In the February issue of Locksmith Ledger, we covered the 2021 model code changes that apply to locks and latches. Other upcoming changes will affect swinging-door openings. Although these changes technically won’t take effect until a new code is adopted in a project’s jurisdiction, some of the changes are clarifications that can be helpful in interpreting the code requirements even before adoption.
The model codes addressed in this article are the International Building Code (IBC) and NFPA 101 – Life Safety Code, but there are other publications from the International Code Council (ICC) and the National Fire Protection Association (NFPA) that might include the same requirements. Most states adopt building codes and fire codes that are based on these model codes, often with state-specific modifications. It’s important to be familiar with the adopted codes in the jurisdiction of any building where you install or modify door openings, including the state requirements.
Fire-Door Assemblies
Fire-door assemblies are an important part of a passive fire-protection system, helping to compartmentalize a building to deter the spread of fire. Labels on the edge of a fire door and in the rabbet of the door frame help to identify these opening protectives. However, labeled doors or frames sometimes are installed in locations where fire-door assemblies aren’t mandated. The labeled component might have been relocated or pulled from stock and installed in an opening that isn’t required to be fire-rated and doesn’t meet all of the requirements for a fire-door assembly. For example, the assembly might have a labeled door but no door closer, leading to concerns about whether the opening complies with code.
Although it might be confusing to find a labeled fire door or frame where a fire-door assembly isn’t required, the model codes don’t prohibit this application. However, a paragraph in NFPA 101 created inconsistent interpretations in the field. This section of the Life Safety Code requires life-safety systems that are obvious to the public to be maintained or to be removed if they aren’t required. If a building occupant sees a sprinkler head, for example, they might decide to shelter in place during a fire, believing, perhaps incorrectly, that the sprinkler system will provide adequate active fire protection.
When a labeled fire door was installed where it wasn’t required, some code officials believed that the label on the door would be obvious to the public as referenced by the section in NFPA 101. In some facilities, the Authority Having Jurisdiction (AHJ) offered two options: Remove the extraneous fire-door label or maintain the assembly as required by NFPA 80 – Standard for Fire Doors and Other Opening Protectives.
The 2021 edition of NFPA 101 includes a change that clarifies the intent of the code: “4.6.12.4 Where a door or door frame that is not required to be fire protection-rated is equipped with a fire protection listing label, the door and the door frame shall not be required to meet NFPA 80.” This clarifies that if a labeled fire door or frame is installed in a location where a fire-door assembly isn’t required, the label can remain, and the assembly isn’t required to comply with NFPA 80.
Terminated Stops
Another code change related to fire-door assemblies addresses the use of terminated stops, also called hospital stops or sanitary stops. This frame modification ends the frame stop about 6 inches above the floor to reduce the number of corners where debris can collect and make it easier to clean the floor at the bottom of the frame. Although terminated stops are allowed by most frame manufacturers’ listings for fire-door assemblies, the IBC didn’t address this application specifically in past editions. This concerned some AHJs because of the perceived potential for smoke infiltration through the area of the missing stops.
The 2021 IBC includes a definition for the term “terminated stop,” as well as a limitation of 6 inches on the height of the missing section of stop. The code lists the locations where terminated stops on fire-door assemblies are NOT permitted, which means they ARE permitted in other locations. All of the locations where terminated stops are prohibited are related to elevator lobby doors — for fire-service access-elevator lobbies, occupant-evacuation elevator lobbies, in some underground buildings and some elevator hoistway doors.
Panic Hardware
For some rooms that contain electrical equipment, NFPA 70 – National Electrical Code (NEC) requires certain doors to be equipped with panic hardware. This helps to ensure that a technician can operate the door easily for egress if a fire or explosion occurs in the room. The IBC also includes a section specifying which electrical rooms are required to have doors equipped with panic hardware. A change was made to align the 2021 IBC with the NEC. However, the requirements of NFPA 70 vary depending on which edition has been adopted.
The 2021 IBC also includes a new requirement specific to doors serving refrigeration machinery rooms; these rooms often are related to a building’s air conditioning system or found in refrigerated warehouses. If the refrigeration machinery room is larger than 1,000 square feet, two exit or exit-access doorways are required, and doors must be outswinging and equipped with panic hardware or fire exit hardware. This helps to protect building occupants from the risk of a rapid release of hazardous or asphyxiant gases from the refrigeration equipment.
Clear Opening Height
When installing a door closer, electromagnetic lock or other hardware at the top of a door, some mounting configurations will result in the hardware projecting into the clear opening height. The model codes and accessibility standards require at least 80 inches of clear opening height but include an exception for certain types of hardware that can project down into the opening. This exception requires a minimum clear height of 78 inches to be maintained between the lowest point of the projecting hardware and the finished floor.
The codes and standards specifically allowed “door closers and door stops” to project into the clear opening height, but a change was made to the 2021 IBC, which expands the types of hardware addressed. The new section specifically allows door closers, overhead stops, automatic operators and electromagnetic locks to project into the clear opening height to the point 78 inches above the floor. NFPA 101-2021 doesn’t include a similar change, so it’s important to know which code has been adopted before you install this hardware.
Automatic Operators
Although automatic operators can make a door opening more convenient for all building occupants, including those who use wheelchairs, the model codes and accessibility standards haven’t required automatic operators in any specific locations. Auto operators sometimes are installed where a door can’t meet the accessibility requirements for a manual door, but in most jurisdictions, there hasn’t been a mandate for doors to be automated.
This changed with the 2021 IBC, which now requires public entrances for some buildings to have at least one door that has an automatic operator. The automatic door might be a power-operated pedestrian door or a door that has a low-energy automatic operator. A power-assist operator wouldn’t be compliant with this new requirement, because these operators reduce the opening force but still require the door to be opened manually.
The new requirement applies to certain assembly occupancies, including theaters, bars, restaurants and sports facilities, that have an occupant load of more than 300 people, as well as business, mercantile and R-1 residential occupancies, such as hotels, that have an occupant load of more than 500 people. Because of changes made in the 2017 edition of ICC A117.1 – Standard for Accessible and Usable Buildings and Facilities, we likely will see more automatic operators on the exterior and vestibule doors at these public entrances.
For detailed information on these and other requirements related to door openings, refer to the 2021 editions of the model codes and be sure to check the adopted codes for state and local modifications.
Lori Greene, DAHC/CDC, CCPR, FDAI, FDHI, is manager, codes and resources at Allegion. Visit her website, idighardware.com.
