Adding Windows to Fire Rated Doors

Q: I have a supply room on a medical surgical floor and the door opens into the corridor.  The corridor and the room are protected with automatic sprinklers.  Because it is a supply rom we are using a 3/4 hr door.  We would like to allow light to enter the room from the corridor and wanted to install a window in the door.  Are we allowed to do this and are we limited to the size of the window?

A: Since you said the door is ¾ hour fire rated, then section 8.2.3.2.1 of the LSC requires compliance with NFPA 80, Standard for Fire Doors and Fire Windows (1999 edition). NFPA 80, section 1-3.4 requires any modifications on fire rated doors to be performed in facilities that are licensed by the door manufacturer. The manufacturer is the entity with the responsibility of ensuring the integrity and fire rating of the door and any modifications to their specifications would jeopardize that rating. Therefore, the standard does not allow any field modifications to a fire rated door, other than those required to install already approved fire rated hardware, such as door closures, latch-sets and hinges. So, the answer to your question is yes, a window would be permitted to be installed in a fire rated door, but the door would have to be removed and sent back to an approved licensed facility were the modification could be made. However, as you could imagine, this is not a simple or inexpensive proposition, and is not done very often.

Magnetic Latches on Suites

Q: We recently had an inspection in our hospital where the inspector cited us for our suite doors not having positive latching. The suite doors have 1500 pound access-control magnets controlled by card-swipe badge readers and with wall-mounted push buttons. They are on emergency power and eight-hour battery back-up. They are also approved by our local and state fire marshals. Is the inspector correct, or do I have a case for an appeal?

A: The concept of a Suite-Of-Rooms requires the barriers of the suite to be protected in the same manner as any other room bordering on an exit access corridor. Therefore, entrance doors to the suite must meet the requirements of corridor doors. In your question, you did not specify if your organization is considered a new healthcare occupancy or an existing healthcare occupancy. This is an important issue, as there are different requirements for each. If your facility’s construction documents were approved by the local authorities after March 1, 2003, then it is considered a new healthcare occupancy.

In new healthcare occupancy, section 18.3.6.3.2 of the 2000 edition of the Life Safety Code specifically requires positive latching hardware for corridor doors. The definition of positive latching is a spring-loaded throw on the edge of the door to engage in the strike plate of the door frame. Magnetic locks do not qualify as positive latching hardware. Therefore, you may not use magnetic locks in new healthcare occupancies for suites (corridor doors).

However, for existing healthcare occupancies, section 19.3.6.3.2 of the same Code specifically allows a device capable of keeping the door fully closed with a minimum force of 5 foot-lbs. Some authorities having jurisdiction (AHJ) approve of magnetic locks for this purpose as long as power to the locks is NOT interrupted during a fire alarm signal. Doors in the path of egress are not permitted to be locked except where the clinical need of the patient requires it. Not all AHJs agree on what types of patients qualify for this exception. When locks are permitted on egress doors, they must meet the requirements found in 19.2.2.2.4. The entrance door to a suite-of-rooms is permitted to be locked, as the path of egress is not allowed into and through a suite.

Magnetic locks in lieu of positive latching on corridor doors is not recommended as there are many complications and challenges in compliance, and not all of the AHJs agree on this application. It appears that a successful appeal on this issue would be difficult.

Door swing in direction of egress?

Q: As we work through deficiencies that were found by a consultant, there is one question we need to have clarified regarding doors. The reference to the deficiency is LSC 7.2.1.4 (2000 edition) citing the deficiency as the door swing makes exiting impossible in both directions. We understood that the doors did not need to swing in opposing directions if they are on existing doors. We understood if new doors are being installed they need to be in opposing directions. What is your take on this item in the LSC?

A: I’m not sure I agree with you. It all depends on the use of the door. Is it a door to a stairwell? Or a horizontal exit? Or a smoke compartment barrier? Your question does not make it clear what purpose the door serves, so let’s look at all of the possibilities.

We start with Chapter 19 for existing conditions in the LSC. Look at 19.2.1 where it says every aisle, passageway, corridor, etc. must comply with Chapter 7, except where modified in sections 19.2.2 through 19.2.11. The modifications found in section 19.2.2.5.3 say a door in a horizontal exit does not have to swing with the direction of egress. Also, section 19.3.7.6 says doors in a smoke compartment barrier do not have to swing in the direction of egress. So that pretty much wraps up the exceptions to Chapter 19.

Let’s look at Chapter 7 for door swing requirements:
• 7.2.1.4.2 says side-swinging doors must swing in the path of egress when the room or area served by the door has an occupant load of 50 or more people
• 7.2.1.4.3 says doors shall swing in the direction of egress when used in an exit enclosure (stairwell) or when serving a high hazard area (not very likely in a hospital)
• Chapter 19 provides exceptions for horizontal exits and existing smoke compartment doors, as described above

So what does your door serve?

A stairwell? Then it DOES have to swing in the direction of egress.

A room with an occupant load of 50 or more? Then it DOES have to swing in the direction of egress.

A smoke compartment barrier? Then it DOES NOT have to swing in the direction of egress, as long as it qualifies as an existing condition.

A horizontal exit? Then it DOES NOT have to swing in the direction of egress as long as it qualifies as an existing condition.

A hazardous room (not a high hazard room)? Then it DOES NOT have to swing in the direction of egress.

Note: Existing conditions are defined as those conditions which were approved for construction prior to March 1, 2003.

Door Holder for Isolation Supplies

Q: We are considering the use of storage devices that hook over the top of the patient room corridor doors that will store supplies that we use for contact precautions. Nurses will then be able to access isolation supplies before they enter the room. Are you aware of any reason why these devices could not be used in a hospital?

A: Yes, there may be a few reasons not to use these devices. Will the storage device protrude more than 6 inches into the corridor when mounted on the door? If so, then it would not be permitted. Will the device damage the corridor doors and render them unable to close completely? If so, they would not be permitted. Joint Commission and CMS will permit the use of carts in the corridor to store isolation supplies, as long as the cart is serving a patient who is actively on contact precautions. Typically these carts will hold more supplies than the door storage devices. I know some state health departments will not allow carts in corridors for isolation supplies regardless what Joint Commission or CMS says, so the door storage devices may be the only solution for you.  However, if your state does not have any such limitations, then I suggest you stick with the carts. Damage to the doors and any interference the storage devices would have on the corridor door closing properly would be a great concern of mine.

Laboratory Entrance Doors

Q: We had a mock survey recently and the life safety surveyor indicated that the lab — because it is a hazard area — is required to have all the doors closed to corridors. He said approved hold-open devices don’t count. But we use approved hold-open devices on some of our lab doors. If we are sprinklered and we have door hold-open devices, are we are good to go?

A: Laboratories are required to be treated as hazardous areas if they contain flammable materials in quantities less than what would be considered a severe hazard (NFPA 101-2000 19.3.2.1 LSC). If the lab contains flammable materials in quantities considered to be a sever hazard, then they still need to be treated as hazardous rooms with fire rated walls (per NFPA 99). Any way you look at it, the door to the lab is required to have a closure and positive latching as a hazardous room door.

Section 19.2.2.2.6 permits any door in an exit passageway, stairway enclosure, horizontal exit, smoke barrier, or hazardous area enclosure to be held open by an automatic releasing device that complies with 7.2.1.8.2. The automatic sprinkler system and the fire alarm system in your building must be arranged to initiate the closing action of all such doors throughout the smoke compartment or throughout the entire facility. This means if you have approved hold-open devices that are connected to the fire alarm system on the lab doors, and they release the door when the fire alarm system is activated, then you qualify to have these devices. The fact that your facility is sprinklered does not have any bearing on this subject.

It appears to me that your scenario of approved hold-open devices connected to the fire alarm system meets the requirements of Life Safety Code.

Door Closing Time

Q: Is there a maximum time required for doors to automatically close? This question came up in a recent department meeting and we cannot find any code reference that specifies how quickly a door must close.

A: It depends if the door is a swinging type or sliding type. The LSC and NFPA 80 Fire Doors and Fire Windows (1999) does not specify the amount of time that a closure must close a swinging door, whether it be for a fire rated door or a non-fire rated door. However, section 4-4.1.1 and 4-4.1.2 of NFPA 80 requires horizontal sliding doors to have a delay of no more than 10 seconds in the initiation of the closing, and the average speed of the closing must be between 6 and 24 inches per second. I suggest you ask your local AHJ if they have a requirement other than NFPA that addresses this issue.

Smoke Detectors Used for Door Release

Q: In our hospital, we have smoke compartment doors in the corridor that are held open with magnetic hold-open devices. When the fire alarm system is activated, the magnetic devices release and the doors automatically close. Are we required to have smoke detectors located within 5 feet of these doors, even though the smoke compartments on either side of the doors are fully protected with smoke detectors?

A: The Life Safety Code (2000 edition) requires your fire alarm system to be in compliance with section 9.6 which further requires compliance with NFPA 72-1999 National Fire Alarm Code. Section 2-10.6 of the National Fie Alarm Code states that smoke detectors that are part of an open area protection system that is covering the room, corridor or enclosed space on each side of the smoke door and that are located and spaced according to NFPA 72-1999, section 2-3.4, shall be permitted to accomplish smoke door release service. Therefore, if your smoke detectors actually meet the spacing requirements found in 2-3.4 on both sides of the smoke door, then you do not need to have a smoke detector mounted within 5 feet of the door to release the door in the event of an alarm.