Last week I was on a conference call for one of my projects in Washington DC, because of a problem with the specified concealed closer and the fire-rated wood door and wood frame. The door manufacturer suggested a “construction label,” and most of the call participants needed an explanation of what that was. I thought posting a description here might help others who are wandering the web seeking information about construction labels. (Don’t laugh…you wouldn’t believe how many people come to this site wondering what a Cush arm is.)
A construction label is applied when a door or frame is used in a location that requires a fire rating, but does not qualify as a rated product. For example, the door or frame may have an opening size which has not been tested, a jamb depth that is larger (or smaller) than the manufacturer’s listings allow, or the specified hardware is not included in the manufacturer’s listings. This is NOT the same as a UL or WH/Intertek label which certifies that the product has been tested to withstand fire for the stated period of time.
Typical text for a construction label is shown at right. The construction label does not imply that the door or frame is capable of furnishing standard fire protection, but that it is manufactured with the same materials and methods used in the manufacturers’ listings. The label is a means to permanently mark the product so that all parties know at a glance that the door or frame did not meet the listing requirements.
In order to use a construction label, permission must be granted by the AHJ!!!
Thank you to Kurt Roeper and Jim Donlan of Steelcraft for their help with this post.
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I can not believe what I am reading. Doesn’t this completely undermine the entire labeling system? Why would the AHJ even permit the use of such a product? Aren’t they just sticking their neck out to be sued if something ever does go wrong with the application? It would seem even the manufacturer would have some liability knowingly producing such a product. Such a label could be very dangerous if placed in the hands of some individuals. As a manufacturer I understand the need for this, but without any control or supervision from someone like UL or Intertek it just seems wrong.
How are these labels going to be handled once the “yearly” inspection for fire doors begins to be implimented in more areas? How is the inspector to know what is actually out of spec for the door? Will these inspectors still pass the application or will the company be forced to purchase new doors or frames?
Hi Eric –
I went to Kurt Roeper of Ingersoll Rand Security Technologies to get the expert opinion on this. Here’s what he said:
“A construction label is a means of disclosing to the AHJ and others that the product, while not within the parameters of the manufacturer’s listing, utilizes construction features similar to listed products. The acceptance of a construction label is up to the discretion of the AHJ, and they are typically submitted, reviewed and approved as part of the plan review and permitting process.
Some codes recognize the concept of ‘Alternate Means of Protection,’ where specific code requirements cannot be met, or where equivalent protection can be achieved through different means. The use of a product with a construction label is consistent with this practice. When these elements are subjected to relevant inspections in subsequent years, they are held to the conditions of acceptance granted when the permit was issued. In the case of construction labeled doors installed in fire protection applications, it is expected that they would be held to the same criteria as other fire doors.”
Eric asks whether the construction label undermines the entire labeling system. In fact, it is a part of the labeling system. What COULD be said, however, is that it could be seen to undermine (show the shortcomings of, actually) the fire door TESTING system. As we in the industry know, it is outrageously expensive to test a fire door assembly, so door and frame manufacturers carefully choose the parameters within which they test their products. One of the main criteria considered is the marketplace. If a door of oversized dimensions is required for one reason or another, how many times will a given manufacturer be called upon to furnish such a fire rated door? Hundreds or even thousands of openings would be required in order to justify the expense of testing something like a 5/0 x 12/0 single door, never mind the 10/0 x 12/0 pair. And what if the door failed in testing? What if it failed because of a hardware item manufactured by another manufacturer, necessitating another test? Construction label: Good. Common Sense: Good. Thanks for your good work.
Well said, leftcoastpdx! Thanks!
Is there a difference between an ‘Oversize fire door label’ and a ‘Construction label’? IBC 7188.8.131.52 seems to put these back in the purview of approved testing agency. Perhaps Construction labels are no longer valid. Thoughts?
They’re still valid on the cases stated above. The difference between a label construction door and a labeled Oversize fire Door, it’s that the later one has been effectevely tested, with important restrictions on Hardware, Gauge, and Door and frame construction. For example, you can have a door of 4′ x 8′ with an exit device and an overhead door closer on X door series from X manufacturer, on 18 gauge for the door leaf and 16 gauge for the frame. But say you need a 5′ x 10′ instead. The manufacturer could supply such door, fire rated, but because of it’s size it might has been tested to work only with a mortise lock and a surface closer, and built on 14 gauge for the door leaf and 12 gauge for the frame (this it’s just an example the kind of restrictions that may apply an oversized door). You can have such big doors, but with restrictions.
Thanks to you Lori 🙂