As much as I like black/white-yes/no answers, sometimes it’s not that easy. This is one of those questions, and it keeps coming back. Here’s the scenario…I have an exterior aluminum door serving a large Assembly occupancy, with no fire rating required. I don’t need the ability to dog* the device, and I have fire exit hardware left over from a previous project. Can I install the fire exit hardware on the aluminum storefront door?
Fire exit hardware is a type of panic hardware, which is listed per UL 10C for use on fire door assemblies in addition to the UL 305 listing required for panic hardware. The aluminum door would require the UL 305 listing, and both the panic hardware and fire exit hardware have it. The fire exit hardware has the additional UL 10C listing, but I don’t see anything in the 2015 edition of the IBC or NFPA 101 that prohibits the additional listing where it is not needed, or any direct answer in the Commentary or Handbook.
NFPA 101 gives us a clue in this section, and the explanatory text in Annex A:
7.2.1.7.2* Only approved fire exit hardware shall be used on fire protection-rated door assemblies. New panic hardware and new fire exit hardware shall comply with ANSI/UL 305, Standard for Safety Panic Hardware, and ANSI/BHMA A156.3, Exit Devices.
A.7.2.1.7.2 The presence of fire exit hardware on a door does not imply the door is required to be a fire protection–rated door.
Based on the Annex A text, I think fire exit hardware on a non-fire-rated door would be ok. This language has been changed from the 2012 edition of NFPA 101, which reads:
7.2.1.7.2 Only approved panic hardware shall be used on door assemblies that are not fire-rated door assemblies. Only approved fire exit hardware shall be used on fire-rated door assemblies. New panic hardware and new fire exit hardware shall comply with ANSI/UL 305, Standard for Safety Panic Hardware, and ANSI/BHMA A156.3, Exit Devices.
Based on the 2012 edition of 101, I would have said that 101 was limiting the use of panic hardware to non-rated doors and fire exit hardware to rated doors, but I’m guessing that was not the intent, hence the change in the 2015 edition.
NFPA 80 – Standard for Fire Doors and Other Opening Protectives includes this statement: 6.4.4.2 Fire exit hardware shall be installed only on fire doors bearing a label stating “Fire Door to Be Equipped with Fire Exit Hardware,” but this standard applies only to fire doors – it would not apply to the storefront door in our example. I think the intent of this statement is to ensure that fire doors with fire exit hardware are properly constructed, reinforced, and labeled for the application. I don’t think the intent is to prohibit fire exit hardware on non-fire-rated doors.
My final answer (for now) is that I don’t see anything in the 2015 editions that officially prohibits the use of fire exit hardware on non-fire-rated doors, but if an AHJ is enforcing the 2012 edition of NFPA 101, he or she may limit the use of fire exit hardware to fire door assemblies.
What do you think? Do you have any other resources to add? What’s the AHJ perspective on this issue?
*The dogging mechanism is used to hold the latch retracted with a key or allen wrench, and this function is not available on fire exit hardware because fire doors must have an active latchbolt. Electric latch retraction could be used to dog fire exit hardware, if the latch projects automatically during a fire.
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I don’t see an issue with using fire exit hardware on a non-fire-rated door. I don’t think it’s any different than putting a labelled door and/or frame in a wall that’s not rated. I know it’s a poor decision financially, but sometimes it works out when changes are made on projects and the fire door that had a handing change months ago becomes the door to the added office or closet the owner requested 3 weeks before C of O.
I would think that the problem with putting a rated opening where it is not required, is that now it would be subject to Fire Door Assembly Inspections, as down the road people would not know that the opening was not a rated opening. Now, there are going to be questions regarding hardware and more. So, a quick simple financial decision, may cost more in the long run. Just my thought, hope others respond to it.
Rachel…..that’s a good point if you were to leave the label on the door. We would remove the fire label from the door (and destroy it) if we used a fire door in a non-rated opening.
I guess the first question is does it fit on the aluminum door?
If it does fit than its a bit of over-kill but otherwise where is the beef since Fire Exit Hardware complies with the requirement for Exit and Fire devices.
I would hope the AHJ has better things to do than complain about something like this.
Thank you for the analysis though.
David R. DeFilippo AIA
We see this installation of lots of projects. It appears that it is easier on the door hardware supplier to order all exit devices as fire exit devices.
Like other situations as long as they meet the minimum they are great
If they want to go above the minimum, sometimes that is fantastic.
Like if they want to put a three hour rated door in a corridor that only requires twenty minute.
Are you going to tell them no? You might question it, and they may say I want a three hour door.
I would agree that it would be ok to use a fire listed device on a non rated door-we use listed locks and closers on non rated opens all the time. Also some customers do not want the dogging feature so the door latches every time its closed. Again easier to just carry fire rated vs ordering LD devices to cover more applicable openings.
I agree with Eric. No issues whatsoever placing a fire rated exit device on a non fire rated opening. The only issue would be if you wanted to dog the device to leave it unlatched. Can’t do that on a fire rated device.
I guess the same questions come up and seem mundane, a lot of aluminum storefront seem tobe getting fire rated panic exit hardware. Can the assembly be rated at least 20 min smoke rating? or 30 min fire ? being that it is a ferrous material? It should be able to withstand some type of added rating by containing the area.Someone please chime and let us know. I’ve come across where AHJ’s want the opening to just latch shut. Anybody else here please provide feedback on this. Thank you all!
I have had this pop up a few times in the distant past where the intent was not to allow dogging on a non-rated exit door. The spec writer simply put a fire exit device on a non-rated opening to achieve that need. It was never considered a big deal and it was never questioned by the AHJ. Now, the “LD” (less dogging) option is commonly offered and not a specialty item for regular exit devices, so don’t waste your money by using a fire exit device when it’s not really needed, even if the device was a “leftover” from a previous project. Save it for when you really need it.
The UL listing of exit devices has always been very clear about panic vs. fire rated devices. Panic devices are UL305 listed. Fire rated devices are UL305 AND UL10C listed. This clearly shows that the fire rated devices are tested and approved for use on any door that requires an exit device….UL305 listed device on a panic rated door. Yes…I can not dog the device….but what is more practical?….using the fire rated device from my stock for a door needing an exit device…..or going out and purchasing a new device that is panic rated…….”a bird in the hand” philosophy would win out in most cases.
I think it was very unclear (or clear in the wrong way) in the 2012 edition of NFPA 101, but the 2015 edition is better.
Great explanations and useful information. Clearly, the intention is to provide the proper hardware for the given application. Performance standards typically outline a “minimum” acceptable method for compliance – one can often exceed the requirement without any issue. In this particular case, using fire rated hardware on a non-rated door assembly would certainly not diminish the integrity of the opening. The only possible issue is the challenge it may pose during a fire door inspection. Sooner or later though I would think the fact would be discovered and it ultimately would not be an issue.
In regards to VD model 99s the actual device is different, beyond the lack of a dogging feature. They have melting points inside the center case that prevent operation after they melt. Life safety should never be treated as “what is easy(or cheaper)”. If someone was trying to egress a burning building and the pins had melted, by design the device would not operate and the door would not open.
A concern I would have is that this might lead the contractor and possibly the inspector to believe this is a required fire rated door and therefore allowed to have an opening force of up to 15lbs in California. It would actually require 5lbs. The hardware itself must also have 5lbs or less of force to activate (ADA 309).
meeting the ada requirements and having both labels/ratings on the exit device,
i don’t see any issues.. more expensive with fire rating, but if it meeds all
the foregoing and is left over.. don’t see why not…