes,
After speaking with the State Fire Marshal from our state he stated that the exception I stated above would be used for any door in a “rated enclosure” meaning a rated door. Thus the requirement for a rated label on a steel protective plate would not be required. Again I believe there is some disconnect between AHJs and the way this code is interpreted, depending on if you are using 80 or 101. In the 2012 edition of the LSC there are several instances where non-rated, factory, and or field applied protective plates are allowed unlimited in height. After speaking with several steel protective plate manufacturers they stated that any inspector that would cite a facility for having a steel plate without an approved fire rating label would be ridiculous, but does often times happen.
E.3 Protective plates are usually utilitarian in nature and are
used to provide additional resistance to wear or impact. NFPA 80 2013 Edition
It is the opinion of many that protective plates are just that, protection from wear and impact and not intended to provide additional fire protection. If anything I would think it provides more physical protection for the fire door, increasing the life span, if it were indeed a steel plate. I still have a hard time understanding why one fire doors protective plate needs a fire rated label and one doesn’t. Seems a bit over the top from a fire protection stand point and yet several hospitals have been cited for this by The Joint Commission forcing them to spend money to add a label.
Back in the Olden Days when I went to hardware school, we were taught that installing a large plate on a fire door could negatively affect the performance of the door during a fire. I get that, but when there is no difference between a labeled and non-labeled plate, and AHJs seem to be allowing labeled plates of any height, I don’t see the point of citing facilities for non-labeled plates and requiring them to replace the plates with labeled plates.
What if a door has a 12″ kick plate and a 8″ stretcher plate? Does the stretcher plate need a label because it is mounted above 16″, or does it not since there is a gap between the plates?
Hi Morgan –
If any plate is field-installed on a fire door above the 16-inch area, it needs to be labeled.
All Say label?? What label what does this label say? Thx
Hi Mike –
It’s a UL label that says the plate is listed to UL 10C.
What kind of plate can be used to replace the hardware on a one hour fire rated door assembly. Door is to remain, but will not be used.
Hi Oscar –
I don’t know of a plate that is listed for use in covering the holes in a fire door. When a fire door is no longer used, the opening in the wall is supposed to be filled with construction equivalent to the required rating of the wall. I wrote about this situation here: http://idighardware.com/2016/12/qq-remove-hardware-from-fire-door/.
HI, our hospital recently went through a JACO inspection and one finding was Deadbolts on surgery doors need to be removed. Is there a recommended
method for covering the holes and cavity left from a deadbolt lock body?
Hi Phil –
Are the doors fire doors?