This article is the third in a series of articles dedicated to the changes in the new NFPA 80. You may read these articles in any order, but the first article includes some helpful tips for accessing NFPA 80 online. Changes in Chapters 1 through 4 are covered in the first two articles. Tips for highlighting your copy of NFPA 80 are also in the first article.
Chapter 5 Inspection, Testing, and Maintenance is next on our list changes in the new NFPA 80. Chapter 5’s requirements apply to most of the opening protectives covered in NFPA 80. The exceptions are Chapter 19 Inspection, Testing, and Maintenance of Fire Dampers, Chapter 20 Fabric Fire Safety Curtains, and Chapter 21 Fire Protective Curtain Assemblies—these chapters include inspection, testing, and maintenance requirements for their respective types of opening protectives.
Changes in Chapter 5 include the following provisions for:
- Prevention of Door Blockage
- Field Labeling
- Repairing Holes in Doors and Frames
- Documentation of Maintenance Work
Prevention of Door Blockage
Section 5.2.13 Prevention of Door Blockage (in the 2010 edition) was inadvertently deleted during the 2013 revision process. Its deletion was an unintentional consequence of revising and reordering Chapter 5’s content at that time. Accordingly, it returned under Section 18.104.22.168 Provision of Door Blockage in the 2016 edition of NFPA 80. The content of 22.214.171.124 is identical to the earlier editions; it’s included below for your convenience:
“126.96.36.199.1 Door openings and their surrounding areas shall be kept clear of anything that could obstruct or interfere with the free operations of the door.
188.8.131.52.2 Where necessary, a barrier shall be built to prevent the piling of material against sliding doors.
184.108.40.206.3 Blocking or wedging of doors in the open position shall be prohibited.”
Field labeling of existing door assemblies is one of the hot topics in today’s industry. Who is allowed to perform this service? How are the door assemblies evaluated? When is field labeling feasible versus replacing components or complete assemblies? Questions like these are common.
Applying new fire door (and door frame) labels in the field is a long-standing industry-practice. The nationally recognized testing laboratories (e.g., Underwriters Laboratories, Intertek/Warnock Hersey, and FM Global) offer field labeling services. Recently, other lesser known, but up and coming, testing labs like QAI Laboratories have established field labeling services. Other sources for field labeling can be found in some regions of the United States. One of the newest field labeling providers is a company called Fire Door Solutions, LLC. As we’ll see in a minute, NFPA 80 requires field inspectors to provide “…proof of qualifications to the authority having jurisdiction…”
Regardless of which field labeling service is used, the process is essentially the same. (Although the process is essentially the same, some field labeling providers might apply more stringent standards and inspection criteria than others.) It begins with a formal request for a field inspection. Field inspectors arrive on site to evaluate the door assemblies. Their assessment includes meeting NFPA 80’s requirements, the applicable building/fire code requirements, and the manufacturer’s listings for the door frames and doors. Door assemblies that do not meet the minimum requirements for fire doors might need to be repaired before a field label can be applied. In some cases, the existing door assemblies cannot be repaired and need to be replaced.
Perhaps the most important point to remember regarding field labeling of existing fire door assemblies is that the entire assemblies are being evaluated, not just the door frames or the doors. Swinging doors with builders hardware (see NFPA 80, Chapter 6) are component-based systems. Each component is required to be labeled or listed for use on fire door assemblies. These labels are applied at the factories or in authorized shops before arriving on site.
Once the assemblies are installed, all of the components must be properly maintained. When any one of the required components is missing, broken, damaged, or malfunctioning the fire rating of the assembly is considered invalid. As simple as it might sound, a field inspector might not be able to replace a label on a door frame or door when the other components don’t meet the requirements for the assembly. For example, a door leaf might be in acceptable condition but if it doesn’t reliably close and latch the field inspector cannot apply a new label until the function of the assembly is corrected. Door assemblies that need new door frame or door labels should be inspected and repaired before the field labeling process is started.
Cost is another dynamic that needs to be considered before procuring field labeling services. In some cases, it might be more cost-effective to replace an entire assembly than to have it field labeled. There is no guarantee that the field labeling provider will be able to apply new labels during their first on site visit. When door assemblies require additional repair work, the field labeling provider might need to make another trip to verify the assembly has been repaired. Field labeling is most cost effective when the door assemblies are in good condition, but the original labels have been painted over or removed. In these cases, it is more likely that the field labeling provider will be able to apply new labels to the door frames and doors.
Section 5.1.4 Field Labeling contains new provisions and requirements that follow the industry-practice for applying labels in the field. Paragraph 220.127.116.11 requires field labeling services to “…be performed only by individuals or companies that have been certified or listed, or by individuals or companies that are representatives of a labeling service…” Even the testing labs are subject to meeting stringent standards in order to perform their services.
Paragraph 18.104.22.168 requires the field inspectors to provide the AHJs with proof of their qualifications. It should be pointed out that this requirement does not expressly state that the AHJs need to approve the field inspections and labeling. However, AHJs should be consulted before procuring field labeling services. They might not accept field labeling from all providers.
Like we saw in Chapter 4 for other types of door frame and door labels, NFPA 80 requires certain information to be printed on the field labels. Paragraph 22.214.171.124 lists the minimum information needed on field labels.
It states, “At a minimum, field labels shall contain the following information:
- The words “field inspected” or “field labeled”
- The words “fire door” or “fire door frame”
- The marking of a third-party certification agency
- The fire protection rating
- A unique serial number (if provided by the listing agency)
- The fire test standard designation to which the assembly was tested”
The next three paragraphs in this section refer to field modifications, but cover points that are directly related to field labeling of door assemblies.
“126.96.36.199 Field modifications shall not be permitted to be made to a non-fire-rated door assembly to achieve a fire rating unless the field modification is completed under label service.
188.8.131.52 Doors in which a field modification in accordance with 184.108.40.206 has been completed shall be labeled.
220.127.116.11 When an opening with a non-fire-rated door requires a fire door, the door assembly shall be replaced.”
The first condition covered in 18.104.22.168 provides for the possibility of converting a non-fire-rated door assembly into a fire-rated door assembly when the work is completed “…under label service.” Remember, label service entails using companies (e.g., distributors of doors) who are authorized (licensed) to perform modification work by the specific manufacturer(s) of the product(s) involved. These companies also subscribe to the policies and procedures of one of the nationally recognized testing laboratories. In most cases, modification work is required to be performed in the service company’s shop, not in the field. When field modification work is necessary, it needs to be approved under the provisions of paragraphs 22.214.171.124 and 126.96.36.199 under the Field Modifications section.
Most service companies are not authorized to field label fire door assemblies.
Paragraph 188.8.131.52 requires door assemblies that were field modified in accordance with 184.108.40.206 to be labeled. When modification work is completed, the field labeling process begins. Ideally, the field labeling service is provided by the same testing lab that approved the modification work, but that is not required by NFPA 80.
Fire door assemblies, other than swinging doors with builders hardware, are unit-based systems. The label on the door covers all of the assembly’s components. For example, rolling steel doors have a label that covers the curtain, track, rollers, guides, springs, cables, anchors, and closing mechanism. Paragraph 220.127.116.11 requires the entire assembly to be replaced when an opening with a non-fire-rated door needs to be fire-rated. In other words, when the field modification work allowed by 18.104.22.168 does not result in converting a non-fire-rated door assembly to a fire-rated assembly, the entire assembly must be replaced.
Because swinging doors with builders hardware are component-based systems, it is more likely that they can be successfully converted from non-fire-rated to fire-rated assemblies in accordance with 22.214.171.124. For instance, a non-fire-rated door leaf can be replaced by a fire-rated door leaf. When necessary, the hardware components can be upgraded (e.g., replacing plain bearing hinges with ball bearing hinges or adding latching hardware and door closers) to meet code requirements. Some field modification work might be necessary (e.g., adding a strike prep to the existing door frame) to accommodate the new hardware. In this scenario, the new door leaf and hardware items are individually labeled or listed, but the modified door frame needs to be field labeled in order for the fire rating of the assembly to be valid.
Mark the following corrections in your copy of NFPA 80: Turn to paragraph A.126.96.36.199 (under Annex A). Notice that the first paragraph is nearly identical to A.188.8.131.52 that appears directly below. Apparently, the annex was not edited completely during the last revision cycle. Strike out paragraph A.184.108.40.206 and change the number of A.220.127.116.11 to A.18.104.22.168. Go back to paragraph 22.214.171.124 and strike out the asterisk (*)—there is no annex comment for this paragraph.
Now that you made the corrections to your copy of NFPA 80, turn back to the newly labeled A.126.96.36.199—the second paragraph is new to the 2016 edition of NFPA 80. This annex comment explains that replacing hardware items on swinging doors with builders hardware is not considered field modification work. The annex comment also lists several examples of work that are field modifications. Earmark this comment so that you can find it quickly when questions regarding maintenance and field modification work come up.
Repairing Holes in Doors and Frames
Moving on to the next change, paragraph 5.5.7 under the Maintenance section includes a new provision for the use of listed materials to fill-in fastener holes in door frames and doors. The word “fastener” was inserted before the word “holes” in the main statement to clarify the types of holes addressed under this provision.
“5.5.7 When fastener holes are left in a door or frame due to the changes or removal of hardware or plant-ons, the holes shall be repaired by one of the following methods:
1. Install steel fasteners that completely fill the holes.
2. Fill the screw or bolt holes with the same material as the door or door frame.
3. Fill holes with material listed for this use and installed in accordance with the manufacturer’s procedures.”
(Note: Underlining added to highlight new content.)
Paragraph 5.5.8 is new, it requires the repair of non-fastener holes in doors and frames to be “…treated as a field modification in accordance with 5.1.5.”
Mark the following correction in your copy of NFPA 80: Change the referenced section at the end of the statement in 5.5.8 from 5.1.4 to 5.1.5.
Fastener holes are usually less than ½ in. (12.7 mm) in diameter, but some might be larger (e.g., holes for sex nuts). When fastener holes in hollow metal door frames and doors need to be filled, the most expedient method is to fill the holes with steel fasteners. Once the fasteners are installed, the exposed heads of the fasteners can be ground flush with the surface of the frame or door.
Item 2 allows the holes to be filled “…with the same material as the door or door frame.” This method was originally intended to repair mineral core wood fire door doors. Some remedies include filling the voids with drywall compound held in place with wood dowel pins that completely fill the diameter of the holes. (Note: Before attempting repairs of this nature, contact the manufacturer of the door or the testing lab listed on the label for their recommendations.)
Item 3 recognizes the introduction of new products that are designed specifically for repairing fire doors and frames. One such product is called Fire Door Caulk; it is designed to fill fastener holes up to ¾ in. (19 mm) diameter in wood fire doors. This particular product is not intended to be used to fill holes in hollow metal door frames or doors. (Note: Before using these types of products, contact the manufacturer confirm their product’s capabilities—review the product’s listings and follow all application instructions.)
Holes larger than ¾ in. (19 mm) in diameter or square, rectangular, or irregular shaped holes (of any size) are required to be repaired in accordance with Section 5.1.5 Field Modifications as required by paragraph 5.5.8.
It’s worth pointing out that 5.5.7 and 5.5.8 do not recognize the use of cover plates to conceal holes in door frames and doors. Frequently, cover plates are used to conceal (not fill) holes left in doors after the locking/latching hardware has been changed out. Even cover plates made from stainless steel cannot be used on fire doors, unless they are tested and listed for use on fire doors (and, specifically to cover holes in doors).
Remember, Section 5.5 Maintenance applies to all types of fire door assemblies covered in NFPA 80. Certain repair methods might be acceptable for some, but not all, fire door assemblies. Best practice is to contact the manufacturer(s) of the door frames and doors before making repairs such as these, as required by 188.8.131.52.
Documentation of Maintenance Work
Since the 2007 edition of NFPA 80, formal documentation of the periodic safety inspections of fire door assemblies has been required. These inspection reports list deficiencies found during the safety inspections that need to be corrected. Paragraph 5.5.9* of the new NFPA 80 requires the maintenance work performed on fire door assemblies to be recorded in accordance with Section 5.2.3 Acceptance Testing and paragraph 5.2.2 under Inspection and Testing. (Read paragraphs 5.2.2 through 184.108.40.206.)
Annex A paragraph A.5.5.9 recommends that fire door assemblies “…should be inspected and tested immediately upon completion of the repair work…” The reason for this additional level of reporting should be obvious, we need to confirm that the repaired fire door assemblies comply with NFPA 80, their listings, and the applicable code requirements.
Acceptance testing of fire door assemblies is required when they are first installed (see paragraphs 5.2.1, 220.127.116.11, and 18.104.22.168), whether they are installed during new construction or as part of a renovation project. Once installed, fire door assemblies are subject to the ongoing periodic safety inspections that are required under Section 5.2.4 Periodic Inspection and Testing. The maintenance reports required by 5.5.9 show the AHJs that the deficiencies cited during the safety inspections were corrected and the affected assemblies comply with NFPA 80.
Acceptance testing records, including those required by 5.5.9, are required to be retained for the life of the individual assemblies (see 22.214.171.124).
Maintenance reports of 5.5.9 are required a minimum amount of information, ranging from the date the maintenance work was completed to a description of the work that was done. (See items (1) through (10) in paragraph 5.5.9.)
Annex A paragraph A.5.5.9(10) explains why the maintenance reports are necessary. It also recommends that field modification work that was “…permitted by the laboratory, in accordance with 126.96.36.199 and approved by the AHJ…” be included with the maintenance reports.
The next logical question that arises is: what type of maintenance work needs to be captured in the reports required under 5.5.9? Generally, the answer is that the correction of any deficiency listed on an acceptance testing report or periodic safety inspection report should be recorded in the maintenance reports. Maintenance work performed on fire door assemblies, in between safety inspections, should be recorded in accordance with 5.5.9. Cosmetic work (e.g., cleaning, staining, and painting) might not trigger the need for maintenance reports. Work that affects the operational components or the functional properties of the door assemblies should be included in the maintenance reports.
We have completed our review of the changes in Chapter 5 Inspection, Testing, and Maintenance. Be sure to review each of these changes in your copy of NFPA 80 to better understand their context. Take time to mark the corrections listed above.
Changes in Chapter 6 Swinging Doors with Builders Hardware are covered in the next article.