Do fire and smoke rated doors require smoke gasketing in healthcare occupancies which are classified as Group I-2 under the International Building Code® (IBC)?
Ask The Code Weenie!
While NFPA 80 nor NFPA 105 specifically state fire doors and smoke doors require smoke gasketing, the key is to check the applicable code or standard, (i.e., International Building Code), for a limitation on air infiltration, typically a reference to UL 1784, Air Leakage Tests of Door Assemblies, as the test standard, and this would only be required on doors contained within a smoke barrier not part of a cross-corridor assembly. For fire doors and smoke doors in certain locations, the limit for air infiltration is 3 cfm per square foot or less as tested at a pressure of 0.10 inch of water (0.02 m3/(s · m2) or less as tested at a pressure of 0.02 kPa)—for most door sizes, this cannot be achieved without smoke gasketing. The requirements for smoke doors and fire doors depend on where they are used. As such, IBC only requires fire rated smoke barrier doors to meet UL 1784. This results in the effect that life safety surveys involving the use of NFPA 101, 2012 cannot technically mandate the installation of smoke gasketing either for existing or new construction involving smoke barrier doors.
The same would not hold true for fire prevention inspections conducted under the International Fire Codeâ for facilities constructed to meet either the IBC or the legacy Uniform Building Code (UBC) – previously adopted throughout Western Pacific regions of the US. What strategy should facility managers take about existing fire doors where edge sealing is not equipped on fire doors in their facility? Like so many things in code compliance, the answer depends on the specifics of your individual facility. If you need any assistance in understanding this parameter for your facility, AEGIS has fire protection specialists here to help you with code consulting services and inspection services that can help maintain compliance with fire door strategies. What about smoke barrier doors – do the codes say I need to install gasketing on these doors? This question will be answered in our next article of this series.
BUYER BEWARE! We recently found this example of incorrect field labeling as shown in the photos. In the second photo you can see that the accredited company added their own label specifying the rating of the door right below the original label. The original label is still clearly visible and says that the door has a 3/4 hour or 45 minute rating. See the issue with the incorrect field label? The accredited company labeled the door as having a 90 minute rating even though the original label is marked as a 45 minute door. The original label is by UL. UL is one of the 19 Nationally Recognized Testing Laboratories. A testing laboratory is a company that actually performs the fire tests and they are the experts on fire rated manufacturing. Follow this link for a complete list of NRTLs. The accredited company has created its own label which is not backed by a testing laboratory.
The correct process for field labeling a door includes:
Before field labeling the door, frame or hardware the original specifications must be verified & documented.
A fire door can’t be rated higher than the wall rating.
The door, hardware and frame are installed per NFPA 80.
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There is often confusion encircling this question with facility managers, designers as well as even fire door inspectors. To what is often perceived as ambiguity in the codes related to this subject, this item is routinely missed during design and construction, which often leads to further confusion during the life cycle of the building that a facility manager also faces. The question is multi-faceted as there is various criterion to consider.
Through a series of questions answered, we intend to discuss 3 of the more common questions that we have noted in our work with fire and smoke door code compliance. In this series we cover our first question, with the other 2 questions to follow shortly in subsequent discussions.
When is edge sealing specifically required for fire protection rated doors?
Do fire and smoke rated doors require smoke gasketing in healthcare occupancies which are classified as Group I-2 under the International Building Code® (IBC)?
Do corridor doors require smoke gasketing in healthcare occupancies (which are classified as Group I-2 under the International Building Code® (IBC)?
To address the question – when edge sealing is specifically required for fire protection rated door openings, in general the following code excerpt from the model code adopted throughout most of the US – the International Cod Council’s International Building Code:
Edge Sealing for Fire Doors – International Building Code® (IBC), 2012
“716.5.1 Side-hinged or pivoted swinging doors. Fire door assemblies with side-hinged and pivoted swinging doors shall be tested in accordance with NFPA 252 or UL 10C. After 5 minutes into the NFPA 252 test, the neutral pressure level in the furnace shall be established at 40 inches (1016 mm) or less above the sill.”
While the UL 10C test method referenced in this section specifically addresses testing for positive pressure on during burn tests for doors, the NFPA 252 test standard does not. Positive pressure testing, however is still mandated by this section since the IBC section specifically establishes a neutral plane height (first established under UBC 7-2) for testing purposes.
Positive pressure testing is required to more closely mimic real fire conditions -as heat develops within an enclosure, pressure begins to develop within the compartment relative to the pressure outside of the room. The pressure continues to increase until the availability of oxygen relative to fuel load causes the fire to reach equilibrium. The transition between the positive and negative pressure in a compartment is referred to as the neutral pressure plane.
In the positive pressure zone in the upper part of the compartment smoke and hot gases are forced through any openings in the doors assembly. In laboratory furnaces implementing fire door testing, the neutral plane is achieved through controlled venting. By establishing the neutral plane at 40” or less, it subjects the door to positive pressures on the door forcing flames and heated gas through gaps and clearances in the tested door assembly.
As such, edge sealing performs a critical function in protecting door clearances and gaps – typically success of the positive pressure tests relies on edge sealing to be in place during the tests, and as such is required to be installed in the field as part of the assembly where required to meet IBC section 716.5.1. This requirement, thus applies to new construction required to meet IBC, and this has been a requirement in the 2000, 2003, 2006 and 2009 codes previous since its inception.
This provision would apply to all IBC required fire doors. NFPA 101, Life Safety Code®, however does not have the same requirement – note excerpts below from the 2012 edition which is currently adopted for enforcement in many healthcare facilities throughout the US.
Edge Sealing for Fire Doors – NFPA® 101, Life Safety Code®, 2012
“220.127.116.11 Openings required to have a fire protection rating by Table 18.104.22.168 shall be protected by approved, listed, labeled fire door assemblies and fire window assemblies and their accompanying hardware, including all frames, closing devices, anchorage, and sills in accordance with the requirements of NFPA 80, Standard for Fire Doors and Other Opening Protectives, except as otherwise specified in this Code.”
“22.214.171.124* Fire protection ratings for products required to comply with 8.3.3 shall be as determined and reported by a nationally recognized testing agency in accordance with NFPA 252, Standard Methods of Fire Tests of Door Assemblies; ANSI/UL 10B, Standard for Fire Tests of Door Assemblies; ANSI/UL 10C, Standard for Positive Pressure Fire Tests of Door Assemblies; NFPA 257, Standard on Fire Test for Window and Glass Block Assemblies; or ANSI/UL 9, Standard for Fire Tests of Window Assemblies.”
NFPA 101 section 126.96.36.199 does not specifically require compliance with test standard UL 10C and as such allows compliance with NFPA 252 or UL10B also which do not require the positive pressure testing parameter. This results in the effect that life safety surveys involving the use of NFPA 101, 2012 cannot technically mandate the installation of edge sealing either for existing or new construction involving fire doors. The same would not hold true for fire prevention inspections conducted under the International Fire Code® for facilities constructed to meet either the IBC or the legacy Uniform Building Code (UBC) – previously adopted throughout Western Pacific regions of the US.
What strategy should facility managers take about existing fire doors where edge sealing is not equipped on fire doors in their facility? Like so many things in code compliance, the answer depends on the specifics of your individual facility. If you need any assistance in understanding this parameter for your facility, AEGIS has fire protection specialists here to help you with code consulting services and inspection services that can help maintain compliance with fire door strategies. What about smoke barrier doors – do the codes say I need to install gasketing on these doors? This question will be answered in our next article of this series.
– Justin B. Biller, P.E., CHFM, CLSS-HC, CFPS | AEGIS Technical Director
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We have sprinklers and alarms, are fire doors really all that important?
“Here’s the reality”, they begin, “There just isn’t enough money or time, and let’s face it, enforcement, to make door inspections part of the priority.” Or so the story goes. Talk to building managers, business owners or school superintendents and you will hear the same arguments over and over.
They continue, “The code is vague and open to interpretation. Doors that pass inspection today are non-compliant again tomorrow. The failure rate is too high. Inspections create legal paper work that makes me liable. No one is enforcing the code.” Or my personal favorite, “fire door inspection is a scam”.
Here’s the actual reality. Active and passive systems are meant to work together during a fire, not one in place of the other. Together they control fires and save lives. The code isn’t all that vague when interpreted by competent life safety professionals with the intention of proactively saving lives. The failure rate is high in most facilities. And this should be a very loud call to action. Inspections do create a paper trail that could lead to liability if you do nothing to maintain your doors, but death due to negligence is a larger problem.
The building code is a living document. It grows and matures based on real life experience. Real life experience like the one of Edward Pikinski, age eleven and pictured here. He is one of the 90 pupils who died in the Our Lady of Angels School Fire in 1958.
The primary cause of loss of life was the inadequacy of the exits, coupled with the use of substandard doors that were propped open at the time of the fire. The building code still enforces the invaluable lessons learned from Edward’s unnecessary death and the deaths of far too many other people. The lesson is clear: APATHY KILLS!
– Stephanie Smith | AEGIS Office Manager
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This dramatic fire safety video below from Underwriters Laboratories explains how closed doors in the home can save lives in a fire. More info on the Close Your Door safety initiative can be found at closeyourdoor.org.
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This question often sparks debate among fire protection specialists and fire safety experts – clearly many door openings in a building may be equipped with fire protection rated doors, hardware and frames, although by nature of its location would not be necessitated in order to meet codes and standards. Is it the intention of adopted codes and standards for these doors to be maintained in the same manner as other fire protection rated doors located in fire walls, fire and smoke barriers? Nowhere in facility fire safety maintenance is the answer to that question more critical than in health care occupancies where strict adherence to codes and standards is obligatory.
This vital issue of code compliance was raised pending adoption of the 2012 edition of Life Safety Code by the Centers for Medicare & Medicaid Services (CMS). In a June, 2016 meeting, the National Fire Protection Association’s (NFPA) Healthcare Interpretations Task Force (HITF) that represents officials from CMS and other health care accrediting organizations including The Joint Commission issued an interpretation of the question of door inspection and maintenance and stated in part that ‘the provisions of NFPA 80 do not apply’ where a fire door label has been removed, and it ‘can be considered the same as rendering the door as other than a fire protection rated door.’ Since it was considered a matter of code compliance to maintain features of fire protection deemed to be obvious to the public, it is important for facility managers to take appropriate action.
Hospital staff striving for accreditation by the Joint Commission in particular have become very familiar with the requirements in accreditation standard LS.01.01.01 to develop and have readily available life safety drawings that accurately depict all locations of fire and smoke barriers. The need for accurate life safety drawings, however extends beyond just health care facilities accredited by the Joint Commission, as it really encompasses all long-term care and hospice facilities, ambulatory surgical facilities and limited-care facilities to name only a few. When life safety drawings are kept up to date and reflect the original fire protection construction measures that were designed and constructed, it is more readily discernable which fire doors are not necessary and could be de-labeled as such. To assist facility managers with this task, AEGIS has partnered with Emerson Graham & Associates, Fire Protection Engineers and Code Consultants licensed in Virginia and North Carolina, for necessary life safety analysis to institute a proactive approach to fire door inspection and maintenance compliance, as well as reducing the unnecessary burden to maintain non-code required equipment. Could your facility benefit from these services? AEGIS is ready to put this consultation at your fingertips – find out more at aegisfiredoor.com/code-consulting/.
Justin Biller of Aegis Fire Safety Consultants will speak on January 16th at the meeting of the Central Virginia Chapter of the Society of Fire Protection Engineers (SFPE) in a joint meeting with ASSE.
He will speak on the subject ‘Fire Door Inspections & Field Labeling’ at 4PM.
In this intriguing article from Mr. Ron Cote’, NFPA technical services lead for life safety, he poses the question – Who is a qualified person to inspect fire doors under NFPA 80? The answer given may surprise you, as Mr. Cote’ himself describes his own personal lack of understanding of many of the critical components of fire door inspections, despite a highly recognizable career as a fire protection and life safety engineer working for NFPA over several decades in the development of the Life Safety Code.
Late last year, after studying the definition of qualified person, I realized I did not have the requisite skills to perform inspection and testing of fire door assemblies to the degree of detail and completeness required by NFPA 80—for starters, I didn’t know the differences between the door frame elements of face, rabbet, stop, soffit, throat, and jamb. I challenged myself to obtain that knowledge, and in so doing I set out on a path to learn what it might take for someone not working in the door and hardware field to learn what was needed to perform fire door assembly inspection and testing.
While nowhere close to the experience Mr. Cote’ has in applying fire and life safety applications in codes and standards, when I began looking into what was necessary to be involved in fire door inspections I too felt very similar feelings of inadequacy about the specifics of fire door hardware and installation. At AEGIS, we also turned to DHI for certification of our professional staff as a Fire Door Assembly Inspector and we agree it is by far the most comprehensive program of instruction and certification currently available in this growing industry.
– Justin Biller, P.E., AEGIS Technical Director
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We are always active in the fire protection industry, providing training and support to local companies and organizations. Shown at the top is Justin Biller, our technical director, speaking to the Carolinas Chapter of the Society of Fire Protection Engineers on fire doors and field labeling issues.
Justin Biller will also be speaking at the Fire Code Expo on Tuesday, February 28th in Columbus, OH on the subject of ‘Fire Doors and Opening Protectives’ and associated field labeling.
Also pictured here is Mark Waller, our executive director, taking time to tour a local fire station with some future firefighters!
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