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Fire doors

Question asked by markh on Mar 20, 2018
Latest reply on Apr 6, 2018 by upnorth

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I have recently come across a situation in a 4 story apartment building with 18 apartments and the landlord has taken it upon himself to have someone install sliding bolt locks on most of the stairway exit/fire doors (at the floor) allowing them to remain propped open.

I see this as a fire/safety hazard and found a section in NFPA 80 regarding blocking and or wedging doors but I need some input on this.

Can anyone chime in and help with some other black n white hard evidence?

I don't currently have any pictures of the door, but they are single doors, self closing devices on each.

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milt.werner Mar 20, 2018 1:53 PM
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Hi Mark:

No matter what the life safety code provides evidence today. Based on the scope and severity to the safety of the residents, this is a serious violation and must be reported to your local fire marshal immediately for immediate action.

Are you the local fire marshal?

In terms of 2018 NFPA 101, Life Safety Code this violates Section 7.1.3.1 (8) Exits

........
........

Let me know that you reported it to the local authorities.

Respectfully,
Milt Werner
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- markh @ milt.werner on Mar 21, 2018 9:07 AM
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  Thank you Milt and cdafd
  I am not a Fire Marshall, but it has been reported to the proper authorities and I am taking action as well.
  I am a Housing Inspector for a Local HUD office and this is the first time I have come across this and needed some assistance.
  Thanks again!
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  - cdafd @ markh on Mar 21, 2018 2:11 PM
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    Good catch
    
    Thank you for doing your job.
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cdafd Mar 20, 2018 3:55 PM
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Have to love stupid, except where it kills someone.

As stated ted talk to someone in the city till you get action

Or are you the City ???
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rfdacm02 Mar 22, 2018 9:51 AM
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We've come across similar cases, and as Milton indicates, it's a serious violation. My FD will remove fold down legs, take wedge or otherwise ensure the door works properly before leaving a building or require the work be done immediately by onsite personnel. On of the other issues that is directly related is the doors not closing with enough force or due to mis-alignment not latching. Rated doors must be self-closing and self-latching. This ensure the increased air pressure (from heat of a fire) cannot/will not open a door and pollute the means of egress.
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milt.werner Mar 22, 2018 10:15 AM
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Hirfdacm02 :

Its interesting to note that the door closing requirements of NFPA 101 I referenced do not mention self-latching. You have to reference the section of NFPA 101 requiring compliance with NFPA 80 to cite the self-latching requirements. A real pain in the **** for those that have to document references to codes and standards for an inspection citation.

I can see how markh got all tied up finding the correct references.

Respectfully,
Milt Werner
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- rfdacm02 @ milt.werner on Mar 24, 2018 10:12 AM
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  Whoops, I did jump a bit without fully going through what you'd posted. My bad. Here's the citations:
  
  So with regard to a corridor that serves as exit access: 30.3.6.1 and 31.3.6.2.3 Doors that open onto exit access corridors shall be self-closing and self-latching.
  
  There may be some question if a stairwell is an exit access corridor, and our interpretation is that , yes, it is. Looking at the intention- to prevent smoke, heat and toxic gases from moving from the fire area to the clean area a door with a latch should close such to engage the latch as building air pressure (from the heat) can and will open doors. Being that common area entry doors into individual apartments in 99.99999% of cases will have latches, they need to engage on their own. Common stairwells are some of the most important areas to protect from heat, smoke and gases.
  
  Additionally, NFPA 80 - 4.3.7 Access-type door assemblies shall consist of single swinging doors with frames, self-latching devices, and closing mechanisms.
  
  Thus a 1 hour rated access door must be NFPA 80 compliant and therefore self-closing, self-latching.
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vincent.quinterno Mar 22, 2018 11:35 AM
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Mark, before you proceed with any action, you must first go to the occupancy chapter related to this case. Focusing on just the condition, may not be a problem, you need to find out how your particular situation can be addressed. Depending on the edition of the code your jurisdiction has adopted, some of the materials here may have been renumbered. In Rhode Island, we have adopted the 2012 Edition of NFPA 1 & 101. Related to your particular question, chapter 31 for existing apartments is where I started. Once in this chapter, 31.2.2 Means of Egress Components is your first stop. Followed by 31.2.2.2 Doors, (references Chapter 7, section 7.2). Chapter 31.2.2.2.1, 31.2.2.2.2., 31.2.2.2.2.1. Chapter 7, specifically 7.2 references 7.2.1.5 Locks, Latches, and Alarm Devides. This will reference 7.2.1.5.1 & 7.2.1.5.3. Following this progression from the occupancy chapter, along with any other supporting relevant code citings, will provide both you and the owner, your legallly supporting documentation to not allow these additional devices per code. NFPA 80 may also also state that, unless otherwise approved and tested for that application, no other device(s) shall be placed upon an approved fire door and assembly. Keep up the great work and Best of luck in the future. .

Stay Safe
Vinny
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milt.werner Mar 22, 2018 3:02 PM
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I totally agree with vincent.quinterno that "where in the code" does the requirement for exits for applying Section 7.1.3.2.1.

To help understand how use NFPA 101, an excerpt from the preface to the code.

According to the original post the exits were observed ("stairway exit/fire doors"). They are there; so the exits was no question.

So to fill the gap in the chain of the code requirements I present the following.

This section of the 2012 NFPA 101 code requires the means of egress to comply with Chapter 7. No excemptions were provided in Chapter 31.

Excerpts are from the 2012 NFPA 101, Life Safety Code
This section requires exits for existing apartment occupancies.

Exits are defined in the 2012 edition.

Citing NFPA 80 does not provide requirements for the exits. It is an installation standard for the fire doors referenced by the principal codes.

Along with citing references to 31.2.4.2 and 31.2.4.3, I concur that the reference to Section 7.1.3.2.1 was appropriate for the observation and circumstantial evidence of the original post. There were no findings given in the original post of the fire doors not latching to frame when operated from the open to the closed position.

In addition, the stairways are vertical openings and must be enclosed.
Here is were the NFPA 101 requires fire barriers. There were no findings in the original post other than the illegitimate bolts not allowing the doors to self-close.
Excerpt for opening protection in fire barriers.
Therefore, this serious code violation was two-fold. Protection of an exit for means of egress and the vertical spread of fire between the floors was violated by the bolt holding the fire doors open essentially voiding the self-closing action of the door.

Respectfully,
Milt Werner
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fireman Mar 23, 2018 1:22 AM
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A very good source for information on fire doors is http://idighardware.com/
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markh Mar 23, 2018 8:43 AM
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Thanks all for the input, it is greatly appreciated!! cdafd milt.werner rfdacm02 vincent.quinterno @douglas.hicks
I have looked at all of those sections as well as NFPA 80, 5.1.2.3 Prevention of door blockage, 5.1.2.3.3 Blocking or wedging of doors in the open position shall be prohibited.
Section 6.1.3.2.1 Self-closing doors shall swing easily and freely and shall be equipped with a self-closing device to cause the door to close and latch each time its opened.

With just those sections alone I can proceed on my end to ensure the owner corrects the situation.

As I am not fire department personnel anymore, (I served 6 years and because of back issues I could no longer perform the duties). I am a Housing Inspector for HUD's Section 8 voucher program and my job is to ensure that each unit/building under the program meets certain HUD guidelines (which has a lot of grey areas).

But again I greatly thank you all for the input.
Markh
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milt.werner Mar 24, 2018 5:07 PM
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Hi rdacm and Vincent:

Somehow the discussion has been sidelined and evolved to the review of corridor and access doors and door latching requirements.

The access type doors of NFPA 80 - 4.3.7 are defined in the 2016 NFPA 80. Don't know if this was the doors that Mark referred to in his original post
Quoted from the original post.
Mark wrote:
"...someone install[ed] sliding bolt locks on most of the stairway exit/fire doors (at the floor) allowing them to remain propped open..."

All my posts were based on that information and my interpretation of it.

I interpreted his statement as the building has unprotected vertical openings and exit enclosures as a result of the doors being propped open by sliding bolt locking the door onto the floor.

I agree with Vincent that you must look at the occupancy and the fundamental chapters of NFPA 101 to have a legal citation. I added the NFPA 101 sections that I thought were applicable. You cannot just jump to NFPA 80 without some prior referencing from NFPA 101.

To clarify the NFPA 101 sections for exit requirements and the vertical openings of the occupancy chapter has a path to NFPA 80 for the requirements for protecting openings in the barriers.

Respectfully,
Milt Werner
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- rfdacm02 @ milt.werner on Mar 26, 2018 8:14 AM
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  Yes, it's easy to go sideways in these. We went from the specific question to covering any door opening in the stairway. What I think has been shown throughout is that any self-closing door into a stairway needs to remain self-closing with the proper force to self-latch.
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- markh @ milt.werner on Mar 26, 2018 9:12 AM
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  Thanks Milt, There are a lot of interpretations of the codes but in my shoes and my prospective this is what I see:
  1. The building has a total of 3 exits, one on side A, 1 one side B/C of the structure and one on C/D of the structure.
  2. All exits lead from the hallways of the propped open fire doors.
  3. Emergency lighting in 3 of the stairway is non-operational
  4. All fire extinguishers either have no inspection tags or are expired
  
  3&4 were not originally mentioned because they are self explanatory.
  
  So if a fire occurs on any floor or in any corridor and the required fire doors are propped open with non-self releasing latches that is a fire/safety hazard and under HUD's rule and our inspection protocol which states:
  8.6 Interior stairs and common hallways;
  Are they free from hazards to the occupants because of loose, broken or missing steps on stairways; absent or insecure railings,; inadequate lighting; or other hazard?
  Yes it's a very vague description but that's HUD for you and that's what I have to go by and then conduct my research as to why or what the "other hazard" is.
  
  If anyone is interested the whole HQS "Housing Quality Standards" can be found on the HUD.gov website.
  rfdacm02 vincent.quinterno cdafd @douglas.hicks
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  - cdafd @ markh on Mar 26, 2018 9:27 AM
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    Or use 8.7 to enforce NFPA 80, or local fire code, that also covers fire doors:
    
    Not sure if this is the current generic check list::
    
    https://www.hud.gov/sites/documents/23021_ANNUALSHELTER-HQS.PDF
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  - upnorth @ markh on Apr 6, 2018 7:26 PM
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    Mark: If you're looking at exit lighting, don't forget that "designated exit components" must be illuminated at all times during which the building is occupied, although some types of motion sensors are allowed. This has historically been a separate issue from "emergency lighting", which is generally only activated during a power outage. The NFPA 101 (2015) requirements for "egress" and "emergency" illumination have grown somewhat closer together, such as where those allowable "motion sensors" must now also activate the lighting during a power outage or fire alarm. 101:7.8.1.2.2.
    
    Also, if you wanted to be a stickler on the fire-door bolting violation, those unauthorized "field modifications" to the doors may have also violated the warranty and the listing/labeling specifications on those assemblies. You could ask the property owners to submit an engineer's statement about whether any field repairs are necessary and how they can be done adequately and safely to restore the fire resistance to an acceptable level. A similar question arose when a school facilities director in a local jurisdiction decided to replace all of the self-closers on the fire doors, without regard to any manufacturers' criteria for drilling new holes in the frames and doors. It raises the question of how much damage a fire-rated assembly can endure without exceeding any essential testing parameters.
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