Each component of a fire door assembly must be tested to verify that the assembly will provide the required protection during a fire.
Back in 2016 (where does the time go??), I answered a Quick Question: Does every component of a fire door assembly have to be listed/labeled? Although the intent of NFPA 80 is YES – every component must be labeled (based on feedback I have received from UL, Intertek, and NFPA staff), the standard still isn’t crystal clear.
I recently began using NFPA Link to access the NFPA publications, and the system includes “enhanced content” to help explain the intent of the codes and standards. Although this information is not part of the adopted code, code officials and others often use it to guide their interpretations.
While researching a different topic, I came across something in the enhanced content that helped to clarify the intent of NFPA 80 regarding whether every component has to be labeled. For example, I have heard people say that an electromagnetic lock or a separate deadbolt should not have to be labeled because these products are not serving as the positive-latching hardware for the fire door. This is incorrect – this hardware DOES have to be listed to UL 10C / NFPA 252 as part of a swinging fire door assembly.
I had a tough time finding the information again, because it is not with the section of the standard that addresses components. The components section establishes that for fire door assemblies addressed by Chapter 6 – Swinging Doors With Builders Hardware, the assembly can include components that are listed by different listing labs that are acceptable to the Authority Having Jurisdiction (AHJ). For example, a fire door could have a UL label and be installed in a frame with an Intertek label. But this section does not specifically state that components without a listing are prohibited.
In the 2022 edition of NFPA 80, the clarification about whether every component has to be labeled is part of the enhanced content found in Section 5.1.5 – Modifications:
One of the main requirements that a user of NFPA 80 should bear in mind is that each component that is attached to a swinging fire door (Chapter 6 doors) needs to be labeled for use on fire door assemblies. For example, there are very few door contact switches that are labeled and/or listed for use on swinging fire doors.
With this statement in the enhanced content on NFPA Link, we’re one step closer to a wider understanding of the intent of the standard. If a component will be installed as part of a fire door assembly, it needs to be tested to determine whether the assembly will perform properly during a fire; the results of this testing will be shown on the label, and in the manufacturer’s listings.
If you have other questions related to this interpretation, leave them in the comment box and I’ll see what I can do.
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Even the clarification needs clarification since it doesn’t address items that are otherwise exempted, like kickplates that are within the 16″ limit. But it is an improvement.
Hi Lori,
“This is incorrect – this hardware DOES have to be listed to UL 10C / NFPA 252 as part of a swinging fire door assembly.”
There are several references to A156.1 and other BHMA .listings starting in NFPA80(2019) 6.4.3.1 and I think it would take a very specialized reading to interpret these statements as calling for for the butt hinge bear a label, or pass a UL10c test. However, i find UL10c tests for hinges on the ULiQ site. What are your thoughts on this?
Is a door contact or electromagnetic lock considered Buikders Hardware (Chapter 6)?
I have a question concerning the Corridor door in a hospital. I have doors leading from corridors into rooms such as medical supplies, cleaning rooms, and electrical panel rooms. The doors are 45 minutes fire-rated, but I cannot find any labels on the hollow metal frames, which are in perfect working condition. This year’s annual Fire Door inspection listed them as deficiencies. They stated that these medal frames would have to be removed, and new ones would have to be installed with a fire-rated label on them. Some of these doors and frames have been installed for over 30 years. They are in good working condition and passed all other inspection items. I don’t think it makes any sense to replace them with what is the same frame, except it has a label attached. The cost is too high, and field relabeling by Intertex, or U/L is costly and is mostly eyewash. What are your thoughts?
I also have a question concerning a label that is missing on a Von Duprin 99 Rim Fire Exit Device; it was cited for a missing label; I can see where it was on the cover plate, but it was peeled off. Do I have to replace it, or can I get a new label or listing documentation that would satisfy CMS?
Robert,
Since labels must be visible and legible is a specific requirement listed in NFPA-80, I don’t think that there is anyway around it. However, most of the time relabeling frames is almost always cheaper than replacing grouted frames in masonry walls and when it comes to the fire exit hardware, I think you would need to replace the device.
-Mark
Thank You, Mark Kuhn. I agree with you about the frame labels it is always less expensive to relabel the other issue of Von Duprin 99 Fire Exit hard with a label that was removed is another issue its so easy to verify that the device is a fire-rated model from Von Duprin, no Dogging. every other door with the same hardware on it in this stairwell is the same hardware device. this one just had someone peel off the little label on the cover.