My two-week hiatus from #101Wednesdays had me teaching the Life Safety Code Essentials seminar in Atlanta the first week, and on vacation last week (if you can call chasing a couple tweens around hot, crowded theme parks for five days a “vacation”) – both experiences contributed to today’s installment. (This was my view as I waited to enter one of said theme parks – woo hoo!)
It’s all about context.
It might seem rudimentary to some, but I see enough people trying to use the Code this way that it warrants a blog post. Let’s say you have an existing five-story building with two exit stairs, each enclosed with 1-hour fire barriers and 45-minute rated doors. You want to determine if this arrangement complies with the 2015 edition of NFPA 101, so you go to the index and look up ‘Enclosures, Exit’, which directs you to 18.104.22.168. There you see 22.214.171.124.1(3):
(3)*The separation shall have a minimum 2-hour fire resistance
rating where the exit connects four or more stories,
unless one of the following conditions exists:
(a) In existing non-high-rise buildings, existing exit
stair enclosures shall have a minimum 1-hour fire
Since your building is existing and you determine it does not meet the definition of ‘high-rise’, 1-hour enclosures are sufficient. So far so good. Now what about those 45-minute doors?
Back to the index and under the entry for ‘Fire door assemblies’ you find a reference to Table 126.96.36.199, Minimum Fire Ratings for Opening Protectives in Fire Resistance-Rated Assemblies and Fire-Rated Glazing Markings. The table provides the minimum fire protection ratings for opening protectives in fire barriers having various fire resistance ratings and applications. In the row for ‘Vertical shafts (including stairways, exits and refuse chutes)’ and 1-hour walls and partitions, you find an entry indicating 1-hour fire door assemblies are required. Looks like those 45-minute rated doors need to be replaced with 1-hour doors. In a five-story building with two stairs, you’re looking at something like ten doors – not necessarily an inexpensive proposition.
Or are you? This example is based on an activity the students complete in the seminar, and about nine times out of ten, this is the answer they come up with. My response is always, “You can’t use the Code with blinders on. How did you get to Table 188.8.131.52?” In many cases it’s via the index. However, the index is only informational; it points to relevant Code sections. There is nothing mandatory about the index. A table or figure in an NFPA code means nothing until a mandatory code paragraph sends you to the table or figure – typically the paragraph with the corresponding number. If you look at paragraph 184.108.40.206, you find:
220.127.116.11* The fire protection rating for opening protectives in
fire barriers, fire-rated smoke barriers, and fire-rated smoke
partitions shall be in accordance with Table 18.104.22.168, except as
otherwise permitted in 22.214.171.124 or 126.96.36.199.
This is the mandatory requirement that tells you opening protectives need to meet the ratings provided in Table 188.8.131.52. But what about, “except as otherwise permitted in 184.108.40.206 or 220.127.116.11?” Let’s take a look:
18.104.22.168 Existing fire door assemblies having a minimum
3⁄4-hour fire protection rating shall be permitted to continue
to be used in vertical openings and in exit enclosures
in lieu of the minimum 1-hour fire protection rating required
by Table 22.214.171.124.
We can stop there, because 126.96.36.199 gives us the answer: existing ¾-hour, or 45-minute fire door assemblies are permitted in existing 1-hour exit enclosures. If you went straight to Table 188.8.131.52 without looking at paragraph 184.108.40.206 (and subsequently 220.127.116.11), you might have needlessly spent a bunch of money replacing a bunch of perfectly acceptable fire doors without gaining a whole lot of additional protection. Don’t read the Code with blinders on. Look at every requirement in context.
Here’s another example, based on a question I had in the office yesterday. You want to determine if your new building needs elevator lobbies, so again, the index entry for ‘Elevator lobby’ points to 18.104.22.168:
22.214.171.124 Elevator Lobby. Every floor served by the elevator
shall have an elevator lobby. Barriers forming the elevator
lobby shall have a minimum 1-hour fire resistance rating and
shall be arranged as a smoke barrier in accordance with Section
Looks like you’ll be constructing rated elevator lobbies with rated doors on every floor level. But are they really needed? If you look at the heading of 7.2.13, it reads, “Elevators in Towers.” The provisions of 7.2.13, including 126.96.36.199, are specific to elevators serving as a second means of egress from towers, such as airport traffic control towers. This is a unique application and elevator lobbies are not generally required by NFPA 101 in typical buildings. Again, applying a code provision out of context could have unnecessarily cost a lot of money.
And what does all this have to do with my vacation? On the plane ride home, I watched “La La Land.” Remember the movie that won the Oscar for Best Picture for about 90 seconds? Despite Warren Beatty's obvious befuddlement, he let Faye Dunaway read what was on the card: “La La Land.” But the card also said “Emma Stone,” and at the bottom in teeny-tiny print it read, “Best Actress.” Oops. You’ve got to read the fine print. Don’t put blinders on. Think of the big picture (not the Best Picture - that's different).
It’s all about context.
(By the way, I highly recommend “La La Land.” It probably deserved to be Best Picture for at least two minutes.)
Thanks for reading. 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.”
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