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.