Duct Detectors

Q: With regard to testing duct detectors in a hospital, I understand that on an annual basis the automatic shutdown of the AHU’s must be verified when duct detectors are activated. I am unclear if there is also an annual requirement to verify damper (pneumatic and/or electric type but excluding fused links) operation at the same time. Also, is there a requirement to test smoke dampers annually?

A: No… there is not. Even though NFPA 72-2010 does require confirmation of all interface relays tested on an annual basis, and does imply that actuation of the dampers are required, NFPA 72-2010 cannot regulate the testing of fire or smoke dampers. Only NFPA 80-2010 and NFPA 105-2010 can regulate testing requirements for fire and smoke dampers respectfully.

You still have to test the interface relays (modules) on an annual basis, but you are not required to confirm that the smoke dampers did close on an annual basis.

But be aware, that some surveyors may require that you do confirm the smoke dampers closed on an annual interface relay test… That would be an incorrect interpretation on their part, and you may want to point out that NFPA 4 was created (in part) to eliminate these conflicting cross-testing requirements.

Smoke Dampers in Smoke Partitions?

Q: When comparing smoke dampers in smoke barriers vs smoke partitions, section requires smoke dampers (with exemptions) for penetrations by ducts or air-transfer openings in a smoke barrier. Section (smoke dampers in smoke partitions) only indicates air-transfer openings as required to have smoke dampers, with no mention of ducted openings, which we interpret to mean that ducted openings in a smoke partition do not require smoke dampers. However, we have been repeatedly told by mechanical engineers that smoke dampers are required for all ducts, transfer ducts, and air-transfer openings that pass through a smoke partition – which interpretation is correct?

A: It appears to me that your mechanical engineers are confusing smoke partitions with smoke barriers. To be sure, air-transfer openings are prohibited in corridor walls (which are smoke partitions) in healthcare occupancies, according to section of the 2012 LSC. Also, section (2) exempts smoke dampers in fully-ducted penetrations in smoke barriers, where the smoke compartments served by the smoke barriers are fully protected with Quick Response sprinklers. I do not see where smoke dampers are required in HVAC ductwork in smoke partitions.

Smoke Dampers in Corridor Walls?

Q: In regards to suite separations, section of 2012 LSC requires walls separating suites to meet requirements for corridor walls, which have to be constructed to limit transfer of smoke. There don’t seem to be any requirements for smoke dampers in air transfer openings or duct penetrations through corridor walls – is this correct?

A: Well… you’re sort of correct. Corridor walls in fully sprinklered smoke compartments are required to be smoke partitions… not smoke barriers. The 2012 Life Safety Code does not require smoke dampers in HVAC ductwork that penetrate smoke partitions. But section 18/ prohibits the use of air-transfer openings in corridor walls.

Smoke Dampers

imagesW9BNC02CWhat do we do with smoke dampers now that the hospital is fully protected with sprinklers? That question is asked many times by facility managers who are looking to cut back on what they believe are unnecessary maintenance costs. For new construction purposes, chapter 18 in the Life Safety Code does not require the installation of smoke dampers in smoke compartment barriers provided the HVAC ductwork that penetrates the smoke compartment barrier is fully ducted (no open return air plenum ceilings), and both smoke compartments served by the smoke compartment barrier are fully protected with quick-response automatic sprinklers. But sprinklers were not always required for healthcare occupancies and only became a rule for new construction in the 1991 edition of the LSC.

Until then, sprinklers were an option (unless state or local laws required it, and the construction type required it), and not all hospitals choose to invest in the systems when the building was constructed. That means smoke dampers had to be installed in the smoke compartment barriers. After the facility became fully protected with sprinklers, many hospitals believed they could remove the smoke dampers (or disable them in place), since new construction specifications did not require the smoke dampers. Section 4.6.7 of the 2000 LSC says whenever alterations or renovations are made, the requirements of new construction must apply. Since new construction (chapter 18) requirements for hospitals did not require smoke dampers where both smoke compartments are protected with sprinklers, facility managers thought they had good ground to stand on.

While this may be acceptable for NFPA, it is not for the International Code Council which publishes the International Building Code (IBC). The organization needs to request permission from their local and state authorities before they remove them. Usually, permission will not be granted because the IBC does not recognize the removal of existing fire safety equipment. I’ve also been told that in those jurisdictions where the smoke dampers were installed prior to the adoption of the IBC, there is a chance that the authorities may permit it.

Bottom line… Don’t be in a hurry to remove the smoke dampers even if you believe they are no longer required. Check with the state and local AHJs and seek their permission. It will save you a lot of work of re-installing them if you don’t ask for permission, and they find out later.

PFIs on Inaccessible Fire Dampers


There seems to be much discussion lately on how to manage the Joint Commission Statement of Conditions Plans For Improvement (PFI) on inaccessible dampers. Joint Commission has instructed healthcare organizations to write a PFI for inaccessible fire or smoke dampers, and place a projected completion date of 6 years on them.

I have been telling my clients to close the PFI out at the end of the 6-year cycle; examine the fire dampers again to see if anything has changed that now allows them to be accessible (and then test them); and if they are still inaccessible, write up a new PFI with a new 6-year projected completion date. I vaguely remember that Joint Commission initially wanted hospital to request another 6-year extension on PFIs for inaccessible fire dampers, but I think they soon realized their error as they would be over-whelmed with extension requests. Also, they typically only allow one extension per PFI, so after the first 12 years, would they grant another extension? I also remember them saying to just close out the PFI and write a new one.

I don’t have a copy of the 2007 EOC article on the PFIs for inaccessible fire dampers, but 7-year old information seems a bit old for me to trust. People and organizations change their mind in 7-years. If anyone has any doubt, they should contact the Standards Interpretation Group at Joint Commission directly and ask them. Their number is (630) 792-5900, select option 6.


Air-Handler Smoke Dampers

Q: What is the amount of air delivery (in CFM) that an air handler needs to have before it is required to have a smoke damper on the discharge of the air-handler?

 A: Section of the 2000 edition of the Life Safety Code requires compliance with section 9.2 concerning utilities. Section 9.2.1 requires compliance with NFPA 90A Standard for the Installation of Air-Conditioning and Ventilation Systems (1999 edition) for all air-conditioning, heating and ventilation equipment.  NFPA 90A section 2-3.9.2 says smoke dampers must be installed in (air handler) systems with a capacity greater than 15,000 cubic feet per minute (CFM) to isolate the air-handling equipment, including filters, from the remainder of the system in order to restrict the circulation of smoke. However, there are some exceptions to this requirement that you may qualify for:

  • Where the air-handling unit is located on the floor that it serves and serves only that floor, and;
  • Where the air-handling unit is located on the roof and serves only the floor immediately below the roof, then smoke dampers are not required on the air-handling equipment.

It is recommended that you contact your state and local authorities to determine if they have other requirements that you must follow.

Smoke Dampers: Part 2- Can I remove smoke dampers that are not required by the LSC?

[This week’s Q&A came from the 49th Annual Conference and Exhibition of the American Society for Healthcare Engineering (ASHE), held in San Antonio, TX, last July, and how it applies to life safety compliance. A plenary panel consisting of 5 industry experts answered key questions from the members. This question on smoke dampers was answered by Bill Koffel, President of Koffel Associates, Inc., and Frank Van Overmeiren, President of FP&C Consultants, Inc.]

Q: After my building has passed the final inspection with the building department, can I take those smoke dampers which are not required by the LSC out of service?

A: It depends. If the building code requires it, you need to comply with the building code and you can’t diminish the protection feature from the building code. If it is not required by the building code and it is not required by the LSC for new construction, then it would be permitted to be taken out of service.

Once you have determined that the damper can be removed, you can secure the damper in the open position. You can leave it in place, but you need to do some sort of documentation on your fire and smoke damper drawings to indicate that it has been affixed in the open position and taken out of service.

Smoke Dampers: Part 1- Where are they required to be installed?

[This week’s Q&A came from the 49th Annual Conference and Exhibition of the American Society for Healthcare Engineering (ASHE), held in San Antonio, TX, last July, and how it applies to life safety compliance. A plenary panel consisting of 5 industry experts answered key questions from the members. This question on smoke dampers was answered by Bill Koffel, President of Koffel Associates, Inc., and Frank Van Overmeiren, President of FP&C Consultants, Inc.]

Q: Where are smoke dampers required to be installed in a hospital?

A: The issue with smoke dampers results in the differences between the International Building Code (IBC) requirements and the Life Safety Code (LSC) requirements. For example, the LSC allows us to omit smoke dampers in duct penetrations of many smoke barriers in buildings protected with a sprinkler system with quick response sprinklers on both sides of the smoke barrier. That exception is not in the IBC and it is one of the issues the ASHE-IBC ad hoc committee is working on at this time. Also the IBC requires smoke dampers at duct penetrations of shafts so there are more smoke damper requirements in the IBC than the LSC.

There are also some folks who recall some previous building code requirements for smoke dampers where dampers were required in all duct penetrations of corridor walls. And some design professionals will require them in their documents.