In 1998 these three code agencies merged to form one national code agency covering the United States called the International Code Congress (ICC). In 2000 the ICC released the International Building Code (IBC).
Today we are teaching IBC-2006. Even though IBC-2009 was just released, it will not be taught until 2010 because of the lag in the state legislatures' in voting these code guides into law.
Don't get building codes confused with life safety codes put out by the National Fire Protection Association (NFPA). When life safety codes are taught, building codes are a big part of the course. Two main code officials enforce these codes, fire marshals and building inspectors.
Building Inspectors enforce IBC during construction of both new and retrofit. The fire marshal enforces Life Safety Codes at all times. Since life safety codes incorporate building codes, the fire marshal is always the last to sign off on any construction project. The fire marshal is charged with periodic inspections to make sure that no barrier to free egress is erected between visits.
In today's building codes, life safety codes are incorporated with accessibility codes outlined under the Americans with Disabilities' Act of 1990 (ADA). The size and range of all these codes can become confusing when each is read individually. For practical locksmith purposes, let's look at how these codes may affect your daily work.
The biggest problem you must overcome is your customers' security needs and the building and life safety codes that dictate what you can do in the means of egress. “Means of Egress” is the safe exit route out of a building or structure. Putting up barriers like deadbolts (mechanical or electronic), slide bolts and chains with padlocks are forbidden. A good rule of thumb is if there is an exit sign above the door, you cannot stop anyone from going through the door from the egress side.
I always tell locksmiths to put themselves in the place of someone exiting from the area on which they are working. In an emergency, do you feel uneasy about what you're asked to do? Always go with your gut feeling.
The most asked question is: “Where does it say I can't drill a hole in a fire door?” Just so we're clear, it has always been in the guide code NFPA-80 since it was enacted many years ago. Here are the most current code sections that enforce this requirement.
NFPA-80 1999, CH. 1
1-3.4 Preparation of fire door assemblies for locks, latches, hinges, remotely operated or remotely monitored hardware, concealed closers, glass lights, vision panels, louvers, and astragals, and the application of plant-ons and laminated overlays shall be performed in accordance with the manufacturer's inspection service procedure and under label service.
Exception: For job site preparation of surface-applied hardware, function holes for mortise locks, and holes for labeled viewers, a maximum 3/4-in. (19-mm) wood and composite door undercutting, and protection plates (see 2-4.5) shall be permitted. Surface-applied hardware is applied to the face of a door without removing material from the door other than drilling round holes through the face of the door to accommodate cylinders, spindles, similar operational elements, and throughbolts. The holes shall not be permitted to exceed a diameter of 1 in. (25.4 mm) with the exception of cylinders.
NFPA-80 2007, Ch 4
22.214.171.124 Preparation of the fire door assemblies for locks, latches, hinges, remotely operated or remotely monitored hardware, concealed closers, glass lights, vision panels, louvers, astragals and split astragals, and the application of plant-ons and lamented overlays, shall be performed in accordance with the manufacturer's inspection service procedure and under label service.
126.96.36.199 For job site preparation of surfaces-applied hardware, function holes for mortise locks, and holes for labeled viewers, a maximum 3/4 in. (19 mm) wood and composite door undercutting, and protection plates shall be permitted.
188.8.131.52 Surface-applied hardware shall be applied to the door or frame without removing material other than drilling round holes to accommodate cylinders, spindles, similar operational elements, and through-bolts in doors.
184.108.40.206 The holes described in 220.127.116.11 shall not be permitted to exceed a diameter of 1 in. (25.4 mm) with the exception of cylinders.
“Manufacturer's inspection service procedure and under label service” means that if you are not a licensed label facility by the door manufacturer, you cannot modify and or alter the door and frame. Even licensed facilities can only make modifications in the licensed shop.
Any time a new code is introduced like NFPA-80 2007, there is a lag time from two to six years while the individual states review the code for compliance into their state laws. This is the case with NFPA-80 2007 since it introduces the concept of Fire Door Assembly Inspections. This requirement is taking off across the United States.
ICC introduced IFC-2009 that incorporates the Fire Door Assembly aspect of NFPA-80 2007. This requirement puts the burden of inspecting the fire door assemblies in the means of egress on the owner/tenant of the space. Hospitals have been doing this for years and it works great for the code inspectors since they only inspect openings where there is a discrepancy or the paperwork isn't clear.
A fire door assembly inspector is required to have sufficient knowledge of fire door assemblies. There are no required courses in order to become an inspector.
Yes, paperwork needs to be filled out on an annual basis that indicates that a knowledgeable doors, frames, and hardware person inspected the fire door assembly. This person can be someone on the maintenance staff with knowledge in doors, frames, and hardware or the facility can hire an inspector or locksmith. The inspections must be done annually.
The Door and Hardware Institute (www.dhi.org) offers a three-day course to become a Certified Fire Door Assembly Inspector. ALOA (www.aloa.org) will offer a one-day course on NFPA-80 2007 to help locksmiths study the requirements to incorporate this service into your daily work schedule.
Tom Demont, AHC, CFL, CIL, CML has been in the locksmith industry for 50+ years. He developed the first codes life safety codes class for locksmiths in 1990.