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 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 requires it to comply with NFPA 80 which requires positive latching; but also 2) Because corridor doors are required to latch, according to section However, all of the other NFPA 80 requirements concerning fire rated doors (i.e. self-closing door and fire rated frames) applies since section 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/

In regards to public restroom doors: According to section, 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.