Today’s Quick Question originated with a fire door inspector:

If an existing fire door assembly has a hollow metal frame in perfect condition, but the frame is missing the label, is this compliant with NFPA 80?

While I could not find anything in NFPA 80 that addressed existing frames with no labels, there is a paragraph in NFPA 101:

8.3.3.3.4 – In existing installations, steel door frames without a label shall be permitted where approved by the authority having jurisdiction.

It looks like this section was added in the 2015 edition of NFPA 101, but there are a few things to consider…

• I don’t see this text in the 2012 edition of NFPA 101, which is the edition currently adopted by CMS and used by the Joint Commission and other accrediting organizations for health care facilities.
• I didn’t find similar text in the International Fire Code (IFC), which is enforced in many jurisdictions in lieu of NFPA 101.
• With that said, an AHJ has the authority to accept a non-labeled hollow metal frame as an equivalency, BUT – I’m not sure how often that actually happens, or whether they are checking the assembly to make sure everything is code-compliant.

I’d love to hear from you about what you’re seeing in the field.  Are non-labeled existing frames allowed to remain?  Or are the AHJs typically requiring these frames to be relabeled by someone who is authorized to do so?

Note: The photo in today’s post was either sent to me by Hal Kelton of DoorData Solutions or Mark Lineberger of Allegion.  Thanks guys!

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