Fire Pins

Q: I had a company put in the fire plugs on the doors to replace the lower bottom rods. Was this okay? They say that the plugs have a thermal-pin that will secure the door in case there was a fire.

A: You must be referring to fire pins… I cannot say if this is okay or not. That is up to the manufacturer of the fire doors. You are not allowed to modify a fire-rated door assembly other than what the manufacturer permits. If you haven’t already done so, contact the manufacturer of the door and ask them if fire pins are permitted to be installed in their door in lieu of the lower bottom rod after the door is installed.

The manufacturer achieves a listing from an independent testing laboratory for the fire-rating of their door assembly. If you modify that door assembly beyond what was tested and listed by the testing laboratory, then you have violated the listing of the door and the entire door assembly would need to be replaced.

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.

 

Marked Fire/Smoke Doors

Q: We are reviewing fire policy, and are wondering if it is a Life Safety Code requirement to have fire and smoke barrier doors labeled as such? By this I mean a sign or sticker on the face of the door stating: “smoke barrier” or “fire barrier”?

A: No… there is no Life Safety Code requirement to post signage on smoke barrier doors or fire-rated door assemblies, identifying them as such. I do not see any CMS or Accreditation Organization requirement to do so, either. However, it’s not a bad idea as long as the signage meets the limitation of NFPA 80 for fire-rated door assemblies. I have seen hospitals identify their smoke barrier doors, that helps their staff be aware of the smoke compartment locations. I think that works well for many organizations. Please check with your state and local authorities to determine if they have any requirements.

 

Strange Observations – Signs on Fire-Rated Doors

Continuing in a series of strange things that I have seen while consulting at hospitals…

Doors to medical gas storage rooms are required to be fire-rated.

Fire-rated doors cannot have signs applied that cover more than 5% of the total surface of the door.

A sign that does not exceed 5% surface of the fire-rated door is approximately 8.5″ x 11″. This door has signs that exceed the 5% surface amount.

Also, the signs cannot be attached to the door using screws or nails, but must use adhesive.

Home-Made Bumpers on Doors

Q: We have metal “bumpers” (for lack of a better term) that were fabricated onsite at our hospital, that are used to keep carts and beds for damaging the doors. These bumpers are installed on fire-rated door assemblies and protrude out past the push pad of the horizontal crash bar on the door. Are these bumpers allowed?

A: No… According to NFPA 80- 2010, section 4.6.1, all devices mounted to a fire-rated door assembly must be listed by an independent laboratory (i.e. UL, Intertek, FM Approval) for use on a fire-rated door assembly. Home-made devices are not permitted. Also, the bumpers may stick out more than the maximum 7 inches allowed by section 7.2.1.4.3.1 of the 2012 LSC, when the door is fully opened.

Fire Pins

Q: I have a concern regarding the use of fire pins in fire rated door leaves: Since the latching feature of these devices is not testable (that I’m aware of, anyway), and as these doors are prone to abuse and sometimes require adjustment for clearance issues and so forth, how do we ensure the alignment of the fire pin assembly when adjustments are made or even during normal expansion/contraction due to temperature/humidity changes?

(The reply for this question comes from Lori Greene, Manager of Codes & Resources at Allegion. Visit Lori’s website on doors and hardware at www.idighardware.com)

 A: You’re right – there’s no way to test the pin.  But the pin and the hole that it will project into (typically filled with a plastic cap) should be visible on the door edge so you can ensure that they’re aligned.  On most pins there is a fair amount of tolerance so the alignment doesn’t have to be perfect.  Since the pins operate only when there’s a fire, and only when the temperature reaches >1000 degrees in the vicinity of the door (approx. 450 degrees at the pin), only a very small percentage of the pins will ever be activated.  The pin doesn’t have much of an impact on life safety – by the time the pin projects, it’s mostly about compartmentalizing the building and protecting property.

Aluminum Astragals

Q: We used our recently updated Life Safety drawings to have our fire doors inspected. The inspector cited us for aluminum astragals on 13 doors. His report stated that they should be changed to steel. My boss asked me to confirm that this is fact. What are your thoughts?

A: The inspector may know something… All hardware installed on fire-rated door assemblies must be listed for use on fire-rated door assemblies, and this includes astragals. Do you have the specification sheets for the astragals that you installed? If not, can you obtain them?

Look on the specification sheets for anything that says the astragals are listed by an independent testing laboratory (UL, Intertek, ETL, etc.) for use on fire-rated door assemblies. If you find that they are listed for use on fire-rated door assemblies, then you are good to go. Photo-copy that information and send it to the inspector for his/her review.

If the specification sheets do not say the astragals are listed for use on fire-rated door assemblies, then the inspector is correct and you would have to remove them. The issue is not whether they are made with steel or aluminum, but whether they are listed for use on fire-rated door assemblies. Perhaps the inspector believes that aluminum astragals are not listed…?

Fire Rated Door in a Non-Rated Barrier

Q: If I replace a smoke barrier door with a fire door, does the wall now have to be brought up to fire-rated wall code or will it still be considered the same smoke barrier code? We were told by an inspector that now the wall would have to be a fire-rated wall even though it’s not needed to be.

A: This issue is becoming a sticky wicket. I’ve had this question raised numerous times recently. I kind-of see where the surveyor is coming from: If the fire-rated door assembly is obvious to the public as a fire door, then the public could conclude that the barrier is also a fire-rated barrier. Kind-of makes sense. But that’s not what the Life Safety Code says. It is clear to me that the LSC does require all fire-rated doors to be tested regardless if they are located in a fire-rated barrier or not.

Section 4.6.12.3 says existing features of life safety obvious to the public, if not required by the LSC must be maintained or removed. Most AHJs will say a fire-rated label on the door is obvious to the public, although an unofficial NFPA interpretation is saying a fire rated label is not obvious to the public. In this situation, we have to go by what the AHJ says. Section 8.3.3.1 says fire-rated doors must comply with NFPA 80-2010, so all fire rated doors must be tested and inspected regardless if they are located in a fire-rated barrier.

But there is nothing in this section of the LSC or any other section that clearly says a fire-rated door assembly located in a barrier requires the barrier to be a fire-rated barrier. The AHJ has the right to interpret the Life Safety Code, but in my opinion this interpretation is way over the top. But, if you do get cited for this, it really is an easy solution: Just pop the fire-rated labels off the door.

 

Fire Door Inspection Records

Q: Do fire door inspection records need to be maintained for 3 years?

A: I would say at least 3-years, and longer as needed. NFPA 80-2010 section 5.2.1 says fire door assemblies must be inspected and tested not less than annually, and a written record of the inspection must be signed and kept for inspection by the AHJ. Since your routine accreditation surveys are once every 3-years, and since the purpose of the accreditation survey is to determine compliance with the standards since the last survey, then I would say you need to retain all records at least 3 years so the surveyor can confirm your level of compliance during that 3-year period. Now, it is my position that you should never throw away any document confirming regulatory compliance as you may need it someday, for other AHJs or maybe even litigation purposes. You can purge your files of test reports older than 3 years but make sure you box them up and store them somewhere safe and dry.