Fire Doors - California & New York

[LGreene]

I'm trying to compile some information on my blog about the states that have adopted a fire code that references NFPA 80-2007. This edition of NFPA 80 requires fire door assemblies to be inspected annually as part of the maintenance procedure. If a fire code states that fire doors have to be maintained in accordance with NFPA 80 and references the 2007 edition, it's my understanding that fire door inspections are required, even if they're not yet being enforced. Because the inspection requirement is buried in a referenced standard, the process of raising awareness is slow.

I wanted to get some input from you all before I got too far into this project. Do you agree with my thought process?...

fire code requires maintenance per NFPA 80 + NFPA 80 requires an inspection as part of maintenance = fire code requires annual inspection?

Keep in mind that the inspection is not meant to be done by the fire marshal...the building owner can use their own qualified personnel or hire a 3rd-party fire door inspector. The reason the annual inspection was added to the standard is because a large percentage of fire doors aren't properly maintained. If your fire code requires inspections, this can be a tool for you to pull out of your bag when you need to get rid of the wood wedges and the non-compliant field modifications.

I'd love to hear your thoughts on this subject. If you want to check out the recent blog posts, here they are:

http://idighardware.com/2011/03/when-will-fire-door-inspections-be-required-in-my-jurisdiction/

http://idighardware.com/2011/03/fdai-california/

http://idighardware.com/2011/03/fdai-new-york-state/

 

[RLGA]

If they have adopted the 2009 IFC, then the 2007 edition of NFPA 80 is the referenced standard. However, a listing in Chapter 47 doesn't mean that the entire text of the standard is a part of the code. Section 102.7 of the IFC states, in part, "...such codes and standards shall be considered part of the requirements of this code to the prescribed extent of each such reference." Thus, if a reference in the text of the code to a standard is very specific, then only that specific reference in the standard is applicable and not the entire standard itself.

Section 703.2 specifically states, "Opening protectives shall be maintained in an operative condition in accordance with NFPA 80." This is a broad, all-inclusive statement that seems to invoke all of the maintenance requirements of NFPA 80, and will likely be interpreted that way.

However, with that in mind, I find it odd that the IFC would provide Section 703.4, which states, "Horizontal and vertical sliding and rolling fire doors shall be inspected and tested annually to confirm proper operation and full closure. A written record shall be maintained and be available to the fire code official."

This seems to limit annual inspections to just sliding (horizontal and vertical) and rolling doors. Since Chapter 5 of NFPA 80 provides requirements for annual inspections, including the inspecting and operational testing of sliding and rolling doors (Section 5.2.5), why would the IFC have a need to develop a specific requirement for those types of doors? Seems like "say it once so they'll do, say it twice to make sure."

 

[LGreene]

Thanks Ron. I noticed the paragraph regarding sliding and rolling doors and I assumed that they were mentioned specifically because they've required inspection for a long time, not because swinging doors were excluded from the inspection requirement. I received the following from the ICC, when they were asked about the reference to NFPA 80 in the building code vs. the fire code:

With the exception of Section 410.3.5, which requires compliance with NFPA 80, the International Building Code only requires fire door assemblies and shutters to be installed in accordance with the provisions of NFPA 80. The installation of fire doors does not refer to annual inspections. As such, the International Building Code does not require annual inspection of fire doors.

Section 703.1.3 of the International Fire Code, however, requires all openings protected with approved doors or fire dampers to be maintained in accordance with NFPA 80. After opening protectives are installed and approved, they may become damaged, corroded or otherwise less effective than required. Since the opening protectives are critical life safety components, they must be maintained throughout the life of the building. Chapter 5 of the 2007 edition of NFPA 80, which is referenced in the 2009 International Codes, refers to annual inspections as part of the maintenance. As such, the 2009 International Fire Code would require the fire doors to be annually inspected.

 

[RLGA]

That's what I would expect. The building code is only concerned with the construction of the building, hence the reference to only the installation requirements of NFPA 80.

The IFC, which focuses on the occupancy and operation of a building once constructed, would thereby include the requirements for maintenance and inspection requirements of NFPA 80.

 

[permitguy]

I agree with all of the above.

 

[peach]

Most places require annual fire inspections... and that SHOULD include annual fire alarm testing, annual elevator inspections (recall and test of heats and smokes), annual service on the fire pump, checking fire extinguishers, checking fire doors, review of ALL maintenance records..

 

[JBI]

Lacking universal enforcement (by what many believe to be bloated and oppressive local government anyway), the requirement is there and the moral obligation of the building owner/occupant clearly exists.

And, I agree with all of the above as well.

 

[Markl_AHC]

"Do you have your fire door inspection report and maintenance records?" is the question that results in enforcement - or at least something similar - in my admittedly simple view. Unfortunately I have yet to personally find a facility whose management (decision-makers who hold the purse strings) feels compelled due to moral obligation. I've discussed this in detail with people who truly care, but yet no action is taken. College housing and hospitality facilities are the two I see regularly where the risk is greatest to a large number of building occupants with fire doors not being properly maintained - and I'm not talking minor problems.

I think the ICC's explanation/opinion is important and takes away some ambiguity regarding inspection. Thanks for posting that information, Lori.

 

[FM William Burns]

Annual fire inspections :lol: We are lucky to get to a building once every five years. This indeed leaves opportunities for failures with assemblies. I can agree that it should and most likely will be an added item on the checklists or inspection forms and treated like alarm & suppression annual maintenance once it catches on by enforcers.

As others have mentioned, the building owner is ultimately the one holding check book when it hit's the fan,

 

[LGreene]

So, FMWB...how can I help it catch on with the enforcers?

 

[FM William Burns]

As I’ve mentioned before the requirements for operations, maintenance and inspections have been there for many years in 80 however granted by a term “periodic” now clearly spelled out as annually via 2007 5.2. Seasoned inspectors have historically required swinging doors to be tested; when upon their inspection it was discovered that something didn’t work properly or look right while doing or witnessing a functional test during the inspection. This has also been the case for rolling and sliding doors and windows. Since the current editions of 80 allow property management (if knowledgeable) to perform this function annually (as spelled out now specifically through the assumed definition of periodic) it is basically clarifying what has been practiced by seasoned inspectors historically in many jurisdictions I’m familiar with.

Regarding what can be done, you have been doing a great job with your Blog. My only suggestion may be to gain or expand access to state and regional fire inspector organizations offering “free” manufacturer specific training addressing the importance and what to look for in functional testing and operational maintenance programs and documentation of swinging and other fire door assemblies. We have done this every few years in our state to stress the importance of maintenance of fire door assemblies dating back to 1994. This can go a long way in keeping the importance of operational and functional testing on their minds when doing existing building inspections.

Personally, we have had drop down items addressing fire door assemblies in our topic field for “fire rated assemblies” on our electronic inspection forms for many years.

Many new inspectors are not aware of what something should look like or how doors should function, latch and seal on manual or automatic means. Now having the criteria spelled out in [80-07 5.2] and performance guidelines it opens the door for them to not have to use interpretational judgments in requiring inspections “periodically” by “qualified individuals” or property management as directed through functional testing.

 

[RLGA]

On the contrary, prior to the 2007 edition of NFPA 80, there was no annual inspection requirement, nor any inspection requirement. NFPA only required that periodic inspection be performed on equipment that that produces labeled and listed assemblies.

The Appendix A, which include explanatory information, mentions period inspection, but is not mandatory as stated at the begining of the appendix. Section 15-2.1 (NFPA 80-1999) states that "hardware shall be examined frequently," but again no required periodic inspection requirement for the entire assembly and definitely no maintenance of an inspection record.

 

[FM William Burns]

No bone to pick here........

Regarding inspections, I am referring:



15-2 Specific Requirements.



15-2.1* Inspections.



A-15-2.1 Fire doors, shutters, and windows are of no value unless they are properly maintained and closed or are able to close at the time of fire. A periodic inspection and maintenance program should be implemented and should be the responsibility of the property management.



15-2.1.1* Hardware shall be examined frequently and any parts found to be inoperative shall be replaced immediately.



and as an AHJ some have used

interpretational judgments in requiring inspections “periodically” by “qualified individuals” or property management

possibly in direct relationship to what and why we see it in current text as mandatory language presently.