I was recently contacted by a locksmith from a local university who attended my fire door inspection class last year. A new dormitory on campus is in the final stages of construction, and many of the fire doors have been installed with perimeter clearances that exceed those allowed by NFPA 80 – Standard for Fire Doors and Other Opening Protectives. The locksmith was concerned that when the local fire marshals eventually begin to enforce the annual fire door assembly inspection requirement, the facility would then be responsible for the non-compliant doors.
The requirement for fire doors to be inspected annually was added to the 2007 edition of NFPA 80, and carried forward in later editions. When other codes – particularly fire codes – reference those editions of the standard, annual fire door assembly inspection becomes a requirement for that jurisdiction. Code officials may not immediately be aware of the requirement because it is in a referenced standard and not the code itself, but eventually the requirement will be enforced. The change to the standard has brought much-needed attention to the condition of fire doors, and a similar change in NFPA 101 – The Life Safety Code (2009 edition and later) addresses the inspection of certain egress doors.
But responsibility for keeping doors in code-compliant condition does not begin when the annual inspection requirements are enforced. Fire doors help to compartmentalize the building and are an important part of the passive fire protection system. Facilities, including the university with the new dorm, are responsible for maintaining those doors in code-compliant condition from Day 1. This has always been the case. I went back to my 1961 edition of NFPA 80 and found a 12-point Care & Maintenance section, including a mandate for “a continual maintenance and inspection program to insure that doors will operate under fire conditions.”
My advice to the locksmith? Insist that the fire door issues are corrected before accepting ownership of the new dorm.
Locksmiths have an opportunity – and a responsibility – to inform the facilities they visit about any compliance issues with their fire doors and egress doors. NFPA 80 and NFPA 101 both require any problems to be corrected “without delay.” Accessibility issues should also be addressed with the facility. Here are some issues to watch for:
Does the door operate properly, open and close without binding? Is any of the hardware damaged, defective, or missing? A leaking door closer might still close the door, but it may not control the door properly or comply with accessibility requirements for closing speed – typically 5-6 seconds.
Fire doors are equipped with a label, and frames for fire-rated openings may have a label or may be embossed with a listing mark. These labels must be present and legible. If they cannot be made legible, the Authority Having Jurisdiction (AHJ) may require the openings to be relabeled by a listing agency.
One of the most common issues with fire doors is a damaged or defective door closer. Fire door assemblies must be self-closing or automatic-closing. Self-closing doors have a closing device (door closer or spring hinges), which closes the door each time it is opened. Automatic-closing doors have a hold-open device that will release the door and allow it to close during a fire. Test these devices to ensure that they release and that the doors close properly. Kick-down door holders and other mechanical hold-open devices are not acceptable for use on fire doors and must be removed. If fire doors are held open with door wedges or similar means, installation of code-compliant hold-open devices should be considered.