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.

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.

Positive Latching Doors

Q: Is positive latching required for any fire rated door in any occupancy classification? If so, are there any exceptions? What about double egress corridor doors; are they required to be positive latching? Are doors to restrooms required to be positive latching?

A: Yes, fire rated doors are required to positively latch no matter where they are installed, according to section 8.3.3.1 of the 2012 Life Safety Code. This section requires all fire rated doors to be compliant with NFPA 80, which requires positive latching hardware. This is a requirement for all occupancies, and is not specific to any one occupancy. There are no exceptions as far as I know: If the door is a fire rated door assembly then it needs to positively latch.

This raises the awareness about barriers that do not require fire rated doors. It is not uncommon for an architect to require all doors in a corridor to be 20-minute fire rated doors, even if the corridor walls are not fire rated. In situations like this, the doors would be required to be positive latching from two different code references: 1) Because the door is a fire rated door and section 8.3.3.1 requires it to comply with NFPA 80 which requires positive latching; but also 2) Because corridor doors are required to latch, according to section 18.3.6.3.5. However, all of the other NFPA 80 requirements concerning fire rated doors (i.e. self-closing door and fire rated frames) applies since section 4.6.12.3 requires features of life safety that are obvious to the public to be maintained even if they are not required.

If the double egress corridor doors are required to be fire rated, then they too must positively latch. But not all double egress doors in a corridor are required to be fire rated. Double egress doors that serve a smoke compartment barrier are not required to latch, according to section 18/19.3.7.8.

In regards to public restroom doors: According to section 19.3.6.3.6, exception #1, these doors are not required to latch, provided they are not fire-rated doors. It is quite rare to find an entrance door to a restroom that is fire rated.