This post from 2015 has been updated with new information from the 2021 edition of NFPA 101 – Life Safety Code.
I have written several times about the model code requirements for doors in a means of egress to be readily distinguishable as exits. The International Building Code (IBC) states: “Means of egress doors shall be readily distinguishable from the adjacent construction and finishes such that the doors are easily recognizable as doors. Mirrors or similar reflecting materials shall not be used on means of egress doors. Means of egress doors shall not be concealed by curtains, drapes, decorations or similar materials.” To date, I have not found an exception to this requirement in the I-Codes, other than some new language related to puzzle rooms (escape rooms).
Beginning with the 2015 edition of NFPA 101 – Life Safety Code, a section was added that allows egress doors in some types of health care units to be disguised with murals. The intent of this exception is to help deter exit seeking and elopement, particularly in memory care units. Patients with mental illness can become fixated on exit doors, so disguising the door may help to create a more calming environment and reduce the chance for elopement when staff members use the door.
The 2012 edition of the Life Safety Code has been adopted by the Centers for Medicare and Medicaid Services (CMS), and this edition does not include the new sections addressing murals. Disguising doors in facilities that are accredited by the Joint Commission or another accreditation organization would require permission from the Authority Having Jurisdiction (AHJ).
The 2021 edition of the code includes a clarification related to fire door assemblies:
126.96.36.199.7* Doors permitted to be locked in accordance with 188.8.131.52.5.1 shall be permitted to have murals on the egress doors to disguise the doors, provided all of the following are met:
1. Staff can readily unlock the doors at all times in accordance with 184.108.40.206.6.
2.* The door-releasing hardware, where provided, is readily accessible for staff use.
3.* Door leaves, windows, and door hardware, other than door-releasing hardware, are permitted to be covered by the murals.
4. The murals do not impair the operation of the doors.
5. The location and operation of doors disguised with murals are identified in the fire safety plan and are included in staff training.
6. Any modification to a fire door complies with NFPA 80.
This section also appears in the chapter for existing health care facilities, with an additional requirement:
5. The affected smoke compartments are protected throughout by an approved, supervised automatic sprinkler system in accordance with 220.127.116.11.
By referencing section 18.104.22.168.5.1, the code limits these murals to doors where controlled egress locks are allowed. These are doors that are allowed to be locked in the direction of egress where containment is required for the security or protection of patients. Doors must be capable of being unlocked by either a) remote control, b) keys carried by staff, or c) other reliable means available to staff at all times. According to Annex A, this method might be acceptable for psychiatric units, Alzheimer units, and dementia units, along with forensic units and detention units. The annex also mentions pediatric units, maternity units, and emergency departments as examples of areas which might justify controlled egress.
Item 6, added in the 2021 edition of NFPA 101, clarifies that any modifications to fire doors must comply with NFPA 80. For example, if a decorative film is added to a fire door, my interpretation of NFPA 80 is that the film must be listed for that purpose (if you know of a listed film, let me know) or application of the film must be allowed as a field modification. On the other hand, painting a fire door in the field is not considered a field modification that requires approval in advance from the listing laboratory.
Remember, the use of murals in these units is allowed by the 2015 edition of NFPA 101 and subsequent editions, but is not addressed in the I-Codes. In jurisdictions where the adopted code is the IBC or IFC, disguising an egress door would require permission from the AHJ. Note that a mural on the access side of the door (vs. the egress side) would not be prohibited by code, but if it’s a fire door it must comply with NFPA 80.
There is a wide variety of door mural designs available, but keep in mind the requirement for a listed product if the door is fire rated. Given the change to NFPA 101, don’t be surprised if you find what appears to be a brick wall or approaching wildlife the next time you visit a memory care unit.
Photos courtesy of FromEUWithLove on Etsy.
You need to login or register to bookmark/favorite this content.
Wonder who brought forth that change?
Note also, it is allowed in existing:::
101 2015 edition:
22.214.171.124.7* Doors permitted to be locked in accordance with 126.96.36.199.5.1 shall be permitted to have murals on the egress doors to disguise the doors, provided all of the following are met:
Staff can readily unlock the doors at all times in accordance with 188.8.131.52.6.
The door-releasing hardware, where provided, is readily accessible for staff use.
Door leaves, windows, and door hardware, other than door-releasing hardware, are permitted to be covered by the murals.
The murals do not impair the operation of the doors.
The affected smoke compartments are protected throughout by an approved, supervised automatic sprinkler system in accordance with 184.108.40.206.
The location and operation of doors disguised with murals are identified in the fire safety plan and are included in staff training.
220.127.116.11.4 The requirements established by this chapter shall apply to the design of all new hospitals, nursing homes, and limited care facilities. The term hospital, wherever used in this Code, shall include general hospitals, psychiatric hospitals, and specialty hospitals. The term nursing home, wherever used in this Code, shall include nursing and convalescent homes, skilled nursing facilities, intermediate care facilities, and infirmaries in homes for the aged. Where requirements vary, the specific subclass of health care occupancy that shall apply is named in the paragraph pertaining thereto. The requirements established by Chapter 20 shall apply to all new ambulatory health care facilities. The operating feature requirements established by Section 18.7 shall apply to all health care occupancies.
“””Does not seem to limit what setting the doors are in”””
18.104.22.168.5.1* Door-locking arrangements shall be permitted where the clinical needs of patients require specialized security measures or where patients pose a security threat, provided that staff can readily unlock doors at all times in accordance with 22.214.171.124.6.
Thanks Charles. I did mention new and existing in the post, but I just added an additional note referencing the code section to help clarify.
okay, you got me.
where’s the lever or release mechanism on the brick wall w/ basketball hoop?
Maybe it’s a push/pull door. 🙂
“If the door is allowed to be locked in the direction of egress, I’m not sure why it would also need to be disguised. Maybe the use of murals is meant as an alternative to controlled egress, but as the code is written, both could be used.”
Patients with mental illness can become fixated on exit doors, so by disguising them it creates a calming environment. It also lessens the chance for elopement when staff use the door as the patients don’t stand by the door waiting for it to open.
Thanks for your insight, Greg!
The examples shown are, at least, clearly different from the adjacent walls. Better than the hide it/match the wall approach seen in other settings. Still, training staff to know that these are doors is important
This is great info, thanks all for sharing. My concern is for the actual product that is used. Is it safe for use from a fire safety perspective? I work in Alberta and all films and decorative materials must be approved for use, meeting CAN/ULC S-109 standards. I have not yet seen a product that is approved for use on a fire rated door. It’s a super idea for our at risk patient and clients but how do we achieve the desired results safely?
Hi Gerry –
I had the same question. When I talked to UL, I think there was only one company who had listed something similar (not for this use specifically) but I don’t think the murals that many facilities are applying to doors are listed for use on a fire door. I’m not familiar with the requirements for wall coverings or whether these products would be an issue for a non-fire-rated door with a flammable layer applied to it. I guess the fire doors could be painted with similar designs and be code-compliant, but the applied film is obviously less expensive, less disruptive, and easier to maintain.
Lori, thanks for your prompt reply!! I am always concerned when new products just show up, installed, with being proven that they are safe for use in care or hospital setting. I’m glad that I stumbled across your blog! and i’ll keep researching. _ gerry
The murals would not be allowed in Health Care facilities that fall under the Federal Government guidelines. They are still using the NFPA 2000 code. Until the Federal Government adopts the NFPA 2015 they would not be allowed.
That is correct, Rudy. As with all new code requirements, they don’t apply unless that code has been adopted by the AHJ for that project’s jurisdiction.
I often wonder what research would lead to the conclusion that some mentally confused person would be calmed by the image of horse charging through what was a doorway. It seems to me that sometimes bad changes occur because the change is based on nothing other than someone’s desire to be responsible for a change. I don’t really trust the basis for the mural change. I am glad to see someone is concerned about how such a large plant-on (to use what is probably now an archaic term for things mounted on fire doors, like signs) might affect the door. This has been studied and objects mounted on fire doors can change heat transfer enough in some cases to cause the door to destructively warp in a fire, enough change to cause the latch to fail as the door bows in the frame.
When I worked in healthcare, I had to resist hundreds of requests that made little or no sense. Like the request to carpet and decorate a 10 story stairwell so it would be “more friendly to people who would then use the stairway instead of the elevator.” The bare cement stair could not have been safely and successfully carpet due to its construction. I felt worst than that, the surface would be transformed from a very sound an safe walking surface into one less safe, particularly with evacuation being its use. It did not get done.
I’m guessing that most memory care units aren’t ordering the charging horse decal, but you never know! 🙂
Thanks, as always, for sharing your insight.
Per comment from Louise. I agree, the hardware is difficult to see. If it was a push pull assembly it would not be rated or controlled egress, exempt from NFPA guidelines, but a concern.
Btw, I also agree, a horse charging through a door is not a comfort.