I don’t want to give TMI and lead the witness(es), so I’ll keep this brief. I need some help from the field, especially if you are involved with health care projects.
Health care corridor doors (ex. patient rooms) are required to have positive-latching hardware, including the inactive leaf if the opening is a pair. What about fire doors in corridor doors in health care facilities? Do those require positive latching hardware on both leaves? Or would manual flush bolts and no closer be acceptable on the inactive leaf of a fire rated pair, for example, an opening leading to an unoccupied space like an electrical room or storage room?
There are differing interpretations on whether these pairs of fire doors need automatic or constant-latching flush bolts, so I would appreciate you sharing your experience.
If anyone has the ability to ask the Joint Commission for their opinion on this, I’d really appreciate it!
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Hi Lori,
Before I dive in, I’ll be referencing NFPA 101 (2012), NFPA 80 (2010), and IBC (2021).
My understanding is that manual flush bolts are not defensible on the inactive leaf of a corridor fire door pair in health care, even to an unoccupied room.
NFPA 80, section 6.4.4.5.1, permits them only where the AHJ accepts them. However, in new health care, NFPA 101, section 18.3.6.3.8, requires automatic flush bolts on the inactive leaf of corridor doors. In my opinion, 18.3.6.3.8, read with NFPA 101, section 2.1(2), nullifies the NFPA 80 allowance.
In existing health care, 19.3.6.3.5 leaves the means of keeping the door closed to the AHJ, with a few exceptions in 19.3.6.3.6. However, 42 CFR 482.41(b)(1)(ii) requires positive latching hardware on corridor doors and doors to rooms containing flammable or combustible materials regardless of the LSC, and The Joint Commission’s 2026 hospital PE chapter repeats it verbatim. As far as I know, a manual bolt does not constitute a positive latch, so in my opinion it does not satisfy that EP.
The IBC (2021), section 1010.2.5, exception 2, permits manual flush bolts on the inactive leaf of doors serving storage or equipment rooms (exception 5 for I-2 patient care rooms allows self-latching edge- or surface-mounted bolts, neither of which are manual flush bolts).
Setting all of that aside, I’d like to point out what I think is the essence of the allowance. NFPA 80, section 6.4.4.5, is written for pairs where the inactive leaf exists only to move large equipment through the opening, and NFPA 80, section 6.4.4.5.1 allows manual bolts where the AHJ determines they pose no hazard to life. Both point to a specific situation that I believe is unaffected by where it exists. An inactive leaf with manual flush bolts opening into a mechanical room off the maintenance shop, far from the egress corridor, is safe under these provisions. Move that same room and leaf to the corridor, and it is now deficient. Why?
Disengaging a manual flush bolt to move equipment is an intentional act, so the arrangement relies on the user intentionally re-engaging it. As long as this happens, I do not see how an inactive leaf with manual flush bolts in a corridor wall wouldn’t achieve the “maintaining tenable conditions” objective detailed in NFPA 101, A.19.3.6.3.5. If I’m honest, I don’t quite understand why we couldn’t extend that same logic to inactive leaves in the corridor that are also part of one of the following assemblies: fire barrier, smoke barrier, non-rated hazardous area, or suite perimeter. However, if someone is to make use of the manual flush bolt allowance, I think it needs to be paired with the “no closer” allowance detailed in NFPA 80-2010, A.6.4.1.1. This is simply because it would be nonsensical to say in one hand that the door is being used to move equipment in and out of the opening, and then install a closer on the door that you’ll be fighting while pushing said equipment through the opening. Do yourself the favor and stick with one of two arrangements: 1. Inactive leaf with manual flush bolts and no closer, or 2. Inactive leaf with automatic flush bolts, a closer, and a coordinator. Any combination of those two arrangements is sending mixed signals, in my opinion.
Hope this helps. Would love to know your thoughts.
Hi Derek –
I really appreciate all of this information! I will try to get an opinion from the Joint Commission so we will know for sure.
– Lori
Lori
You can log on the Joint Commission website and ask JC your question. Go to thier FAQ site scroll down to bottom of page and click on the link ask JC a question. Once you click on the link you will need to fill out a form and then enter your question then hit submitt.
Typically JC SIG will respond within 48 hours.
Hope the helps
Joe
Thanks Joe! Last time I asked a question they told me that they would only answer questions for “their” hospitals…hopefully that policy has changed!
– Lori
In addition to what was said about positive latching, I’ve seen the following section from 101 (2012) used to disallow manual flush bolts on corridor doors.
19.3.6.3.10* Doors shall not be held open by devices other than those that release when the door is pushed or pulled.
A.19.3.6.3.10 Doors should not be blocked open by furniture, door stops, chocks, tie-backs, drop-down or plunger-type devices, or other devices that necessitate manual unlatching or releasing action to close. Examples of hold-open devices that release when the door is pushed or pulled are friction catches or magnetic catches.
That’s interesting, Paul. How do you think manual flush bolts related to items used to keep the doors open?
– Lori
Lori –
I think it relates to the point that corridor doors need to close with a push or pulling motion, so by having to re-engage the manual flush bolt, it adds the extra step in the closing process.
The annex note talks about “manual unlatching to close”
IBC 2024 1010.2.4 Locks and Latches
There is a Table 1010.2.4 which breaks down the various types of bolts and where permitted.
Yes, that table is one of the things that raised this question, and there are differing opinions. Thanks Tony!
– Lori
Table 1010.2.4 permits manual flush bolts on a storage/equipment room when the inactive leaf is not needed to meet egress capacity requirements, provided the door does not qualify as a corridor door required to latch per footnote (a). Section 407.3.1 says, “Corridor doors, other than those in a wall required to be rated by Section 509.4…shall be equipped with positive latching…Other doors shall conform to Section 716.”
The scenario you described is a fire-rated storage/equipment room and would fall under the “Other doors” mentioned in Section 407.3.1. Therefore, it would not be constrained to the positive latching requirements of a corridor door, and we would need to comply with Section 716.
Section 716.2.6.2 says, “Unless otherwise specifically permitted…” and then requires an active latch bolt.
The Table 1010.2.4 manual flush bolt allowance for storage/equipment rooms is a “specifically permitted” reference. This position is further corroborated by the “Section 716 applies: Yes” sub-row for this application on the Table.
However, Chapter 18, Section 18.3.6.3.8 of NFPA 101 (2012) still doesn’t permit a manual flush bolt in a corridor, so NFPA and the IBC are not in harmony here.
What’s the alternate interpretation?
Thanks Derek! I’m absorbing all of the info I’m receiving and I’ll do a follow-up post.
– Lori