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:
220.127.116.11.2* 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.18.104.22.168.2 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:
22.214.171.124.2 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: 126.96.36.199 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.