Here’s my next Decoded column…let me know if you have anything to add.
This article will be published in the April 2020 issue of Door Security + Safety
In recent years, the increased enforcement of annual fire door assembly inspections has brought new focus to the condition of existing fire doors. Many questions have resulted – some of which have not been specifically answered by the codes and standards. In the absence of prescriptive code language, the interpretations are left up to the Authority Having Jurisdiction (AHJ), and this sometimes leads to inconsistent enforcement.
A change has been approved for the 2021 edition of NFPA 101 – Life Safety Code, which will help to clarify an issue that has been a source of confusion. The question: If a labeled fire door is installed in a location where a fire door is not required, must the assembly be maintained and inspected according to the requirements of NFPA 80 – Standard for Fire Doors and Other Opening Protectives?
It’s quite common for labeled fire doors to be found where they are not mandated by code. For example, the door may have been moved from its original location, or a wall that was once fire-resistance-rated may no longer require that level of protection due to the addition of an automatic sprinkler system. If a door assembly must be maintained and inspected per NFPA 80 just because the door has a label on it, this could result in expensive and unnecessary work which has no impact on life safety. What is the point of having a code-compliant fire door assembly in a wall that will provide little resistance to the spread of fire?
Intent of NFPA 101
NFPA 101 mandates the minimum fire ratings for opening protectives in fire-resistance-rated walls. This is a MINIMUM requirement – there is no language in the code that would prohibit a door with a higher rating from being installed, and the code does not restrict fire doors from being installed where they are not required. If a fire door is installed where a rating is not needed, NFPA 101 does not mandate that the door, frame, and hardware must meet all of the requirements of a fire door assembly.
A label is not required by NFPA 101 to be removed if the assembly is in a location where a fire door is not required, although removing an unneeded label is not prohibited by the code. It may be advantageous to remove extraneous labels to avoid confusion during an inspection. For example, if an AHJ sees a labeled fire door without a door closer, he or she may initially believe that the door is a fire door assembly that is not self-closing; this would be a deficiency. The facility manager would then have to prove that the rating is not required. It’s important to note that once a label is removed, it can’t be reattached by facility personnel. The assembly would have to go through the field labeling process as described in NFPA 80.
Questions about extraneous labels have been caused by a section of NFPA 101 which states that “Existing life safety features obvious to the public, if not required by the Code, shall be either maintained or removed.” The motivation behind this requirement is the idea that if a building occupant sees a life safety feature and assumes that it is functional, they might make decisions based on that assumption. For example, if the occupant of an apartment sees sprinkler heads in the ceiling, they may shelter in place during a fire, based on the protection provided by the sprinkler system. But maybe the building owner shut down the sprinkler system because of a leak and never repaired it. Even if the building pre-dates the sprinkler requirements and the sprinkler system is not mandated by code or local ordinance, NFPA 101 requires the system to be maintained or removed, so that life-or-death decisions are not based on bad assumptions.
The big debate has been whether a label on a fire door or frame is something that would be “obvious to the public”, and whether it might cause someone to assume that they would be protected by the fire door during a fire. If the door was labeled but was not fully compliant with NFPA 80, the building occupant would not have the expected protection provided by a complete and code-compliant fire door assembly in a wall that meets the requirements for a fire barrier. The door might have a label, but perhaps it is not self-closing or self-latching, or does not have the proper glazing, or the wall does not offer the same level of fire protection shown on the door label.
The general consensus was that most building occupants would not notice the fire door label, or wouldn’t understand the implications, but some AHJs continued to require fire door labels to be removed if not required. In some cases, AHJs were also requiring the fire door assembly label to match what was required for that location – no more, no less. If a 45-minute door was required, the interpretation was that a 90-minute door could not be installed. The common interpretation in years past was that the fire rating of the overall assembly was equal to the rating of the lowest-rated component. As long as that rating was equal to or greater than what was required, the assembly was acceptable – a 90-minute door in a 3-hour frame could be installed in a location that required an opening protective rated for up to 90 minutes.
In the 2015 edition of NFPA 101, a line was added to the annex information for the section of the code addressing obvious life safety features, stating: “Where a door that is not required to be fire protection-rated is equipped with a fire protection listing label, it is not the intent of 220.127.116.11 to require such door to be self- or automatic-closing due merely to the presence of the label.” The intent of this change was to clarify that door assemblies with a labeled component are not required to be treated as fire door assemblies. Despite this clarification, some AHJs continued to require all labeled fire doors to be inspected and maintained in accordance with NFPA 80, even though there was no life-safety benefit.
A new paragraph has been approved for inclusion in the 2021 edition of NFPA 101, which further clarifies the intent of the code:
“18.104.22.168 Where a door or door frame that is not required to be fire protection-rated is equipped with a fire protection listing label, the door and the door frame shall not be required to meet NFPA 80.”
The problem statement submitted as part of the code development process referenced the 2015 change to Annex A. Although that change was intended to clarify that the requirements of the section were not meant to pertain to fire doors, interpretations were still inconsistent. Facilities were being cited by AHJs for non-compliant fire door assemblies – even when those assemblies were installed in locations where a fire rating was not required. This was because some AHJs were interpreting fire doors and frames as being life safety features that were obvious to the public.
The paragraph that has been approved for the 2021 edition of NFPA 101 is very clear. If a door or frame has a label and is installed where a rated opening protective is not required, the requirements of NFPA 80 do not apply. Although a code change does not technically take effect until that edition of the code is adopted, this change is more of a clarification and hopefully, it will begin to affect AHJ interpretations immediately.
The new code language makes it clear that extraneous labels can remain, without prompting additional requirements. The intent of NFPA 101 is that only the required opening protectives indicated on a facility’s life safety drawings must be maintained in accordance with NFPA 80 and must be inspected annually. As always, the AHJ has the final say and should be consulted for their interpretation of the adopted codes.