For Wo
rdless Wednesday, most participating bloggers post a photo with no words; the photo needs no description to get their point across. I post photos that leave me Wordless (speechless) – usually because they are blatant code violations. I reserve the right to include words when I want to use the photo as a “teachable moment.” This is one of those posts.
Today’s photo is from Connor Jordan, originally posted on the Door Closer Enthusiasts page on Facebook. I don’t know for sure that this is a fire door, but let’s assume that it is for the sake of this lesson. NFPA 80 (2013) states: “5.1.5 Removal of Door or Window. Where a fire door or fire window opening no longer functions as an opening, or the door or window is removed and not replaced, the opening shall be filled to maintain the required rating of the wall assembly.” (This is also discussed in Annex K of NFPA 80.)
So a fire door or fire window that is no longer used as an opening must be removed, and the opening filled with construction that will maintain the rating of the wall. [Edit: As stated in a comment below, there may be a method of filling the opening that does not involve removing the door, but the AHJ should be consulted for approval.] The rating of an opening protective (fire door assembly, fire window, etc.) is typically less than the required rating of the wall, because the fuel load against the wall – furniture, stored items – is generally greater than the fuel load against an operable door. When a fire door is no longer operable, there’s the possibility that items could be placed against it which would increase the fuel load, as in this photo (imagine the cabinet is full of newspaper and oil-based paint to go with the roller pans). For this reason, inactive openings should be removed and replaced with the appropriate wall construction – just make sure the door is not required for egress.
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You have said that when the opening is no longer used, the opening protective (door or window) ‘must’ be removed, while the quoted NFPA section says if “is removed & not replaced…..” Therefore an AHJ may approve the door in picture if he is not aware of the fuel load as explained herein.
Your last point about making sure the door is not required for egress is a difficult one for older buildings. Frequently the owner has not kept life safety plans.
You have, as point out above, incorrectly quoted and interpreted the code section, which does not require removal of the door… and requires only that it ultimately have a fire rating equal to or better than what is required of the wall in which is it contained.
Second, you have made assumptions that are not supportable if all you have is the photograph.
First, it is possible the door/frame assembly actually has a rating that exceeds what is required… but without researching this you cannot know what the required wall rating is, or what the assembly rating is.
Second, you can only see one side of the door, so cannot know if the opposing side of the door has been treated (or not) such that the rating has been increased. Depending on what materials may have been added to the opposing side, and the detailing where prior existing door/frame/wall components adjoin, it is possible that the composite assembly rating has been effectively increased.
This is why an observation on site cannot be taken at face value unless it is supported by appropriate further investigation/inquiry. While the point you are trying to make may be valid, and the photo is helpful in making the point, you cannot hold up the photo as prima facie evidence of a code violation in this particular instance.
Thank you for the feedback, Howard. My intent was not to hold up the photo as prima facie evidence of a code violation – that’s why I wrote in my blog post, “I don’t know for sure that this is a fire door, but let’s assume that it is for the sake of this lesson.”
Without the ability to open the door, it would be tough to find out for sure if it had a label, or what the stated rating of the door is. I guess it would be possible for someone to remove a fire door that is no longer used, and replace it with another door that has the same rating as the wall, although I don’t think this is a common occurrence. More often the bookcase, storage cabinet, etc. is pushed against the door and the door is forgotten. It would be very difficult to verify the door rating and operation during the annual fire door inspection if the door can’t be opened. It’s also possible that the other side of this opening (assuming that it is a fire door) could have been “treated” to increase the rating…again, this is not something I have seen done. The 2010 edition of NFPA 80 says:
5.1.2 Removal of Door or Window. Where a door or window opening is no longer in use, the opening shall be filled with construction equivalent to that of the wall.
My interpretation was based on the word “removal” and the requirement for the opening to be filled with construction equivalent to the wall. The wording has changed slightly (although the 2010 edition or earlier is still in effect for most jurisdictions). There may be other ways to accomplish this in a manner that would be acceptable to the AHJ.
The photo is a good illustration of why an unused fire door should be addressed. As you and I both stated, we don’t know if it is a fire door, but I think that the concept is much easier to absorb with the photo than it would be without.
– Lori