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Fire rated door maintenance vs code change

D

DTBarch

SAWHORSE
Joined
Nov 1, 2010
Messages
84
Location
Phoenix, AZ
Type II-B, fully sprinkled office bldg built in the 80’s. Corridors and doors were originally required to be fire rated. Current IBC exempts corridors and doors if building is fully sprinkled. Are the original rated doors in the corridors required to be maintained even if they are not required by the current code?
 
Is the building sprinkler system up to the current NFPA-13 standard? If so, then I would say the doors can be "de-rated," so to speak. Otherwise, a 1980s sprinkler system may not provide the same level of coverage and reliance as today's modern sprinkler systems, allowing fire-resistance-rated assemblies to be reduced or eliminated.

If you were to go into a plan review stating you were installing a new sprinkler system per NFPA-13-80 but still wanted to take advantage of the sprinkler tradeoffs the current code allows, you would get a snicker and an emphatic "no."
 
DTBarch said:
Are the original rated doors in the corridors required to be maintained even if they are not required by the current code?
Click to expand...
IMHO yes they are required to be maintained. The code requirement for Light Hazard Occupancies Suppression system requires Quick-Response or Residential Sprinklers.


c. Buildings equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1 or 903.3.1.2 where allowed.

[F] 903.3.1 Standards.
Sprinkler systems shall be designed and installed in accordance with Section 903.3.1.1 unless otherwise permitted by Sections 903.3.1.2 and 903.3.1.3 and other chapters of this code, as applicable.

[F] 903.3.2 Quick-response and residential sprinklers.
Where automatic sprinkler systems are required by this code, quick-response or residential automatic sprinklers shall be installed in all of the following areas in accordance with Section 903.3.1 and their listings:

1. Throughout all spaces within a smoke compartment containing care recipient sleeping units in Group I-2 in accordance with this code.

2. Throughout all spaces within a smoke compartment containing treatment rooms in ambulatory care facilities.

3. Dwelling units and sleeping units in Group I-1 and R occupancies.

4. Light-hazard occupancies as defined in NFPA 13.
 
Here’s what I found in a recent article by Lori Greene that appears to confirm that, per NFPA, existing rated doors that are no longer required to be rated, do not need to be maintained, or “de-rated” (have the labels removed)

2021 Clarification

A new paragraph was added to the 2021 edition of NFPA 101, which further clarified 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.”

The problem statement submitted as part of the code development process referenced the 2015 change to Annex A. Although that change was intended to clarify that the requirements of the section were not meant to pertain to fire doors, interpretations were still inconsistent. Facilities were being cited by AHJs for non-compliant fire door assemblies – even when those assemblies were installed in locations where a fire rating was not required. This was because some AHJs were interpreting fire doors and frames as being life safety features that were obvious to the public.

The new paragraph in the 2021 edition of NFPA 101 is very clear. If a door or frame has a label and is installed where a rated opening protective is not required, the requirements of NFPA 80 do not apply. Although a code change does not technically take effect until that edition of the code is adopted, this change is more of a clarification and the hope is that it will begin to affect AHJ interpretations immediately.

The new code language makes it clear that extraneous labels can remain, without prompting additional requirements. The intent of NFPA 101 is that only the required opening protectives indicated on a facility’s life safety drawings must be maintained in accordance with NFPA 80 and must be inspected annually. As always, the AHJ has the final say and should be consulted for their interpretation of the adopted codes.
 
I believe you would have to document why they are no longer required to be rated. Just because there is an existing sprinkler system in place does not automatically mean it meets todays IBC requirements for a sprinkler system.

2018 IEBC Chapter 5

501.2 Fire-resistance ratings.
Where approved by the code official, in buildings where an automatic sprinkler system installed in accordance with Section 903.3.1.1 or 903.3.1.2 of the International Building Code has been added, and the building is now sprinklered throughout, the required fire resistance ratings of building elements and materials shall be permitted to meet the requirements of the current building code. The building is required to meet the other applicable requirements of the International Building Code.

Plans, investigation and evaluation reports, and other data shall be submitted indicating which building elements and materials the applicant is requesting the code official to review and approve for determination of applying the current building code fire-resistance ratings. Any special construction features, including fire-resistance-rated assemblies and smoke-resistive assemblies, conditions of occupancy, means of egress conditions, fire code deficiencies, approved modifications or approved alternative materials, design and methods of construction, and equipment applying to the building that impact required fire-resistance ratings shall be identified in the evaluation reports submitted.
 
I do not believe the 80's vintage sprinkler system without upgrades will allow you to take the exception.

I had a conversation with the Life Safety Plan Reviewer here in San Diego way back in 2015. This was in response to all of the commercial real estate brokers telling their building owners that they no longer needed to maintain the existing fire rated corridors and could go ahead and install glass doors and sidelights throughout the corridors in some very old buildings since the code changed and their building was fire sprinklered. This battle still continues to this day.

I have attached my conference report from back then where we ended up with 1996 being the trigger date to allow this to occur. Some jurisdictions will actually require a permit be pulled to de-rate the corridors. basically forcing the owners to explain their reasoning. I wish more would do this.

I would love to hear what you all have to say and how this conference report has aged.
 

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