Horizontal Sliding Doors

Q: Someone just asked me a question and I haven’t thought about this one before.  This AHJ is enforcing the IBC but I’m looking for an NFPA viewpoint and of course I thought of you.  The IBC and the LSC both require corridor doors in a health care facility to latch.  But what if those doors are horizontal sliding doors (manually-operated)?  The IBC allows horizontal sliding doors if the space served by the door has an occupant load of 10 or less.  The doors in question are not in suites.  I don’t see anything that prevents the use of horizontal sliding doors, or anything that says these doors don’t need to latch, but why should they have to latch since they aren’t affected by pressure the same way a swinging door would be?  It seems like latching hardware on horizontal sliding doors would be a pain for hospital staff. Have you ever run into this?

A: Yes… I see this issue a lot in hospitals. Many architects are mistaken when it comes to glass sliding doors. Perhaps they follow IBC and specify non-latching doors, but then they fail to comply with the 2012 Life Safety Code, which gets them (and the hospital) in hot water.

Section 19.2.2.2.10.2 discusses horizontal sliding doors that serve an occupant load of fewer than 10 people have to meet all of the requirements in the sub-headings 1 – 5. Sub-heading 5 says where corridor doors are required to latch, the doors are equipped with a latch or other mechanism that ensures the door will not rebound into a partially open position if forcefully closed.

So, the LSC is clear: Where corridor doors are required to latch, the horizontal sliding doors must also latch.

Yes… there are a lot of requirements in the LSC that are a pain to staff. But patient safety is a job that all have to work for, regardless how inconvenient it may be.

Power Operated Doors Do Not Have to Latch

Q: I read recently that Joint Commission allows a door with a power operator to not have to positively latch as long as it has 5-lbs. of force keeping it closed. I thought CMS already said that the 5-pound existing door exemption that’s in the Life Safety Code does not apply to CMS facilities.  Is the change that they are now allowing the 5-pound exemption on doors with automatic operators and not requiring positive latching on restroom doors?  Is it common for an automatic door manufacturer to be unable to provide positive latching?

A: I was not aware that there were any door manufacturers that could not provide positive latching hardware on power-operated doors. Apparently, the Joint Commission is aware of at least one manufacturer and made this exception to their standard. But the 2012 LSC does permit this action under 19.3.6.3.7, whereby powered doors that comply with section 7.2.1.9 (sub-section 7.2.1.9.2(5) requires powered doors to latch upon activation of the fire alarm system) are considered compliant provided the door is equipped with a means to keep the door closed that is acceptable to the AHJ, and is capable of keeping the door closed with 5-lbs. of force. But just because Joint Commission permits this (i.e. it is acceptable to them), it does not mean it is acceptable to all other AHJs. Hospitals will be taking a certain risk if they choose to go this route because it may pass a Joint Commission survey but fail a state agency survey.

You are correct in that CMS does not permit the option of a device with 5-lbs. of force to keep an existing corridor door closed, as described under 19.3.6.3.5. They have prohibited this for a few years and communicated that via informal emails to the accreditors, but did not release that information to the public as far as I know.

Certain corridor doors do not require positive latching (i.e. toilet-room doors, shower-room doors, janitor’s closets that do not store combustibles… see 19.3.6.3.6) and therefore they are permitted to have roller latches if they want. CMS and the accreditors are okay with that, although I’m not sure all surveyors fully understand that concept.

Dutch Doors

Q: I have been asked by a clinic manager at one of our primary care clinics to install a door knob on a split Dutch type door that goes into a lab area. They are requesting that the lock set be a double cylinder type where one would have to use a key to enter from the hallway as well as use a key to exit from inside of the room. I have never heard of this before (that doesn’t necessarily mean anything). I have concerns regarding egress safety, should I do this?

A: I advise you to not do this. From what you describe, it sounds to me that there would be multiple violations with this arrangement. First, having a second latch set on the Dutch door would require two actions to operate the door, which is not permitted according to section 7.2.1.5.10.2 of the 2012 LSC.

Second, it sounds like a key would be required to egress the door which is not permitted according to section 19.2.2.2.4. I’m glad you asked, but it sounds like trouble to me if you agree to install this equipment.

Downgrading Fire-Rated Door Assemblies

Q: My boss has hired an outside company that has advised him to rip fire rating labels off of doors and frames that we have maintained properly for decades. We do have automatic sprinklers in all areas. It does not feel appropriate to simply downgrade hazardous rooms, corridors, and elevator lobbies. My boss refuses to contact the AHJ and will only refer to his outside company. Is this appropriate and something I can sign my name too? Thank you for any information.

A: Well… maybe yes and maybe no.

All fire rated doors must be inspected based on 2012 LSC section 4.6.12.3 and 8.3.3.1, regardless if they are located in a fire-rated barrier or not. So, if your facility has a fire-rated door installed in a barrier (i.e. a corridor wall) that is not a fire-rated barrier, then the door assembly still has to be tested and inspected even though it is not located in a fire-rated barrier.

If you have a lot of these situations, then it can be costly to test and inspect fire-rated doors where you don’t have to, so the easy solution is to remove the fire-rating label from the door and frame. If you do that, then you don’t have to test and inspect the doors as they are no longer fire-rated assemblies. But you must be very cautious before you take such action and make doubly-sure that the door assembly is no longer needed to be fire-rated.

But you said something in your question that disturbs me… You said: “It does not feel appropriate to simply downgrade hazardous rooms, corridors, and elevator lobbies.” This statement is very troubling as you are not permitted to downgrade features of life safety that were required at the time of design or construction, unless it is a change with new construction standards. So, here is a possible scenario that may apply to your facility: When your facility was originally constructed, it was required to have all hazardous rooms be 1-hour fire-rated and fully protected with sprinklers. Today, that same room is now considered ‘existing conditions’ by definition since the 2012 LSC was adopted in July 5, 2016, and your facility was constructed prior to that date. According to the 2012 LSC, existing conditions hazardous rooms are permitted to be 1-hour fire-rated or sprinklered; not both. But section 4.6.12.2 of the 2012 LSC says no existing life safety feature shall be removed or reduced where such feature is a requirement for new construction. The 2012 LSC still requires sprinklers and 1-hour fire rated hazardous rooms, so you are not permitted to down-grade the fire-rated doors to a hazardous room just because it now qualifies as existing conditions.

You have every reason to be questioning this strategy. I suggest you and your boss contact your AHJs for guidance, or at least get some decent advice from a consultant. This outside company that you refer to… are they a qualified Life Safety company to be offering advice like this?

Some AHJs will not allow any down-grading of fire-rated door assemblies even if the doors are not required to be fire-rated, so make sure you check with them before removing any labels.

Lower Bottom Rods

Q: My department is assisting with a fire/smoke barrier door assessment. I have noticed that some of the ¾-hour corridor doors have had the lower bottom rods removed from the latching hardware with cups still visible in the floor. It is unclear why they were removed however the top latches still work and secure the door. There are small screw holes in the door as well where the hardware was removed. My thoughts are the door has been modified and no longer compliant. What are your thoughts?

 A: You are absolutely correct… By your description, the lower bottom rods were required when the door was installed, but have since been removed (They do get hit and bent by carts and are simply removed rather than replaced by poorly informed maintenance staff.) This door no longer meets the UL listing it received by the manufacturer when it was installed, and should be flagged as not passing an annual inspection.

Lower Bottom Rod Latching

Q: My question is regarding a 2-hour fire-rated wall that is separating our physical therapy department and the main hospital. In between the two is a long glass hallway with a dual egress 90-minute fire-rated door. The doors are top latching. I have had an environment of care consultant say that the door has to be top and bottom latching. Their reasoning is because it separates two occupancies. But both occupancies are owned by the hospital, and are not separate entities. Does the dual egress door have to be top and bottom latching?

A: Maybe yes and maybe no… The requirement for a lower bottom rod is dependent on the door assembly manufacturer’s UL listing when they had the door tested. It is not a NFPA standard that all doors have to have a lower bottom rod, but rather it is driven by the manufacturer’s hardware listing from UL.

I have not seen the door assembly but your consultant has. If there is evidence that the lower bottom rod on the fire-rated door assembly was originally installed and now it has been removed, then yes you need to re-install it and have a top and bottom latching connection. This is not uncommon after a few years when the lower bottom rod becomes damaged, and the hospital maintenance just removes it since it latches at the top. If that is the situation for you, then that would be a non-compliant situation.

In some cases, the door manufacturer provides a ‘Fire Pin’ in lieu of the lower bottom rod, which is spring-activated to shoot a pin horizontally from one leaf to the other to hold the door closed during a fire. These ‘Fire Pins’ do not operate until the temperature at the floor reaches 450°F or thereabouts, so there is no chance of the pin activating prior to anyone wanting to use the doors.

Then I’ve been told there are a few door manufacturer’s that have passed the UL testing whereby they are only required to have a latching device at the top of the door, and not at the bottom of the door. I’ve never seen one, but I’ve been told they are out there.

I suggest you contact the distributer of the door in question and ask them what hardware is required in order to maintain the fire-rating from UL. Then maintain that documentation for future reference during a survey.

Corridor Doors Have to Be Fire-Rated?

Q: We have an engineer who is telling us that the 2012 Life Safety Code requires our corridor doors to be fire-rated. He is referencing Table 8.3.4.2 which says exit-access corridor walls that are either 1-hour rated or ½-hour rated require a 20-minute fire-rate door. He says the healthcare occupancy chapter sections 19.3.6.2.4 and 19.3.6.3.2 support this as well. Is this true?

A: Well… it appears your engineer is reading the Life Safety Code wrong. When you want to learn what the Life Safety Code requires pertaining to any subject, you start with the occupancy chapter first, not the core chapters (chapters 1 – 11). Section 19.3.6.3.2 of the 2012 LSC says corridor walls in healthcare occupancies are ½-hour fire-rated and extend from the floor to the deck above. However, in smoke compartments that are protected throughout with approved sprinklers, the corridor walls are permitted to be non-fire-rated, but only resist the passage of smoke and extend from the floor to the ceiling provided the ceiling also resists the passage of smoke.

And according to section 19.3.6.3, doors in corridor walls in healthcare occupancies are only required to resist the passage of smoke, be 1¾-inches thick, solid bonded, wood core, or made of materials that resists fire for a minimum of 20 minutes. This does not mean the door has to be 20-minute rated… just constructed to resist fire for a minimum of 20-minutes.

According to section 4.4.2.3, whenever there is a conflict between the occupancy chapters and the core chapters, the information in the occupancy chapter governs. The information your engineer saw in Table 8.3.4.2 is general information and applies to all occupancies. However, the existing healthcare occupancy chapter differs with information in Table 8.3.4.2, which means the information in the occupancy chapter governs.

I don’t see what you are referring to regarding 19.3.6.3.2. It does not say doors have to be 20-minute rated. It says doors do not have to be 1¾-inches thick, solid bonded, wood core, and resists fire for 20-minutes for certain areas such as toilets rooms, bathrooms, and shower rooms. It is giving you a break for being an existing healthcare occupancy. In some very old hospitals, they installed doors that were not 1¾-inches thick, and this section is permitting them to remain.

And section 19.3.6.2.4 is stating what I’ve already mentioned: Corridor walls in smoke compartments that are fully protected with sprinklers are permitted to be non-fire-rated smoke resistant partitions that extend from the floor to the ceiling, provided the ceiling also resists the passage of smoke.

Fire-Rated Doors in Fire-Rated Barriers?

Q: If the health care facility is fully sprinklered do doors in a corridor, where the walls are fire rated, do the doors have to be fire rated? I read in NFPA 101 that they do not….

A: Where do you read that…? I would like to know what you’re reading to be able to provide you with a better answer.

Generally speaking, where you have a fire-rated barrier, you usually need to have fire-rated doors in openings in the fire-rated barriers. But there are some exceptions:

  • Fire-rated barriers that separate an atrium from the rest of the facility are not required to have fire-rated doors.
  • Corridor walls in existing healthcare occupancies located in a smoke compartment that is not fully sprinklered, are required to be 30-minute fire-rated and the corridor doors are permitted to be non-fire-rated, but must limit the passage of smoke.
  • Some building codes that require fire-rated corridor walls do not require fire-rated doors in the openings. But this is not a LSC issue.
  • Smoke barriers that separate smoke compartments are required to be rated (1-hour for new construction) but doors in smoke barriers are not required to be fire-rated.

 

Door Lever Hardware

Q: Is there a Life Safety Code requirement for door lever hardware to have a return, so as to not “hook” passing clothing, straps, purses during emergency evacuations? I swear I remember this for healthcare occupancies from somewhere, but can no longer find it in the Life Safety Code.

A: No, the 2012 Life Safety Code does not require a return on door lever handles to prevent hooking clothing during egress. But my good friend Lori Greene (www.idighardware.com) tells me the return is only required by the California Referenced Standards Code, which says: Levers.  The lever of lever-actuated levers or locks shall be curved with a return to within 1/2″ of the face of the door to prevent catching on the clothing of persons during egress. Since this is not a requirement of the NFPA or ICC codes or standards, it would only apply in California.

Closet Doors

Q: Are closet doors located inside a corridor considered corridor doors and do they have to meet life and safety codes referring to corridor doors?

A: It depends…. What does your Life Safety drawings say?

Section 19.3.6.3 of the 2012 LSC requires doors in the corridor to be positive latching. If the closet door is in the corridor wall then it must be positive latching. However, there may be a possibility that the corridor wall could run behind the closet, provided the back of the closet wall meets the requirements of 19.3.6.2 for construction of corridor walls.

But your Life Safety drawings need to specifically identify that the corridor wall runs behind the closet. If they do not, then the surveyor has no choice but to hold your closet doors compliant to 19.3.6.3 for positive latching corridor doors.