This is the third in a series of articles that highlight and discuss changes that occurred in the 2015 edition of NFPA 101, Life Safety Code that affect egress, fire, and security door assemblies. You might find it helpful to read the first two installments of this series of articles before continuing. In order to understand the full context of the comments that follow, I recommend you refer to a copy of the 2015 edition of NFPA 101, Life Safety Code as you go through these articles. You can read NFPA 101 online through the NFPA web site (www.NFPA.org/101). Access to the online versions of NFPA’s publications is available (free of charge) to registered users of the NFPA web site.
In this installment we will be highlighting additional changes in Chapter 7, Means of Egress that affect door assemblies. Starting at the beginning of Chapter 7, a new definition for Fire Exit Hardware is listed as 126.96.36.199(13), which directs users to 188.8.131.52 in Chapter 3, Definitions; it states, “A type of panic hardware that additionally provides fire protection where used as a part of a fire door assembly.” (Note: This definition was modified from the 2012 edition.) The definition for Panic Hardware (184.108.40.206) remains unchanged from the 2012 edition of NFPA 101, it states; “A door-latching assembly incorporating an actuating member or bar that releases the latch bolt upon the application of a force in the direction of egress travel.”
It’s worth pointing out that the NFPA 101’s definition for Fire Exit Hardware varies from the definition found in the 2013 edition of NFPA 80, Standard for Swinging Fire Doors and Other Opening Protectives. NFPA 80 section 3.3.55 Fire Exit Hardware states, “Labeled devices for swinging fire doors installed to facilitate safe egress of persons and generally consisting of a crossbar and various types of latching mechanisms that cannot hold the latch in a retracted locked position.”
For those of us who are familiar with panic hardware and fire exit hardware these definitions do not fully describe the differences between the two categories of exit devices. In addition to permitting free egress like panic hardware, fire exit hardware devices are specifically designed to withstand the extreme temperatures and the stresses exerted on door assemblies under fire conditions; they are labeled for use on swinging fire door assemblies. As is the case in so many instances when studying and researching code (and standard) requirements, we need to refer to related sections in the codes and standards to gain a better understanding of the issue in question. In this case, NFPA 80
Section 220.127.116.11 contains the requirements for fire exit hardware (see the excerpt below):
Excerpted from NFPA 80, 2013
Notice that paragraph 18.104.22.168.3 expressly states that panic hardware “…is not acceptable for use on fire doors.” Additionally, paragraphs 22.214.171.124 and 126.96.36.199 in NFPA 80 address fire exit hardware devices. The latter paragraph states, “Fire exit hardware shall consist of exit devices that have been labeled for both fire and panic protection.” Spoiler alert! The reason for taking time here to discuss the differences between fire exit hardware and panic hardware will become apparent later in this article when we cover paragraph 188.8.131.52.2.
The next change that affects door assemblies, albeit indirectly, is found in Section 184.108.40.206 Floor Level. A new provision was added that address door assemblies where the floor on one side of a door assembly is lower than the other. Specifically, the new provision is applicable to rooms or spaces that are normally unoccupied, such as mechanical rooms, electrical equipment rooms, elevator pits, etc. Paragraph 220.127.116.11.7 states, “Where doors serve spaces that are not normally occupied, the floor level shall be permitted to be lower than that of the door opening, but shall be not more than 8 in. (205 mm) lower.” While this condition is not an element of a door assembly per se, the new provision recognizes that this condition exists in many types of buildings. In the context of safety inspections of door assemblies, this condition should not be cited as a deficiency as it is a necessary structural design element in these types of unoccupied rooms and spaces.
A subtle, but important change was made to the signage that is required for horizontal-sliding and vertical-rolling security grilles and door assemblies that are installed in a means of egress. Paragraph 18.104.22.168 (3) (b) requires signage with specific wording to be placed “…on or adjacent to…” these types of grilles or doors assemblies. The signage is required to state, “THIS DOOR TO REMAIN OPEN WHEN THE SPACE IS OCCUPIED.” (Note: Underlining is added to indicate the change in this provision.) The word “SPACE” replaces the word “OPEN” that appeared in the 2012 edition of NFPA 101.
The significance of this change might not be readily apparent to many users of the Code. Consider how tenant spaces within large buildings such as office buildings, hotels, malls, and other multiple-occupancy buildings are affected by this provision. Strict enforcement of the 2012 version of this requirement would require the security grilles and door assemblies to be in the open position when the building was occupied, even though the affected tenant space was not occupied. In other words, the tenant space would be required to keep the security grille or door assembly open when the business itself was closed. The new phrasing of the signage clarifies the intent of this provision.
Section 22.214.171.124.3 Door Leaf Encroachment addresses the issue of the projection of door leaves into the required width of corridors. Paragraph 126.96.36.199.3.1 was modified to state, “During its swing, any door leaf in a means of egress shall leave not less than one-half of the required width of an aisle, a corridor, a passageway, or a landing unobstructed, unless both of the following conditions are met:” The first condition requires the door assembly to provide access to a stair in existing buildings and the second condition requires the door assembly to “…meet the requirement of 188.8.131.52.3.2.” Paragraph 184.108.40.206.3.2 is entirely new for the 2015 edition, it states; “When fully open, any door leaf in a means of egress shall not project more than 7 in. (180 mm) into the required width of an aisle, a corridor, a passageway, or a landing, unless the door leaf is equipped with an approved self-closing device and is not required by the provisions of 220.127.116.11.2 to swing in the direction of egress travel.”
Let’s take a minute to examine this new provision more closely. The 7-inch dimension is the same dimension that has been in place for past several editions of NFPA 101, which was intended to address door leaves that were left in the normally opened position (e.g., automatic-closing doors) rather than in the closed position. Over the years, enforcement of this provision in the field has been problematic as Authorities Having Jurisdiction (AHJs) were left to determine which door leaves were subject to the 7-inch limitation—as well as where to take the measurement. The new provision recognizes that door leaves that are equipped with self-closing devices will be kept in the normally closed position, thereby rendering the projection of the fully-opened door leaves moot. The next part of the provision requires the AHJs to determine door leaves that are required to swing in the direction of egress travel from door leaves that are arranged to swing the direction of egress travel as matter of design and convenience to the occupants.
One additional comment regarding this new provision is the use of the term “approved” in conjunction with the self-closing device. Remember, in the context of NFPA codes and standards only the AHJs determine which products are approved. Many of the door leaves swinging to corridors, passageways, and landings are fire-rated, which require them to be self-closing or automatic-closing in accordance with NFPA 80. However, there are many non-fire rated door leaves (due to the nature of construction and occupancy) that might not otherwise be required to be self-closing or automatic-closing. In these cases, adding “…an approved self-closing device…” might be an acceptable means of resolving the issue of door leaf encroachment when it arises in the field. (Note: As always, consult with the respective AHJ for specific applications.)
The provisions for determining where to measure the projection of a door leaf, as well as what door-leaf mounted hardware is included in the measurement, remain the same as the 2012 edition.
Under the provisions for Delayed-Egress Locking Systems, Section 18.104.22.168, item (4) that addresses the required signage for these types of systems has been expanded to include two conditions. Item (4) (a) contains the old-familiar requirement that states, “PUSH UNTIL ALARM SOUNDS, DOOR CAN BE OPENED IN 15 SECONDS, for doors that swing in the direction of egress travel.“ New item (4) (b) states, “PULL UNTIL ALARM SOUNDS, DOOR CAN BE OPENED IN 15 SECONDS, for doors that swing against the direction of egress travel.“ (Note: Underlining added for emphasis.) Otherwise, the requirements for delayed-egress locking systems are unchanged from the 2012 edition. At the risk of stating the obvious, only the phases that are capitalized are required for the signage not the underlined portions of the above statements. (You know it’s going to happen…) Likewise, where the systems are approved for a 30-second delay, the phrasing of the signage would be changed accordingly.
The next change is found in paragraph 22.214.171.124.2, which addresses the application of fire exit hardware and panic hardware. (Refer to the top of this article for related comments.) For many years NFPA 101 explicitly restricted the application of panic hardware to non-fire rated doors and the application of fire exit hardware to fire-rated doors. Paragraph 126.96.36.199.2 states, “Only approved fire exit hardware shall be used on fire protection-rated door assemblies. New panic hardware and new fire exit hardware shall comply with ANSI/UL 305, Standard for Safety Panic Hardware, and ANSI/BHMA A156.3 Exit Devices.” The new phrasing retains the requirement for fire exit hardware to be installed on fire-rated door assemblies, which prohibits (albeit silently) the application of panic hardware on fire-rated door assemblies.
Additionally, there is a new annex comment (A.188.8.131.52.2) that states, “The presence of fire exit hardware on a door does not imply the door is required to be a fire protection-rated door.” I think this might be a particularly useful reference note and highlight in your copy of NFPA 101.
As discussed at the beginning of this article, NFPA 80 has additional requirements for the installation of fire exit hardware.
At first glance, the significance of this change might not be apparent. Under the provisions of the 2012 edition of NFPA 101, the discovery of fire exit hardware installed on non-fire rated doors during safety inspections of non-fire rated egress door assemblies would be cited as a deficiency. Many other types of labeled and listed door hardware components are routinely installed on non-fire rated door assemblies, the lone exception to this practice was the restriction of installing fire exit hardware on non-fire rated doors. Installing fire exit hardware on non-fire rated doors does not create a hazard to the building occupants, whereas installing panic hardware on fire-rated door assemblies does create a hazard.
Some of you, no doubt, work with turnstiles that are installed in the means of egress. There are a couple of changes in the 2015 edition of NFPA 101 that affect requirements for turnstiles. A new section 184.108.40.206.3, with accompanying annex comments, has been added to address modern-style security turnstiles with physical barriers that are installed in the means of egress. (This new section will be the subject of a separate article in this series, due to the lengthy set of new provisions.)
The title for Section 220.127.116.11 was changed from “Horizontal-Sliding Door Assemblies” to “Special-Purpose Horizontally Sliding Accordion or Folding Door Assemblies.” The purpose of this change is to reduce confusion for designers and AHJs between the types of sliding doors addressed in 18.104.22.168, such as sliding aluminum storefront door assemblies and the sliding accordion and folding doors that are required to be fire protection-rated (in some cases). The latter types of door assemblies are usually arranged for automatic-closing by smoke detectors or are self-closing. To gain a better understanding the differences between these types of door assemblies, refer to sections 22.214.171.124 and 126.96.36.199 respectively.
A minor change to Section 188.8.131.52.5.7 Door Hardware Marking is found in item (2) (a), it states; “The marking stripe shall have a minimum width of 1 in. (25 mm) and be applied to the entire length of the actuating bar or touch pad.” In the 2012 edition, the word “horizontal” preceded the word “width” in the statement—it was deleted, which does not materially affect this provision.
As near as I have been able to determine, the remaining changes in Chapter 7 Means of Egress do not directly affect egress, fire, and security door assemblies. Let me know if you discover a change that I missed.
Thank you for taking time to read this article. Keep an eye out for the next installment in this series of articles that highlight and discuss changes in the 2015 edition of NFPA 101, Life Safety Code that affect egress, fire, and security door assemblies. Let me know if there is a related topic that you would like to see in a future article.