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2 Posts authored by: rcote Employee
What Percentage of Fire Door Assemblies Fail the Required Yearly Inspection?
As part of the process through which NFPA staff provides answers to technical questions received from members and AHJs, one stakeholder recently asked about compliance rates for fire door assemblies inspected yearly, as required by NFPA 80, Standard for Fire Doors and Other Opening Protectives. I took the question to mean: “What percentage of fire door assemblies fail the required yearly inspection?” 
In my mind, the inquiry asks the wrong question; even if I had the statistics requested, providing them would not be helpful. A fire door assembly can fail the inspection if any of scores of elements/features have anything wrong with them. The failure of some of those features should carry a heavier weight than others, but they don’t; a violation is a violation; any violation fails the fire door assembly. Thus, we are hearing fire door assembly inspectors say things like ___% fail the inspection (I’m leaving it to others to fill in the blank, but I’m often hearing numbers as high as 50, 60, 70, or even 80 percent). 
Consider three examples of violations that have differing importance:
  1. Some metal plates for attaching the arms of a hydraulic door closer to the top jamb/soffit are fabricated with five pre-drilled holes for the passage of screws for attaching the plate; very often one of those holes does not have a fastener; a missing fastener is a violation; such violation fails the fire door assembly. The deficiency can be repaired, almost immediately, using readily available tools, like a drill and screwdriver, and readily available parts, like screws matching those provided by the manufacturer of the closing device. The repair takes almost no time and can be performed without disassembling the fire door. The door assembly can then be removed from the failures portion of the report or, perhaps, not added to the failures report in the first place, especially if the facility performs a pre-inspection prior to the required yearly inspection or has an effective on-going maintenance program.
  2. A door leaf has sagged, within its frame, such that the clearance is excessive between the top edge of the latch stile and the rabbet at the top of the frame. Relatedly, the clearance is excessive between the upper portion of the edge of the hinge stile and the rabbet at the side of the frame. The clearance violations can be corrected by installing steel shims behind portions of one or more of the hinges. Effective shimming takes considerable skill; the facility has no one on staff who can successfully accomplish the needed shimming; a professional will be brought in to perform the work. The violation cannot be immediately corrected; such condition must be reported as a failure. Had the facility performed a pre-inspection or had an effective on-going maintenance program, the condition could have been noted earlier and corrective action taken so the door would pass the required yearly inspection.
  3. A fire door assembly has a door leaf that is so warped that the door leaf face is not in alignment with the face of the door frame, meaning that some portion of the latch stile doesn’t contact the stops built into the frame. The gaps are noticeable and, obviously, the fire door assembly will not prevent fire from getting to the unexposed side. The door leaf, at minimum, and perhaps the door frame, must be replaced. Based on availability of a door leaf that meets the facility’s needs, the violation might not be able to be corrected for days or weeks. Such condition must be reported as a failure on the inspection report. Remedial action must commence immediately.
Rather than asking for a statistical report of the overall failure rate of fire door assemblies inspected, a more useful request might be: What percent of the fire door assemblies in a facility would fail a re-inspection conducted a few days after the initial inspection? This would help weed out the noise created by minor violations in contrast with violations that your gut feeling tells you might keep the fire door assembly from performing as intended under fire conditions.
Such question could help to ensure that inspection reports get utilized immediately to commence remedial action, especially for minor issues that might have been avoided by an effective maintenance program or if pre-inspections had been conducted. Where a facility ignores the inspection report and does not immediately correct the violations that are easy to correct, all violations will be considered to carry equal weight. Together, the violations might place the facility into serious non-compliance.

The full video is available for free here when logged into Xchange.

 

Fire barrier walls and fire door assemblies carry a fire rating. Fire barrier walls receive a fire resistance rating based on fire testing in accordance with ASTM E119 or UL 263. Fire door assemblies receive a fire protection rating based on fire testing in accordance with NFPA 252, UL 10B or UL 10C.

 

The terms ‘fire resistance rating’ and ‘fire protection rating’ are different and not interchangeable as fire barrier walls are held to a different performance level than fire door assemblies. For example, in the fire test for walls, there is a failure point where too much heat is transmitted through the wall, to the unexposed side, establishing the potential for the ignition of combustible contents. In the fire test for doors, there is no criterion for limiting heat transmission through the door as combustibles should not be stacked against the door.


Some fire door assemblies are tested like walls. Where the door assembly meets all the fire test criteria applicable to walls, the fire door assembly receives a fire resistance rating and can be used to satisfy code requirements for a wall. Regardless of whether the fire door assembly carries a fire protection rating or a fire resistance rating, it must be inspected, tested, and maintained in accordance with the applicable standards.

 

Relative to health care occupancies, the Centers for Medicare and Medicaid Services (CMS) require compliance with the 2012 edition of NFPA 101®, Life Safety Code® as a condition of participation in the Medicare and Medicaid Programs. NFPA 101-2012, in turn, requires fire door assemblies to be installed, tested and maintained in accordance with NFPA 80-2010, Fire Doors and Other Opening Protectives. NFPA 80 requires fire door assemblies to be inspected and tested yearly.

 

Not all doors in a health care occupancy are required to be fire rated. So, do you know how to determine if a door is required to be fire rated? Whether an existing door assembly is fire rated? Whether the fire-rated door is code-compliant? If a wall is required to be fire rated, the doors in that wall are typically required to be fire rated. But there are exceptions to every rule. For example, a health care occupancy smoke barrier is required to be fire rated, but the cross-corridor smoke barrier doors are not required to be rated as it is important, for day-to-day function, that the door not have a latch. All fire protection-rated door assemblies are required to be latching.


To ensure an efficient review of fire-rated doors, it’s important to prepare an inventory of all the fire-rated doors in your facility; conduct the yearly inspection and testing of those doors; perform any required maintenance; and prepare and retain records. It is these records that CMS or accreditation agency surveyors will require you to produce at time of survey.

 

For more detailed information on fire door ratings, watch the full video clip for free when you login or register for NFPA Xchange. It was taped during a one-day NFPA 101/NFPA 80 training hosted by NFPA and the Door Security & Safety Foundation (DSSF). Additional trainings, to be held in the coming months, will address the following issues:

 

•    door types encountered in a health care facility
•    door locking means permitted
•    thirteen verification points required for the yearly inspection of swinging fire door assemblies
•    the skills required to serve as the qualified person permitted to perform inspection and testing in accordance with NFPA 80

 

Here are the dates: 
March 6, 2017 - NFPA Headquarters, Quincy, MA
May 15, 2017 - NFPA Headquarters, Quincy, MA
July 10, 2017 - NFPA Headquarters, Quincy, MA
October 5, 2017 - NFPA Headquarters, Quincy, MA
December 4, 2017 - NFPA Headquarters, Quincy, MA

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