There has been quite a bit of discussion about this lately – fire doors installed where they are not required, listed components used on openings that are not fire door assemblies, products with different labels in the same assembly (for example, a 20-minute door in a 90-minute frame).  I think the reason behind this increased focus is the enforcement of annual fire door inspections in health care facilities.  I wrote about a possible conflict between the NFPA requirements and the Joint Commission’s procedures back in November, and I still haven’t received notice of a resolution.

So we’ll keep chipping away at this issue until we are all clear on the intent of the model codes and standards.  Today’s “chip” is the question of using fire exit hardware on a door that is not fire rated.  Is this acceptable?  Would the hardware or the entire assembly then have to be inspected annually?

Fire exit hardware is a type of panic hardware which is tested in accordance with UL 10C for use on fire doors, in addition to being listed to UL 305 for panic hardware.  Typically, fire exit hardware would not be installed on a non-fire-rated door because fire exit hardware usually costs a bit more and does not include the dogging feature.

But what if a facility locksmith has fire exit hardware in stock and considers installing it on a non-fire-rated door?  Or maybe a fire door is no longer needed in a specific location and the door label has been removed…can the fire exit hardware remain in place?  As with so many questions like this, the codes and standards don’t specifically state the answer.  Sometimes we just have to attempt to understand the intent of the codes and hope that the AHJ agrees.

I found something in the 2015 edition of NFPA 101 that may help us understand NFPA’s position on this issue.  Even though a previous edition of NFPA 101 (the 2012 edition) is being enforced for most health care facilities, the language added in the 2015 edition is more of a clarification than an actual change.

This paragraph is included in the 2012 and 2015 editions of NFPA 101:* 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.

This line was added in Annex A of the 2015 edition:

A . The presence of fire exit hardware on a door does not imply the door is required to be a fire protection–rated door.

The Annex A language indicates that it is possible to have fire exit hardware on a non-rated door.  In my opinion, the language in NFPA 101 would prevent panic hardware without the UL 10C listing to be installed on a fire door assembly, but does NOT prevent fire exit hardware with the UL 10C listing to be installed on a non-fire-rated door.

I checked with NFPA staff to make sure I wasn’t missing something, and the staff member confirmed that neither NFPA 101 nor NFPA 80 prohibit the use of fire exit hardware on a non-fire-rated door, and also that the use of fire exit hardware would not prompt a need for annual inspection of the non-fire-rated assembly.  The inspection requirements apply to opening protectives in locations where fire door assemblies are required.  The installation of an individual listed component in a location that is not required to have an opening protective does not result in a need for annual inspections.

As always, I welcome your thoughts on this…whether you agree or disagree!  This is my opinion, along with the NFPA staff opinion – an AHJ may or may not agree.

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