Q: Are fire dampers required in 1-hour fire rated walls if the facility is fully sprinkled? Also, we have a couple of inaccessible dampers and I was wondering if I needed to add them on the Statement of Conditions PFI list?
A: According to NFPA 90A (1999 edition), 1-hour fire rated barriers do not require fire dampers in fully ducted HVAC systems, unless the 1-hour fire rated barrier is a vertical shaft. If the air duct is an air transfer opening (meaning it is not fully ducted) at the fire rated barrier, then the duct needs a fire damper where other openings are required to be protected as well. However, 2-hour fire rated barriers do require fire dampers in fully ducted HVAC systems. Being fully sprinklered, or not, has no bearing on the requirement whether fire dampers are required. It does have a bearing on whether or not smoke dampers are needed, though.
Inaccessible fire dampers are a life safety code deficiency, and must be addressed by the following:
- The inaccessible fire dampers must be assessed for Interim Life Safety Measures (ILSM)
- A decision must be made as to whether or not you will make the fire dampers accessible, and therefore be able to test them
- If you cannot resolve the inaccessible fire dampers within 45 days of discovery, they must be placed on the PFI list of the Statement of Conditions.
- If you decide you will not resolve the inaccessible fire dampers, then the projected completion date for the PFI may be set at 6-years. After 6 years, re-examine the inaccessible fire damper to determine if the environment has changed, and if they are still inaccessible, then close out the PFI, and open a new one for another 6-year cycle.
Joint Commission surveyors are very astute to identifying inaccessible fire dampers, and whether or not you placed them on the PFI list, and whether or not you assessed them for ILSMs. So, make sure you assess them for ILSMs, and place them on the PFI list.