This post was published in the April 2014 issue of Doors & Hardware
There has been a lot of publicity about the annual inspections required for fire door assemblies, but we must also be familiar with the inspection and testing requirements for egress doors. These requirements were added in the 2009 edition of NFPA 101 – The Life Safety Code, and are also found in the 2012 edition.
In the 2012 edition of NFPA 101, these inspections are covered in section 184.108.40.206 – Inspection of Door Openings. Inspections of specified egress doors are required not less than annually by NFPA 101 if so stated in chapters 11-43 – the occupancy chapters. The occupancy chapters in this edition which refer to section 220.127.116.11 are:
- Assembly (18.104.22.168, 22.214.171.124)
- Educational (126.96.36.199, 188.8.131.52)
- Day-Care (184.108.40.206, 220.127.116.11)
- Residential Board and Care (32.7.7, 33.7.7)
UPDATE: The following sections have been added in later editions of NFPA 101 (paragraph numbers based on the 2018 edition):
- Hotels and Dormitories (28.7.7, 29.7.7)
- Apartment Buildings (30.7.3, 31.7.3)
- Mercantile (36.7.7, 37.7.7)
- Business (38.7.7, 39.7.7)
- Industrial (40.7.3)
- Storage (42.9.3)
Section 18.104.22.168 also addresses the annual inspection of fire doors (performed in accordance with NFPA 80) and smoke doors (performed in accordance with NFPA 105), for fire doors and smoke doors in all occupancy types.
The egress door inspection and testing requirements do not apply to every door in a facility, but the following doors in the referenced occupancy types must be addressed:
- Door leaves equipped with panic hardware or fire exit hardware in accordance with 22.214.171.124 – panic hardware is required by NFPA 101 for doors in Assembly, Educational, and Day Care occupancies serving an occupant load of 100 or more, but this inspection requirement also applies to other doors that are equipped with panic hardware or fire exit hardware where not specifically required, according to the NFPA 101 Handbook.
- Door assemblies in exit enclosures – typically stairwells and exit passageways.
- Electrically controlled egress doors – electrically-locked doors that are released by a door-mounted release device such as panic hardware with an integral request-to-exit switch.
- Door assemblies with special locking arrangements subject to 126.96.36.199 – includes Delayed Egress Locking Systems (188.8.131.52.1), Access-Controlled Egress Door Assemblies (184.108.40.206.2), and Elevator Lobby Exit Access Door Assemblies Locking (220.127.116.11.3).
- For Residential Board and Care, the requirements apply to doors which are required to swing in the direction of egress – typically doors serving areas with an occupant load of 50 or more, and doors used in an exit enclosure.
Inspecting doors in these locations helps to ensure that the doors used most frequently and are more prone to wear and tear are operating properly. Similar to the NFPA 80 standards for fire door inspections, door assemblies must be visually inspected from both sides of the opening to assess the condition. Functional testing must be performed by individuals who can demonstrate knowledge and understanding of the type of doors subject to testing. A written record must be signed and kept for review by the Authority Having Jurisdiction, this documentation providing an enforcement tool to ensure that the inspections are done properly. Any deficiencies noted during the inspection must be repaired or replaced “without delay.” There is a set of guidelines in NFPA 80 for a written performance-based program which allows the inspection period to exceed 12 months, and this can also be applied to egress doors.
From the 2012 edition of NFPA 101:
18.104.22.168.7 As a minimum, the following items shall be verified:
1. Floor space on both sides of the openings is clear of obstructions, and door leaves open fully and close freely.
2. Forces required to set door leaves in motion and move to the fully open position do not exceed the requirements in 22.214.171.124.5.
3. Latching and locking devices comply with 126.96.36.199.
4. Releasing hardware devices are installed in accordance with 188.8.131.52.10.1.
5. Door leaves of paired openings are installed in accordance with 184.108.40.206.11.
6. Door closers are adjusted properly to control the closing speed of door leaves in accordance with accessibility requirements.
7. Projection of door leaves into the path of egress does not exceed the encroachment permitted by 220.127.116.11.3.
8. Powered door openings operate in accordance with 18.104.22.168.
9. Signage required by 22.214.171.124.1(3), 126.96.36.199.5, 188.8.131.52, and 184.108.40.206 is intact and legible.
10. Door openings with special locking arrangements function in accordance with 220.127.116.11
11. Security devices that impede egress are not installed on openings, as required by 18.104.22.168.12.
The Authority Having Jurisdiction may require annual inspections for additional doors if he or she determines that there is a hazard to building occupants. Annual inspections of fire doors, egress doors, and smoke doors will help to ensure that they perform as designed, tested, and required by code. Even if the annual inspection requirements are not being enforced in your jurisdiction, each building owner or property manager is required to maintain their fire doors, egress doors, and smoke doors in proper operating condition.
Note: NFPA 101 requires all exit facilities, including stairways and doors, in Educational and Day Care occupancies to be inspected daily by principals, teachers, or staff to ensure that they are in proper condition. This is not the same type of inspection required to be performed and documented annually, but with knowledgeable staff, this practice could go a long way toward code-compliant egress doors. Annex A specifically mentions that attention should be given to keeping egress doors unlocked, and avoiding non-compliant hold-open devices on fire doors.
This post was originally created on February 6, 2014, and printed in the April 2014 issue of Doors & Hardware magazine.