Products that comply with the applicable fire test standards are listed by an approved listing and labeling agency like Underwriters Laboratory and Warnock Hersey.
What do you do if the label is missing from the door or the hardware and you have determined that the door is fire a rated assembly?
You must treat the replacement of all hardware as if the label was there. If you cannot determine this by looking at the location of the assembly, ask to see the architectural drawings and construction plans. Refer to the door schedule for locations of fire-rated openings.
Note: If an opening is fire rated, and the label has been removed from a piece of fire rated hardware, the hardware must be replaced. For example, on some exit devices, the label is on the end cap. Unfortunately, in an environment where there is cart traffic, the exit device end caps have a tendency to be ripped off when a heavy laden cart forces open the door. A fire rated (labeled) end cap cannot be purchased separately. For most, if not all exit devices, the only way to determine the difference between a fire rated device and a non-fire rated device is the testing laboratory label Mark.
In 2007 NFPA 80 was rewritten to require fire door inspections, putting the burden on the owner. This new code requirement has been floundering for the past five years with the state governments as to how to adopt and regulate this procedure.
Most jurisdictions are taking the soft approach and making suggestions to the building owners to contact a fire door inspection company to verify all of their fire doors are up to code.
There are some like Clark County, Nev., that made it mandatory that all building fire doors will be inspected annually by a fire door inspector. The Door and Hardware Institute, (DHI) and the International Fire Door Inspection Association, (IFDIA) and Associated Locksmiths of America, (ALOA) have courses that offer this training. They all require a pre test to assure that you know basic standards for doors, frames, and hardware.
NFPA 80 2007/2010 5.2.1 Fire door assemblies shall be inspected and tested not less than annually and a written record of the inspection shall be signed and kept for inspection by the AHJ.
NFPA 80 2007/2010 5.1.5 Repairs and Field Modifications
NFPA 80 2007/2010 18.104.22.168 Repairs shall be made, and defects that could interfere with operation shall be corrected without delay.
NFPA 80 2007/2010 22.214.171.124 Field Modifications
NFPA 80 2007/2010 126.96.36.199.1 In cases where a field modification to a fire door assembly is desired, the laboratory whose label is on the assembly shall be contacted and a description of the modification shall be presented to the laboratory.
NFPA 80 2007/2010 188.8.131.52.2 If the laboratory finds that the modifications will not compromise the integrity and fire resistance capabilities of the assembly, the modifications shall be permitted to be authorized by the laboratory without a field visit from the laboratory.
These NFPA 80 requirements provide a process by which field modifications to a fire door assembly can be reviewed to make a determination if the field modified fire door assembly will continue to comply with the applicable requirements. As was noted earlier, listing and labeling agencies play a key role in building safety. If a field modification has been made to a fire door assembly component, that component must bear a label of a listing and labeling agency acceptable to the AHJ.
When there is a field modification to a component, the listing and labeling agency for that component will normally be contacted and information on the modification will be provided. Upon review of the information, if the listing and labeling agency determines the modification will not compromise the integrity of the component and fire door assembly, the listing and labeling agency may authorize the modification without the need to visit the job site. In these cases, the listing and labeling agency will more than likely issue a written finding that should be kept on file by the building owner, contractor that did the modification and AHJ as appropriate.