A couple of weeks ago, I wrote a post about annual fire door assembly inspection and why it’s important for the safety of building occupants. The video below from a recent hotel fire clearly illustrates how code-compliant fire doors can help to save lives.
If all fire door assemblies were kept in code-compliant condition at all times, maybe fire door inspections wouldn’t be quite so important. But the truth is…the majority of existing fire doors have deficiencies, and there’s no way to know how the doors will function during a fire. Case in point…last November I wrote about a report that had been released by the Minnesota State Fire Marshal’s Office. The report detailed a fire that occurred in a Minneapolis high rise, where 5 people were killed. According to the report, the door leading to the apartment where the fire originated did not close properly because of a seal at the bottom of the door that caught on the flooring. This open door contributed to the fatalities as well as the property damage.
If the door to Apartment 1407 had been subject to a fire door inspection, presumably the deficiency would have been resolved and the door would have closed automatically to deter the spread of the fire. Unfortunately, a few months before the fire occurred, Minnesota removed the requirement for annual inspections from their state fire code:
Exception: Periodic testing and inspection in accordance with NFPA 80 and NFPA 105 is not required for swinging fire door and smoke door assemblies. Swinging fire door and smoke door assemblies shall be maintained in an operable condition in accordance with NFPA 80 and NFPA 105. Damaged or defective swinging fire door and smoke door assemblies shall be repaired or replaced.
When making this modification to the International Fire Code (IFC), a Statement of Need and Reasonableness was submitted, explaining the reason for removing the inspection requirement – it was unnecessary and too costly:
7511.0705 SECTION 705, DOOR AND WINDOW OPENINGS.
This new rule part modifies section 705.2 of the 2018 IFC by adding an exception exempting swinging fire door and smoke door assemblies from the testing and inspection requirements of NFPA 80 and NFPA 105. Section 705.2 of the 2018 IFC requires opening protectives to be inspected and maintained in accordance with NFPA 80 and NFPA 105, which includes swinging fire door and smoke door assemblies. The inspection and testing of swinging fire door and smoke door assemblies is a requirement that is new to the 2018 IFC and is a significant change to the code.
The annual inspection and testing of swinging fire door and smoke door assemblies is unnecessary because of the relatively simple operation of these types of door assemblies and the expense of testing. The Minnesota State Fire Code only requires annual inspection and testing of horizontal and vertical rolling and sliding doors because their operations are complex and require testing to ascertain that they are operating correctly. To ensure that a swinging fire door or smoke door assembly is operating correctly, all that is needed is: (1) a visual check for damage and alteration; and (2) verification that the door fully closes and latches when released from the full open position. NFPA 80 and NFPA 105 require specialized testing and inspection of swinging fire door and smoke door assemblies unnecessary to ensure that the door operates properly. The cost of NFPA 80 and NFPA 105 compliant inspection and testing of swinging fire door and smoke door assemblies can represent a significant cost for larger apartment buildings and lodging facilities. For an apartment building with 100 units and 120 swinging fire doors, the cost of inspection and testing is approximately $2,400 per a year. It is reasonable to exempt swinging fire door and smoke door assemblies from the testing and inspection requirements of NFPA 80 and NFPA 105 because: (1) under section 705.2, the doors will still need to be maintained in accordance with NFPA 80 and NFPA 105; and (2) extensive testing and inspection is unnecessary to verify that the doors operate in compliance with those standards.
The Minnesota exemption states that fire door assemblies don’t need to be inspected, but that the assemblies must be maintained in operable condition with deficient components repaired or replaced. The model codes have always required these assemblies to be properly maintained, but this requirement isn’t enough – proven by the condition of millions of fire doors across the US. That is exactly why fire door inspections are now required by code. In my opinion, removing the inspection requirements through a state modification of the model codes is detrimental to the safety of building occupants.