Building And Fire Codes and the Locksmith

Oct. 17, 2011

Building and Fire Codes are such an important aspect of locksmithing that every locksmith should have a working knowledge of codes that affect your market area. Locksmiths should also have a good understanding of the reference standards that pertain to fire doors and egress doors.

Locksmiths who take the time to study the codes see their business growing in leaps and bounds mainly because knowledge is powerful. When you can explain to your customer why you can’t install a specific lock on a fire labeled door, you will get the sale that is legal and more profitable.   I cannot emphasize enough the importance of staying informed and stay up to date on all building and fire codes in your market!

Let’s start off by answering some common questions.

What is a fire door assembly?

A fire door assembly (installed in a fire rated wall) is used as part of a passive fire protection system to reduce the spread of fire or smoke between compartments and to enable safe egress in the event of a fire. To qualify as a fire rated opening, all of the hardware as well as the door, frame, and required smoke gasket must be listed with a testing laboratory for use on a rated fire door assembly.

Fire door assemblies are rated for 180 minutes, 90 minutes, 60 minutes, 45 minutes, and 20 minutes. The fire rating of a fire door assembly is determined by the lowest rated component; for example, a 20 minute rated door mounted in a 180 minute rated frame would be rated as 20 minute.

Temperature rise rated doors are specially designed for stairwells where door assemblies must not only be fire rated, but also limit the transmission of heat, to allow safe passage.

Fire doors must be self-closing and self-latching. In some situations, the local AHJ (Authority Having Jurisdiction) may allow doors to be automatic-closing by means of a magnetic holder or other device that releases and allows the door to close upon activation of the buildings’ fire alarm system.

What is a testing laboratory?

An independent testing laboratory tests fire door assembly components and publishes a listing of products that conform to the published standard. A label or mark is applied to identify products that meet certain test criteria. Two nationally recognized testing laboratories are Underwriters Laboratory (UL) and Warnock Hersey (WH). There are others as well. A local building code official or fire marshal relies on these test standards and listings to assure that fire door assemblies will perform as expected so that public safety is maintained.

How do you identify a fire rated opening?

An architect or structural design engineer will develop a compartmentalization plan to restrict the spread of fire and smoke in the event of a fire as part of the building design and engineering. This is done according to the type of construction and applicable building and fire codes in place at that time in the jurisdiction where the building is located. The best way for locksmiths to identify fire rated openings is to look for fire labels on doors and frames, particularly in these locations:

  • Openings in walls that separate buildings or divide a single building into designated fire areas.
  • Openings in vertical enclosures such as stairwells.
  • Openings that divide occupancies in a building.
  • Openings in corridors or room partitions.
  • Openings in a wall where there is the potential for fire exposure from the exterior of the building.
  • Openings in corridors where smoke and draft control is required, such as hotel or dormitory sleeping rooms.

As mentioned, the easiest way to find the rating is to look for the testing labels on the door, frame and hardware. If there are testing labels on everything, the opening is definitely fire rated.

To find the labels, begin by looking along the hinge stile of the door below the top hinge for metal doors. For wood doors the label is either below the top hinge or sometimes on top of the door.

The frame will have a label either on or embossed into the metal along the hinge stile, below the top hinge.

In photo 1, you see the embossed label on the frame. This frame is embossed with a one and a half hour rating. Some frames will have a three hour rating that will allow any rated door from 20 minutes to three hours to be used in the frame.

Photo 2 shows a labeled wood door with the label attached to the door edge below the top hinge.

For the latch or lockset to be installed on a fire rated opening it must be tested and listed with a testing laboratory. In photos 3A and 3B, you will see the (UL) F Mark on the scalp plate of the lock or latch bolt. The F mark indicates that the product has been tested and approved for use on a fire door assembly. Both of these are displaying the (UL) F Mark.

If you need to know the size of the latch projection, the door label will state a size of the latch on the label. If there is no size indicated on the door label then the minimum acceptable size is ½ inch with the (UL) F Mark or the (WH) F Mark.

As you can see by the Listed F Mark, it is not too hard to identify fire rated hardware in the field. Some of the other items that will have the testing laboratory mark is the door closer, flush bolts, door viewers, and some hinges. Kick plates that exceed 16” from the bottom of the door need to be listed and have a mark showing on the plate.

In Photo 4, you can see the Listed Door Closer Body (UL) Mark on this spring hinge. Some rules of thumb to follow with spring hinges is that you must always have two spring hinges on a door assembly and the door cannot exceed seven foot in height. Ball bearing hinges conform to construction standards as specified by NFPA (National Fire Protection Association) in NFPA 80 (2010) and are not required to be marked.

Fire Exit vs. Fire Panic Hardware

A good example of non-fire rated hardware are latches for residential use; these are generally not fire rated or listed.

There is some confusion between Fire Exit Hardware and Panic Exit Hardware. Even though a manufacturer may have two devices that look identical in design, function, and operation, the difference would be the testing label.   All Fire Exit Hardware components are also listed as Panic Exit Hardware. The main difference besides the label is that Fire Exit Hardware does not have a mechanical dog down feature for the bar to leave it in the unlocked condition. The label in Photo 5 contains a wealth of information.

S Mark indicates the assembly has been evaluated to elevated ambient temperature air leakage tests. S Mark needs a Category H edge seal to be applied to the frame or door. Category H edge seals must be provided to meet the S Mark where required. Most likely, they will be required on any door rated 20 minutes and up in a smoke controlled environment.

Fire Exit Hardware means that it was tested on a door and burned in a testing laboratory to determine the rating that hardware will withstand and the label show that level.

The bottom line is you can only use Fire Exit Hardware on labeled fire door assemblies that require a panic device.   Many conditions would require Fire Exit or Panic Exit hardware. The first that comes to mind is the occupant load of the room. If the occupancy reaches or exceeds 50 then panic hardware is required and the doors must swing in the direction of egress travel. Another area would be High Hazard occupancies.

Panic Exit Hardware has not been fire tested to be used on a fire labeled assembly so you will see these devices on exterior doors since most of these doors are not fire labeled. This device will have a dogging feature so you can leave the door in the unlatched state. Exit discharges from a stairwell will not have the dogging feature because positive latching is required at all times.

What all this means is that the product is tested to a standard and listed in the testing laboratory’s directory. Here is a definition from NFPA 80 2007.

3.2.4 Listed. Equipment, materials, or services included in a list published by an organization that is acceptable to the authority having jurisdiction and concerned with evaluation of products or services, that maintains periodic inspection of production of listed equipment or materials or periodic evaluation of services, and whose listing states that either the equipment, material, or service meets appropriate designated standards or has been tested and found suitable for a specified purpose.

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.

Code Requirements

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 Repairs shall be made, and defects that could interfere with operation shall be corrected without delay.

NFPA 80 2007/2010 Field Modifications

NFPA 80 2007/2010 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 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.

If the listing and labeling agency is not able to issue a finding on the modification based on the information provided, a field inspection may be required. The listing and labeling agency will send a representative to the job site and the representative will review the modification and if the modification is determined to not compromise the door assembly, they will normally apply a field inspection label to the door assembly or component. They may also provide a written summary of the inspection.

NFPA is a nationally recognized association that helps regulate requirements for a safer environment for everyone. Where these reference standards try to integrate with the International Code Congresses, International Building Code, (IBC) and the International Fire Code, (IFC) the ambiguity is clear and this leaves the readers scratching their heads.   There comes a problem because The IBC and IFC does not come right out and make the fire door inspection a requirement of their codes. I see this changing in the future because of the popularity of the fire door inspection by the code officials and it makes the AHJ’s job easier with “More feet on the street.”

The predominately used building code is International Code Congress 2009 International Building Code across the United States and Mexico.   The dominate IBC 2009 building code has a close runner up in IBC 2006 and behind that is IBC 2003. The reason for this is that the states are slow to adopt new laws until all of the t’s are crossed and all of the I’s are dotted. This takes up to five years to get through the individual state legislations so the bill can be submitted and usually the code their adopting into their own law is outdated to the latest code guide. That is why some jurisdictions will jump a code series like going from IBC 2003 to IBC 2009 and skipping IBC 2006. This is quite common because of the time frame to get codes turned into laws.

It would be a lot easier if all of the states just adopted one code.   As I write this I have to laugh because each state is its own governing body and a lot of work goes into developing the state adopted building and fire codes. What would be the drawback in adopting the new code guide when it is released by ICC. One important aspect is the language that it is written in. You’re asking yourself, “Well, don’t they all use English?” The answer is yes but the wording text is unique in each states constitution so all written documents for a particular state must be written in the same text as their constitution or it is not enforceable in their courts.

That is the beauty of America; we have 50 states and 50 constitutions that the proposed model building and fire codes must fit into in order for these states to be able to enforce their laws.

Tom Resciniti Demont is president of Technical Services, Inc., a Pittsburgh area based consulting company and the author of “Life Safety Codes – In the Means of Egress.” He is an expert on Building and Fire Codes in the means of egress for ALOA and is happy to answer any question about doors, frames, and hardware in the means of egress. E-mail Tom at [email protected]