In case you missed this short paragraph in the NFPA Journal article I shared on Monday, I wanted to bring it to your attention since several iDigHardware readers emailed me about it…
Several years ago, I posted about the problem related to varying interpretations of a section of NFPA 101 that required life safety features visible to the public to be maintained or removed (if not required). The question was whether a fire door label would be obvious to the public and therefore the fire door assembly would need to be maintained and inspected as required by NFPA 80 – even if it was in a location where a fire door was not required.
In my Decoded column in the April edition of Door Security + Safety Magazine, I wrote about a proposed change to the 2021 edition of NFPA 101, which clarifies that just because a door has a fire door label does not mean that it must be maintained and inspected as a fire door assembly. If it is installed in a location where a fire door assembly is required, then of course it must comply with NFPA 80. But the change makes it clear that the presence of an extraneous label is not prohibited by NFPA 101.
For example, if a labeled fire door is taken out of stock and installed in a location where a fire door is not required, it is not mandatory to add a closer, latch, etc., or to inspect the opening annually. This has been a huge problem for many health care facilities – it’s very expensive to rectify, with little or no benefit to life safety. Although fire door inspections may be easier to manage if extraneous labels are removed, NFPA 101 does not require these openings to be “decommissioned.”
In case anyone was skeptical (or you run into an AHJ who is still using the “old” interpretation), the proposed change to NFPA 101-2021 was mentioned in the NFPA Journal article – 2021 Code Revision Roundup:
“Another change that could have a significant impact on health care and other occupancies is a proposed revision that would eliminate the inspection, testing, and maintenance requirements for extraneous fire doors that aren’t required by code. Those fire doors would now be treated as regular doors, resulting in time and cost savings for facilities.”
This makes the intent of NFPA 101 clear, and the text of the code will be finalized within the next few months. Although it will likely be years until there is widespread adoption of the 2021 edition, I see this as more of a clarification than a change, so hopefully it will start impacting the interpretations right away.