egress door hidden by mural

Photo: Gail Erickson

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:*  Doors permitted to be locked in accordance with 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
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

By referencing section, 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.

Basketball  Horse

Photos courtesy of FromEUWithLove on Etsy.

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