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:
18.104.22.168 A fire door assembly shall consist of components that are separate products incorporated into the assembly and are allowed to have their own subcomponents.
22.214.171.124* 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.