Aug 25 2017

Smoke Barrier Doors

Category: Doors,Questions and Answers,Smoke BarrierBKeyes @ 12:00 am
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Q: Are smoke barrier doors and frames required to have a fire rating label?

A: No. This seems to be a difficult issue for many people (including surveyors) to grasp. According to section 19.3.7.6 of the 2012 LSC, doors in smoke barriers are required to be 1¾ inch thick, solid-bonded, wood-core doors, or be of construction that resists fire for at least 20 minutes. This does not mean the door and frame must be a fire-rated door. It only means the door must be of construction that resists fire for at least 20 minutes.

The confusion surrounding this issue may be found in section 8.3.4.2 of the 2012 LSC, which says doors in smoke barriers must have a fire rating of not less than 20 minutes. But whenever there is a conflict between the core chapters (chapters 1 – 11) and the occupancy chapters (chapters 12 – 42), the requirements of the occupancy chapter over-rides the requirements of the core chapter (see section 4.4.2.3). In other words; the occupancy chapter trumps the core chapters.

Section 19.3.7.8 of the 2012 LSC continues to say that doors in smoke barriers are not required to be positive latching That alone should be the tell-tale sign that the door is not required to be a fire-rated door since all fire rated doors must be positive latching (according to NFPA 80).

Some architects do specify 20-minute fire rated doors in smoke barriers, and while this practice is not a violation of the LSC, it does present a burden on the healthcare facility because now they have to maintain it as a fire rated door, even though it is not required to be a fire rated door. This causes more headaches because the 2012 LSC references the 2010 edition of NFPA 80 which will require an annual inspection of all side-hinged swinging fire doors.


Aug 23 2017

Are Smoke Barrier Doors Required to be Inspected in Hospitals?

Category: Doors,Questions and Answers,Smoke Barrier,TestingBKeyes @ 12:00 am
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Q: Do doors in smoke barriers in healthcare occupancies have to be tested and inspected? Section 7.2.1.15.2 of the 2012 Life Safety Code says smoke door assemblies have to be inspected and tested in accordance with NFPA 105.

A: Well, the answer is no… Smoke barrier doors that are non-rated are not required to be inspected annually in healthcare occupancies, even though 7.2.1.15.2 says they do. Here’s why:

  • Section 19.3.7.8 says doors in smoke barriers shall comply with 8.5.4 and all of the following: 1) Doors shall be self-closing; 2) Latching hardware is not required; and 3) The doors do not have to swing in direction of travel.
  • Section 8.5.4.2 says where required by chapters 11 through 43, doors in smoke barriers that are required to be smoke leakage-rated shall comply with section 8.2.2.4. [NOTE: Chapters 18 & 19 for healthcare occupancies do not require smoke leakage-rated doors in smoke barriers…. Therefore, compliance with section 8.2.2.4 is not required.]
  • Section 8.2.2.4(4) says where door assemblies are required elsewhere in the Code to be smoke leakage-rated, door assemblies shall be inspected in accordance with 7.2.1.15.

CONCLUSION: Since the healthcare occupancy chapters do not require smoke barrier doors to be smoke leakage-rated, then there is no requirement to be compliant with 7.2.1.15.2 that says the smoke doors need to be inspected.

Section 4.4.2.3 says where specific requirements contained in chapters 11 through 43 differ from general requirements contained in chapters 1 through 4 and from chapter 6 through 10, then the requirements of chapters 11 through 43 govern. Since the healthcare chapters do not require smoke barrier doors to be smoke leakage-rated, then it conflicts with section 7.2.1.1.5.2, and when that happens, you follow the occupancy chapter requirements.

The problem is… not all authorities having jurisdictions (AHJs) knew this or understood this. Case in point: The Centers for Medicare & Medicaid Services (CMS) had instructed their state agency Life Safety surveyors that all smoke doors in healthcare occupancies need to be tested and inspected, citing section 7.2.1.15.2.

In addition, CMS also taught their LS surveyors that doors in healthcare occupancies that meet the requirements of 7.2.1.15.1 have to be tested as well, which is not entirely true. These doors identified in 7.2.1.15.1 only have to be tested in assembly occupancies, educational occupancies, or residential board & care occupancies. The exception is, some hospitals have mixed occupancies that include the requirements for assembly occupancies, so in those cases, yes, the doors in 7.2.1.15.1 would have to be tested and inspected on an annual basis.

But on July 28, 2017, CMS issued S&C memo 17-38 which corrected this error. In this memo, CMS says smoke barrier doors do not have to be tested in healthcare occupancies. So, they saw an inconsistency with the 2012 Life Safety Code, and corrected their position. They even admitted some confusion on their part regarding door testing in general and decided to extend the date that the first fire door test is due from July 5, 2017 to January 1, 2018. But be careful with that: Not all AHJs are moving the date that the first fire door test is required.

You can expect a similar announcement from Joint Commission, if it hasn’t happened already. I’ve been told they will changed their standards to reflect what CMS has said.