Two Releasing Devices for Doors

Q: I heard in a webinar that under the 2012 edition of the Life Safety Code, I can you have two releasing devices on doors. Is this true?

A: Yes, it is true, but only in very limited situations is it permitted. A new section ( of the 2012 Life Safety Code allows two releasing operations to be permitted for existing hardware on a door serving an occupant load not exceeding three persons, provided the releasing mechanisms do not require simultaneous operations. This only applies to existing conditions, and does not allow you to install deadbolt locks on doors that only serve three people. Existing means the second releasing device (i.e. deadbolt lock) was on the door prior to July 5, 2016.

Closers on Doors to CT Scan

Q: Do entrance doors to x-ray rooms and CT scanner rooms have to be controlled by door closers?

A: According to the Life Safety Code, they only need closers if they are considered to be hazardous rooms (normally not) or if the door in question is also part of the smoke compartment barrier wall. However, other codes and standards may apply. Be sure to check with your state and local authorities.

Round Door Knobs

Q: Our hospital has round door knobs to latch cross corridor smoke doors. I am thinking this is not okay. Does the Life Safety Code address this?

A: Other than section of the 2012 LSC that requires panic hardware on egress doors (or fire-exit hardware on fire rated doors) in Assembly occupancies (or mixed occupancies that include Assembly occupancy areas) that serve 100 or more persons, there is nothing in the Life Safety Code or NFPA 80 that prevents the use of round door knobs on doors that you describe.

However, round door knobs could present a safety risk for ligature if they were located in an area where behavioral health patients are located. This risk would have to be addressed in a risk assessment and mitigation activities implemented. But the LSC does not prohibit them.

Lower Bottom Rods

Q: I have been asked about the requirements for the use of the lower bottom rod hardware in cross-corridor egress doors which provide positive latching and building separation. For aesthetic reasons, we wish to remove the bottom flush bolts, allowing for the floor to be void of the ‘ugly’ recessed catch. Is it required by code to have the lower bottom rod, or is this more of a question for the hardware manufacturer?

A: The lower bottom rod latching system is there because the manufacturer of the door hardware says it has to be there; not because there is a code or standard that requires it. It’s there because the manufacturer received a UL listing (or other independent laboratory listing) saying that is how they secure the door during a fire.

If it is a fire-rated door, then according to section of the 2012 Life Safety Code, you are required to maintain the door to be in compliance with NFPA 80, which requires the fully compliment of hardware that the manufacturer says is required.

Some door hardware manufacturers have been able to obtain UL listings without having the lower bottom rod, and that is entirely an issue between the manufacturer and the testing laboratory. Some door hardware manufacturers have been able to obtain a listing to remove the lower bottom rod and replace it with a fire-pin… a fusible link mounted inside the door that secures the door during a fire.

Work with the manufacturer of the door hardware. Do what they say is required in order to maintain the fire rating of the door assembly. A missing lower bottom rod is likely to be observed during a survey and if you have documented proof from the door hardware manufacturer that the lower bottom rod is not required then you should be safe.

Egress Hardware

Q: We have “clinic” type areas within suites.  Some of these doors that lead to the main corridor for egress, have regular “turn handle” type handles.  Not panic hardware.  What is the mindset of where it is required to have panic hardware on a door, and when turn handles are permitted?  Is there a “rule of thumb” on when a door has to have panic hardware for egress?

A: Horizontal egress hardware on a door (commonly referred to as crash bars and often misnamed panic hardware) are not required in a healthcare occupancy. Crash bars are required on doors in the path of egress from assembly occupancies. So, if a hospital has a dining area or an auditorium; these are assembly occupancies areas, and horizontal crash bars would be required even if the entire area is classified as healthcare occupancy. Section of the 2012 Life Safety Code requires where there is a mixed occupancy (meaning the different occupancies are not separated with a 2-hour fire rated barrier), then the more restrictive requirements of the occupancies involved must be followed. Therefore, since an auditorium and a dining area (50 or more people) exist inside a hospital, then the requirements of assembly occupancy must be followed. Horizontal crash bars would then be required.

But there is no requirement for horizontal crash bar hardware on egress doors from a hospital suite as you described.

Lower Bottom Rods

Q: I am a consultant and I am surveying a system where the bottom strike rod and the floor receiver have been removed.  I think this “field” modification may void the UL rating.  Is there a reference for clarification on this?

A: You’re not going to find a section in any NFPA code or standard that says “There must be a lower bottom rod on fire rated doors”. But, nonetheless, they are required when the manufacturer says they are required. The manufacturer of fire rated door assemblies have to have them listed by on independent testing laboratory, such as UL or ETL (Intertek). The manufacturer submits their fire door assembly for testing and if it passes the test, then the testing laboratory will list it as meeting the required standards based on the total assembly, including the hardware.

For decades certain types of cross-corridor fire rated door assemblies were designed with surface mounted hardware that included the lower bottom rod for latching. And for decades, hospital employees hit that lower bottom rod with carts and instead of repairing the rod, the poorly-informed maintenance staff would just remove the rod. Along comes better-informed surveyors who identifies that this is not correct and cites the hospitals.

Recently, some door manufacturers are actually designing cross-corridor fire-rated doors with surface hardware that eliminates the lower bottom rod all-together. This design was tested and listed by the testing laboratories. Some of these designs have employed devices what are commonly called ‘fire-pins’ in the lower part of the door that releases a pin from one door leaf to the other door leaf to ‘lock’ it in place when the ambient temperature at the floor approached 500 degrees (or so).

As you come across fire-rated doors that have surface mounted hardware but no lower bottom rods, I suggest you do the following:

  • Check the horizontal crash bar hardware and confirm if there is an opening on the underside of housing for a lower bottom rod. If not, then check the independent testing laboratory label on the horizontal crash bar assembly to confirm that it is listed for use as fire-rated hardware.
  • If there is an opening on the underside of the housing, then check to see if there is a fire-pin installed on one of the door leafs.
  • If there is no fire-pin installed, then ask the organization to provide you with documentation that the door assembly as presented meets the requirements for the UL (or ETL) listing. If they can provide that information, then review it and determine that the remaining hardware is installed as designed.
  • If they cannot provide that information, then cite them for non-compliant modifications to a fire-rated doors assembly.