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January 18, 2017 Previous day Next day

Image courtesy of Jake Pauls

 

With the recent move from the 2000 edition of NFPA 101 to the 2012 edition by the Centers for Medicare & Medicaid Services (CMS), we’ve been getting questions at NFPA periodically about the Code’s requirements for door inspections, particularly as they apply to health care occupancies. Here’s a little history on the Code’s door inspection provisions.

 

In the 2009 edition, Chapter 7, which addresses means of egress, introduced a new set of requirements titled ‘Inspection of Door Openings’ (see 7.2.1.15 in the 2009 edition). The provisions were intended to ensure reliability of egress doors, especially in areas like assembly occupancies, where door hardware might be subject to accelerated wear due to high-frequency usage. The provisions were formatted to apply where required by Chapters 11 through 43, and served as a ‘menu item’ that could be referenced by the various occupancy chapters where the applicable technical committees deemed it appropriate. In addition, the provisions only applied to those egress doors that were required to swing in the direction of egress travel – generally, doors serving a room or area with an occupant load of 50 or more, doors serving exit enclosures, and doors serving high-hazard content rooms. The annual inspection included items such as:

  • Inspection and testing in accordance with NFPA 80 where the door is a fire door
  • Functional testing to ensure proper operation
  • Visual inspection to assess the door’s overall condition
  • Verification of the following:
    • The door can be opened fully and closed freely
    • Opening forces do not exceed maximums prescribed by the Code
    • Latching and locking mechanisms comply with the Code
    • Releasing hardware is installed between 34 in. and 48 in. above the finished floor
    • Doors installed in pairs comply with the Code’s releasing requirements
    • Door closers are properly adjusted
    • Projection of door leaf into egress path does not exceed Code maximums
    • Powered doors comply with Code requirements
    • Any required signage is intact and legible
    • Any special locking arrangements comply with Code requirements
    • Security devices that impede egress are not installed

The annual inspection was to be documented and kept for inspection by the AHJ. Further, any deficiencies were to be repaired or replaced “without delay.”

 

Fast-forward to the 2012 edition; the door inspection provisions were revised so that rather than applying to doors that swing in the direction of egress travel, they would apply to any of the following:

  • Doors equipped with panic hardware or fire exit hardware
  • Doors in exit enclosures
  • Electrically-controlled egress doors
  • Doors with special locking arrangements (delayed-egress locks, access-controlled egress doors, and elevator lobby door locking)

Further, a requirement for inspection and testing of smoke door assemblies in accordance with NFPA 105 was added.

 

The occupancies that mandated the 7.2.1.15 annual egress door inspection were:

  • Assembly occupancies
  • Educational occupancies
  • Day care occupancies
  • Residential board and care occupancies

This is where a bit of confusion comes in for health care occupancies. Since the 7.2.1.15 door inspection criteria is not referenced by either Chapter 18 or 19 for new or existing health care occupancies, respectively, does that mean doors in health care occupancies, including fire doors, are not required to be inspected? The answer is no, fire doors need to be inspected, regardless of occupancy classification or the lack of reference to 7.2.1.15. The inclusion of the reference to NFPA 80 (and NFPA 105) in 7.2.1.15 was well intended; it was supposed to remind users that, while you’re doing your required egress door inspection, if the door also happens to be a fire door, it needs to be tested and inspected in accordance with NFPA 80. In the 2012 edition, you get there via 8.3.3.1, which requires fire doors and windows to comply with NFPA 80, including its inspection and testing requirements.

 

This confusion got cleared up in the 2015 edition. The references to NFPA 80 and NFPA 105 were removed from 7.2.1.15 and moved to Chapter 8 – 8.3.3.13 requires fire door inspection and testing per NFPA 80 in all cases, and 8.2.2.4 addresses smoke door maintenance. Although most health care occupancies must comply with the 2012 edition, the revision in 2015 clarified the Code’s intent.

 

The 2015 edition added a couple other inspection items:

  • Verification of the presence of required door hardware marking
  • Verification of the presence and proper function of emergency lighting at access-controlled egress doors and doors equipped with delayed-egress locking systems

 

So what can you expect for the 2018 edition of NFPA 101, which will be released later this year? Not much has changed this time around with the egress door inspection requirements, other than some changes in terminology:

  • ‘Electrically controlled egress doors’ will be known as ‘electrically locked egress door assemblies’
  • ‘Delayed-egress locking systems’ will be known as ‘delayed-egress electrical locking systems’
  • ‘Access-controlled egress door assemblies’ will be known as ‘sensor release of electrical locking systems’

 

I hope you found this installment of #101Wednesdays to be informative. Now I have to figure out why there’s a red light flashing on and off on the (relatively newly installed) GFCI outlet in my kitchen. Buy a house, they said… It’ll be fun, they said… Good thing I know where the NEC guys sit at the office! Until next time, stay safe!

 

Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!

 

Did you know NFPA 101 is available to review online for free? Head over to www.nfpa.org/101 and click on “Free access to the 2015 edition of NFPA 101.”

Three construction workers died when they entered a manhole Monday without taking any of the precautions needed to safely enter a confined space. The hazards of the space were readily predictable and preventable. Many workers have died in manhole entries. Any one of several key confined space safe entry procedures likely would have prevented this tragedy.  

The incident occurred when a private contractor who was fixing a roadway in Key Largo climbed into a 15 foot deep hole to investigate complaints of sewage backups in the neighborhood. Reportedly the first man went in and lost contact with his coworkers above. The second worker climbed down in search of the first coworker and also lost consciousness. A third man then went down in a desperate search to find his two coworkers. A volunteer Key Largo firefighter attempted to rescue the downed workers and entered the space without an SCBA since the space was so narrow. He became incapacitated within seconds of entering. The space was later tested and found to contain elevated levels of methane and hydrogen sulfide as well as decreased oxygen levels. Atmospheric hazards in confined spaces are typically the result of material previously stored in the space, or in this case likely were the result of decaying organic material and rust.

While many news reports point to the lack of “air packs” being used as the problem, respiratory protection, such as self-contained breathing apparatus are the last line of defense to be used only after all other control measures are applied. They can rarely be used in spaces such as manholes due to the small configuration of the space.  

The real reason for this incident involved the lack of confined space entry procedures that would include;

  1. Recognition that this was a confined space and evaluation of the atmosphere using a calibrated gas monitor
  2. Identification of all hazards in the space and control of the atmospheric hazards using ventilation
  3. Issuance of a permit by the on-site entry supervisor that included rescue procedures

If the workers had recognized that the space was a confined space and used a properly selected and calibrated gas monitor, they would have known the space was unsafe to enter.   If the workers had identified the atmospheric hazard and used ventilation to remove the hazardous atmosphere, they would not have entered until the atmosphere was verified as safe to enter.   Finally, if confined space entry procedures were followed, an entry supervisor would have issued a permit that would describe the hazards and control measures for the entry and would have established a non-entry rescue procedure. A non-entry rescue procedure would require the first worker to enter the space with a harness attached to rescue equipment such as a tripod/winch system so that the attendant could remain outside the space and winch the first worker to safety should the worker become incapacitated or the atmosphere become unsafe. If the confined space procedures had been established, there would be no need for the second or third worker or the firefighter to enter for rescue. These basic requirements have been present in OSHA’s confined space regulation 1910.146 for over 20 years.  

In an effort to further improve confined space safety, and recognizing that confined space incidents continue to occur, the recommendations in NFPA 350 Practices for Safe Confined Space Entry and Work were established to provide more detailed information on “how to” implement the requirements in the OSHA standard. NFPA 350 explains how to select, calibrate and use the atmospheric monitoring equipment and how to ventilate a space depending on the hazard. Competencies are included for those performing various aspects of the confined space entry and a rescue procedures with pre-plans are established.  

For more information you may view NFPA 350 free of charge at www.nfpa.org/350. You will also find a free 5 minute video on confined space identification as well as information about on-line and instructor lead confined space training.  

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