At least once a week someone asks me whether each and every component of a fire door assembly has to be listed or labeled. The question usually comes up because there is a hardware item that doesn’t seem to be available in a listed or labeled version. The most common components that prompt this question are safety sensors for automatic operators, door loops/door cords for transferring wires from the frame to the door, and hardware protectors made of plastic or metal that mount adjacent to the lever or panic hardware to protect it from cart traffic.
I have scoured NFPA 80 for a catch-all phrase requiring every component of a fire door assembly to be listed or labeled. While the specific sections on locks, fire exit hardware, etc., do reference listings or labels for each of these components, if there isn’t a section to address a certain type of hardware, the requirement for a listing or label may not be as clear.
After speaking with NFPA, UL, and Intertek, I believe that the intent is for every component used as part of a fire door assembly to be listed/labeled. This may be clarified in a future edition of NFPA 80, but currently this paragraph comes closest to establishing the intent:
4.2.6 Components.
4.2.6.1 A fire door assembly shall consist of components that are separate products incorporated into the assembly and are allowed to have their own subcomponents.
4.2.6.2* Except where restricted by individual published listings, a fire door assembly shall be permitted to consist of the labeled, listed, or classified components of different organizations that are acceptable to the AHJ.
If you know of any accessories like safety sensors, door loops, or hardware protectors that are listed for use as part of a fire door assembly, feel free to share the information in the comments.
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Hi Lori,
I have had a standing question around this and would love some input. Does the device have to be “listed” or listed as a device which maintains the fire labeling of the opening? For example, a 1″ door position switch that is drilled into the edge of the door and frame. These are typically plastic devices. They are UL listed security devices but I don’t recall any reference to stopping fire from penetrating the door and frame. I would love to be wrong! Thoughts?
Thanks,
Mike
Hi Mike –
I believe the intent is for the door position switch to be UL listed for use on a fire door in addition to the UL listing for security. I know we have a couple of door position switches that are listed for use on a fire door.
– Lori
Can you get me more information on the UL listed door position switch. I can’t find them on the website.
I pulled up Google Earth. I think I saw you at the top of the beach on the right side.
You were waving from under your palapa.
Haha – I’m not sure I want all of the iDH readers to be able to see me laying on the beach. 🙂
– Lori
NFPA-80 6.4.5.3
Labeling shall not be required where the top of the
protection plate is not more than 16 in. (406 mm) above the
bottom of the door.
Good point Moses! I’ll add something about this to the post after I get back from vacation.
– Lori
Lori,
The one I see more often is a request for fire listing for butt hinges. I have spoken with UL on many occasions and labeled hinges are not required on fire exits provided they meet the specifications spelled out in 6.4.3 or if different, meet the manufacturers published listings. Section 4.2.5 gives leeway to generic items not labeled as long as they are identified and their specifications are spelled out in NFPA 80.
Hi Matt –
You’re right…hinges are considered “items of a generic nature” which are not required to be individually listed/labeled if they meet the requirements spelled out in the standard (NFPA 80). I’ll add something about this to the post after I get back from vacation. 🙂
– Lori
Hi Lori –
Power loops, concealed power transfers, and electric power transfer hinges are all UL listed components. The concealed power transfer and electric hinge power transfer product typically have a UL10C 3 Hr rating. I’m not sure if the door loops are rated 3 Hr. Check DORMA+kaba or SDC Security products and you will find UL Listings. Kickplates should be labeled above a certain size. I cannot comment on sensors or hardware protectors. I did quickly review the BEA site and I didn’t see a UL Listing on the two door sensors I reviewed.
Hi David –
There are UL listings for fire, burglary, panic, etc., so for use as part of a fire door assembly we need to look for the listing for UL 10C specifically. There are some product categories where those products don’t seem to be readily available.
– Lori
Hi Lori –
To paraphrase, you asked, “are there any safety sensors, door loops, or hardware protectors that are listed for use on a fire door.” I completely understand there are different listings at UL for different applications. The SDC Security door hinges and PT5 concealed power transfer I described previously are specifically listed UL 10B. SDC Security’s Heavy Duty PTM concealed power transfer is specifically listed UL10C 3 Hr. This information is defined on their datasheets. I didn’t specifically look at the door loop, that is why I stated I wasn’t sure. (But after your reply, I reviewed the loops and they are not listed 10B or 10C. I’m not surprised – the plastic ends would melt off in seconds, exposing a hole into the door for fire to enter the door.) As I stated in my earlier reply, I do not know if sensors or hardware protectors are listed. This isn’t because I don’t understand what UL listing is required for fire door usage, but because I didn’t see the ‘UL Listed’ symbol in any product literature sheets that I reviewed prior to submitting my earlier post.
David
Sorry, I just re-read my earlier post.
Great topic, this comes up every day! Thanks and Merry Christmas!
You too Jerry!
– Lori
Lori,
This just happen to me today. Read your post yesterday and I received a phone from a hotel here in Florida we just finish. Fire Marshall was at the site looking at a pair of Full Glass Doors, 45 MIN Rated and he question not only the hardware which was Ives Hinges, Schlage L Series locks, but we had to give proof on the glass in the doors. When we purchase fire rate wood doors with glass, we always have glass installed by the MFG, It done by their testing and approvals. So I able to pull my PO and Acknowledgement and provide information for the fire rated glass. So I hope this satisfy the Fire Marshall for now. Your Blog has been a great help!!!
Thanks Carol
Hi Carol –
I’m glad the timing was right and the blog is helpful! I will continue to work on code development so eventually there are fewer mysteries for us to try to figure out!
– Lori
This might not be the most informed reply but here it goes. Before retirement, I used to try to answer these types of questions at the Hospital by considering the information UL puts out to be a “cook book” description of the assembly of components that was found to survive the attempted destruction of testing. If I could, I always used the entire assembly description and its component parts as my guide. I was always curious about things so I would also research what I could of the listing of individual components such as wall construction, hinge construction, gaps, etc. as they applied to the assembly of interest. This effort was to recreate an assembly that had the best chance of surviving the fire and limiting smoke. Not every variation can be tested of every component so what survived the original testing for listing seems to me to be the safest bet and surest to create.
By looking through the guidelines, it seems as if every component does need to be labeled. Hopefully in the future, the compliance guidelines will be rewritten to make this point even clearer!
i got a question :
can a fire rated doors and frames shipped to the site then put the labels or they must be labeled at the factory.
i could not find any paragraph on NFPA 80 to clarify
Hi Nabil –
I have never seen fire doors and frames labeled at the site except when there is a problem that requires field certification.
– Lori
Thank you all for the me info. I have rated door frames that I need to grill a 1” hole into and Mount on a door position sensor. The Schlage door position sensors are ul listed but they are plastic and I don’t see how the hell that can be rated. Does anyone know of any door position sensors that are fire rated for 45 or 90 minutes? I’m in a bind right now so any info helps.
Hi Ryan –
Which Schlage DPS are you looking at?
– Lori
If you’re drilling 1” holes into the frame and I presume the edge of the door! Are you also cutting in an electric strike? I was under the impression these are all field modifications and void the fire ratings of the assembly! I’m a door and hardware guy constantly butting heads with security guys who are hacking up lots of openings in our hospital! Your thoughts Lori! Thanks
Hi Rick –
NFPA 80 allows some job-site preparations, but anything beyond that would have to be done as a field modification which requires approval from the listing lab. There’s more info in this article: https://idighardware.com/2017/10/decoded-alterations-to-fire-door-assemblies/.
– Lori
What solutions do you have for Electric Mortise Locks, door position sensors and electric strikes that have the UL294 Listing?
Hi Lori, This is an older thread but seems to continue to gain industry traction and awareness. I’m 100% in agreement with your interpretation…..Regarding the safety sensors…..see UL Listing #R39071….I’ll also reply to you directly in case this thread is closed.
Thanks Jeff!
– Lori
Hi Lori, This comment is a bit after your 2016 blog…however, I hope you are still monitoring this. I have a question on what can be applied to a rated fire door. Do all items like posters, signs and safety finger door guards require labeling? I see in NFPA-80 Annex E -Surface Attachments to Swinging Door Faces…ARE NOT PART OF NFPA REQUIREMENTS, Plant-ons”shall be attached per the manufacturer’s listing instructions”. What is your interpretation of “manufacturer’s listing instructions” ? or do all “plant-ons” need to be tested and labeled? Thank you.
Brian,
Good question…let me break this down into parts: 1) Signs (Posters) on this subject NFPA80 is clear. It addresses Signage specifically, limiting the size (5% of the door face) and telling us how they have to be attached to the door (with adhesive not with fasteners). 2) As far as actual pieces of hardware, like finger guards, are concerned. I would be inclined to follow Lori’s lead in the article above and say that they need to be labeled or listed.
-Mark
I have a question concerning the corridor doors with 45-minute fire-rated openings in an old hospital. The Doors in these openings have labels, but there are no visible labels on the frames. Most of these frames are hollow metal frames embedded in concrete. These frames were installed before the 1980s, and some were as far back as the early 1960s.
I want to know if they must be removed and replaced with new labeled frames, as CMS requests. I believe it is an overreach of power for CMS to request this if the openings are in good working order, as tested and examined during the last annual Fire Door Inspection. I can’t see how removing an embedded Hollow Metal frame and replacing it with another Hollow Metal frame that is virtually identical except for a 45-minute rated label.
What are your thoughts?
Robert – National Firedoor, LLC in Miami Florida
Robert,
It’s hard to fight the AHJ in this case the CMS is the AHJ. However, I agree that in this case I would ask for a different solution. Has the hospital thought about getting a field labeling service to label the frames in place? I know I have suggested this many times and it has been a successful alternative to replacing grouted in frames and a much more affordable solution.
-Mark