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 188.8.131.52 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 184.108.40.206 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 220.127.116.11 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 18.104.22.168. The inclusion of the reference to NFPA 80 (and NFPA 105) in 22.214.171.124 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 126.96.36.199, 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 188.8.131.52 and moved to Chapter 8 – 184.108.40.206 requires fire door inspection and testing per NFPA 80 in all cases, and 220.127.116.11 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.”