When I started my career in the door and hardware industry, I used to think that the codes were black and white…that if I could just understand them, I’d have all the answers.  I learned long ago that this is not true.  The codes are constantly changing and evolving, in response to tragedy, product innovation, and hard work by those involved in code development.  When a new edition of a code or standard is published, it can take some time for a new requirement to be fully understood and implemented, and if the requirement is not completely clear it can take even longer for a precedent to be set with regard to the interpretation of the requirement.

The IBC has referred to UL 1784 – Air Leakage Tests of Door Assemblies since the 2000 edition (the first edition of the IBC).  But there are still questions about how and where to apply it.  The 2012 edition of the IBC includes this paragraph:

716.5.3.1 Smoke and draft control. Fire door assemblies shall also meet the requirements for a smoke and draft control door assembly tested in accordance with UL 1784. The air leakage rate of the door assembly shall not exceed 3.0 cubic feet per minute per square foot (0.01524 m3/s • m2) of door opening at 0.10 inch (24.9 Pa) of water for both the ambient temperature and elevated temperature tests. Louvers shall be prohibited. Installation of smoke doors shall be in accordance with NFPA 105.

If you read this paragraph in a vacuum, it seems like all fire doors have to limit the air infiltration to this level (in most cases this would require gasketing), but this paragraph falls under section 716.5.3 – Door assemblies in corridors and smoke barriers.  There are two sections following 716.5.3 that apply to other types of fire doors – 716.5.4 – Door assemblies in other fire partitions and 716.5.5 – Doors in interior exit stairways and ramps and exit passageways.  Neither of these sections currently include a reference to UL 1784, and I confirmed with the ICC several years ago that these other types of doors would not be required to meet the air leakage limits and would not require gasketing.

The ICC has issued an interpretation on this topic:

Question: Door openings for elevators, exit stairways, and incidental use areas are located in walls that also form a corridor.  The corridor does not require a fire-resistance rating in accordance with Section 1018. Are these doors required to meet the requirements for a smoke and draft control assembly in accordance with Section 716.5.3.1?
Answer: No.  Section 716.5.3 and its subsections are applicable to fire door assemblies located in corridor walls that have a fire resistance rating in accordance with Table 716.5. For Section 716.5.3 to be applicable, the required rating of the corridor walls would need to be either 0.5 hour or 1 hour (Table 716.5). Since there is no rating required for the corridor, Section 716.5.3 is not applicable.  Even though the fire barrier wall for the elevator, exit stairway, and incidental use area serve as part of the corridor, the corridor is not considered to be fire-resistance rated.  The segment of the corridor wall is fire-resistance-rated based on the elevator enclosure, exit stairway enclosure, and incidental use area separation requirement, not because of the corridor requirement.  Therefore, the fire door assembly in the fire-resistance-rated part of the corridor wall is not required to meet the requirements for a smoke and draft control assembly.

According to the ICC interpretation, stair doors are not required to meet the requirements for a smoke and draft control assembly, so they would not require gasketing the way the code is currently written.  What do you think?  Should the code be changed to require stair doors to comply?  If a stair is pressurized, gasketing may be helpful in maintaining the pressure.  If the stair is not pressurized, gasketing to limit smoke infiltration could help to ensure a safer egress path.  Have you ever had an AHJ require gasketing on stair doors?

Please share your thoughts or questions by leaving a comment below.

Thank you to Paul Stockert of EYP Architecture and Engineering for sending me the ICC interpretation!

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