A fire protection engineer recently sent me this photo from a health care facility, which shows a fire door assembly with the original 20-minute label on the door. A new “field inspected fire door” label has been added below the original one, stating that the door is labeled for 60 minutes. Today’s Quick Question is this:
Can an existing fire door be labeled in the field for a higher rating than what it was originally listed for?
Since the opening in the photo happens to be a Steelcraft door and frame, I asked our engineer for her opinion, based on our fire door and frame listings. She responded that a door can not typically be field-labeled as a door with a higher rating – at least not without further investigation. Although technically a hollow metal door may carry a rating of up to 3 hours, there are modifications such as vision lights and hardware preps that affect the maximum allowable rating.
The door in the photo would have been listed in our records as a 20-minute door, not a 60-minute door. It would be difficult or impossible for a field-labeler to know whether a particular door or frame would meet the requirements for a rating different from what was on the label. If a change in the rating was required, it would likely involve the listing lab (UL, Intertek, etc.) to determine whether the change could be made as a field modification, defined by NFPA 80.
For many years, nationally-recognized testing laboratories have provided field labeling services for installed assemblies when the original labels have been painted or removed, or where doors or frames have been modified. A section was added to the 2016 edition of NFPA 80, addressing field labeling of existing fire doors, shutters, and windows, as there has been an increased demand for these services along with the increased enforcement of annual fire door assembly inspections.
In short, the new section mandates the following:
- Individuals or companies performing field labeling must be certified or listed, or individuals or companies must be representatives of a labeling service that “maintains periodic inspections of production of labeled equipment or materials and by whose labeling the manufacturer indicates compliance with appropriate standards or performance in a specified manner.”
- Individuals must provide proof of qualifications to the AHJ prior to performing the field labeling.
- Field-applied labels must include, at minimum, the words “field inspected” or “field labeled”, the words “fire door” or “fire door frame”, the marking of a third-party certification agency, the fire protection rating, a unique serial number (if provided by the listing agency), and the fire test standard designation to which the assembly was tested.
- If a fire door assembly is required in a location where a non-fire-rated assembly was installed, NFPA 80 includes some requirements and limitations related to that process.
Hopefully, we will see further guidance on field labeling in the future from the test labs and organizations representing manufacturers of fire doors. Until then, any questions about field labeling should be carefully considered by the manufacturer and the AHJ to ensure that the labels applied in the field are accurate.
If you have insight or experience with this issue, please share it by leaving a comment!
Thank you to Matt Ruhrer of HDR Inc. for the photo!