This article is the fifth in a series of articles dedicated to the changes in the new NFPA 80. You may read these articles in any order. The first article includes some helpful tips for accessing NFPA 80 online. Changes in Chapters 1 through 6 are covered in the first four articles. Tips for highlighting your copy of NFPA 80 are also in the first article.
Changes in chapters 7 through 20 are covered in this article.
Several chapters in NFPA 80 saw only minor editorial changes that included updating the titles of external referenced publications. No technical changes occurred in these chapters. Let’s go ahead and dispense them before we turn our attention to the remaining chapters. The following list of chapters have no technical changes from the 2013 edition of NFPA 80:
- Chapter 7 Swinging Doors with Fire Door Hardware
- Chapter 10 Vertically Sliding Fire Doors
- Chapter 11 Rolling Steel Doors
- Chapter 12 Fire Shutters
- Chapter 13 Service Counter Fire Doors
- Chapter 14 Hoistway Doors for Elevators and Dumbwaiters
- Chapter 17 Fire Windows
- Chapter 18 Glass Block Assemblies
That leaves us with changes in the following chapters to review:
- Chapter 8 Horizontally Sliding Doors
- Chapter 9 Special-Purpose Horizontally Sliding Accordion or Folding Doors
- Chapter 15 Chute Doors
- Chapter 16 Access Doors
- Chapter 19 Installation, Testing, and Maintenance of Fire Dampers
- Chapter 20 Fabric Fire Safety Curtains
Chapter 8 Horizontally Sliding Doors
Two changes in Chapter 8 were made that you might need to know. Both changes deleted the provision for a 10-second delay in the closing or reclosing of automatic-closing doors (see former 18.104.22.168.2 in the 2013 edition) and the 10-second delay “…from failure of normal power operation to emergency power…” (see former 22.214.171.124.4).
The provisions allowing delays in the closing of automatic-closing, self-closing, or emergency power operation were moved to 126.96.36.199. In other words, Chapter 8’s provisions for 10-second delay features moved to Chapter 4, they were not eliminated from NFPA 80. Remember, the provisions of Chapter 4 General Requirements apply to all types of fire door assemblies covered in NFPA 80.
Chapter 9 Special-Purpose Horizontally Sliding Accordion or Folding Doors
Similar to the changes found in Chapter 8 Horizontally Sliding Doors, one change occurred in Chapter 9. The 10-second delay “…from failure of normal power operation to emergency power…” (see former 188.8.131.52.1) was deleted. Time-delay features are now covered in 184.108.40.206.
You might wonder why the provision for a time-delay feature for self-closing or automatic-closing special purpose horizontally sliding doors (see 220.127.116.11) were retained under Chapter 9. According to the committee statement regarding these changes, “…the requirement [of 18.104.22.168] has not been addressed by the changes to Chapter 4 and should be retained [in Chapter 9].”
Chapter 15 Chute Doors
When you look up Chapter 15 in the 2013 edition of NFPA 80, one of the first things you notice is this is a short chapter. It consists of only 5 paragraphs that contain basic, non-application specific, requirements.
In the new NFPA 80, the content of Chapter 15 has been extracted almost entirely from NFPA 82, Standard on Incinerators and Waste and Linen Handling Systems and Equipment (2014 edition). While Chapter 15 is one of the shortest chapters in NFPA 80, you will see that its requirements and provisions are now application-specific.
Chute doors are formed from sheet metal, primarily stainless steel, that include a frame and hinge and, where required, gasketing and latching or locking hardware. These doors also include a self-closing or automatic-closing device. The label on the door panel covers the entire assembly. In other words, chute doors are unit-based assemblies (systems) that are assembled at the factory. Chute doors are available with 250°F temperature rise ratings (see A.15.1.2).
Paragraph 15.1.1 Operation requires openings in the fire resistance-rated enclosures to have fire protection-rated opening protectives that are rated for 1-1/2 hours or 1 hour, in 2-hour and 1-hour construction respectively. The enclosure covered in this requirement is the construction directly surrounding the chutes. Chute intake and discharge rooms are required to be separated from other building areas by fire resistance-rated construction that is equal to or greater than the rating of the chute (see NFPA 82, 22.214.171.124.1 and 126.96.36.199.1).
On a related note, NFPA 82 also requires the use of “…approved automatic or self-closing fire door assemblies…” for openings in chute intake rooms and chute discharge rooms (see NFPA 82, 188.8.131.52.2 and 184.108.40.206.2). In most cases, these types of fire door assemblies will be swinging doors with builders hardware, but other types of fire door assemblies (e.g., rolling steel doors) can be used to accommodate collection equipment in discharge rooms.
If you specify, supply, or install chute doors, you should take time to read Chapter 15’s provisions and requirements closely. You might also want to study NFPA 82, Standard on Incinerators and Waste and Linen Handling Systems and Equipment. Remember, you can read NFPA 82 online for free through the NFPA website.
Chapter 16 Access Doors
The only change that occurred in Chapter 16 is found in paragraph 220.127.116.11. A reference to ANSI/UL 263, Standard for Fire Tests of Building Construction and Materials was added as an equivalent to ASTM E119. No other technical changes were made to this chapter.
Chapter 19 Installation, Testing, and Maintenance of Fire Dampers
Much of the content in Chapter 19 remains unchanged from the 2013 edition of NFPA 80. You will see new requirements for fire damper testing: operational, acceptance, and periodic. We are going to look at each of these new requirements, albeit in a different order.
New Section 19.4 Acceptance Testing, sets baseline requirements for testing fire dampers. Paragraph 19.4.1 requires acceptance testing to “…be performed by a qualified person with knowledge and understanding of the operational components of the types of assembly [damper] being subject to testing.” (Note: Underlining added for emphasis.)
According to the definition listed in Chapter 3, A Qualified Person is “A person who, by possession of a recognized degree, certificate, professional standing, or skill, and who, by knowledge, training, and experience, has demonstrated the ability to deal with the subject matter, the work, or the project” (see 3.3.96).
Previous editions of NFPA 80 relied on industry practices for operational and periodic testing of fire dampers and did not specify who could perform this work. Under this new provision, AHJs can ask to see the professional qualifications of the persons testing fire dampers. AHJs are likely to have greater confidence that the fire dampers are installed and functioning correctly when testing is performed by qualified persons.
Fire dampers and combination fire/smoke dampers are required to be inspected and tested, as follows:
- Upon completion of installation (see paragraphs 19.3.1 and 19.3.2).
- One year after installation (see paragraph 18.104.22.168).
- Once every 4 years thereafter in buildings that do not contain a hospital or once every 6 years thereafter in buildings containing a hospital (see paragraph 22.214.171.124).
- Immediately upon completion of any repairs (see paragraph 19.6.4).
It’s important to note that the frequency for periodic inspection and testing has not changed from the 2013 edition of NFPA 80.
Paragraph 19.6.1 under Maintenance contains a provision that might trigger the need for inspecting and testing dampers in between the formal inspection cycles listed above; it states: “Reports of changes in airflow or noise from the duct system shall be investigated to verify they are not related to damper operation.” When dampers are the source of changes in airflow or noises from the duct system, paragraph 19.6.3 requires that the “…repairs shall begin without delay.”
Section 19.5.3 Documentation specifies the minimum information needed for inspection reports. Acceptance, operational, and periodic testing records need to include the following information (see paragraph 126.96.36.199):
- Location of the dampers.
- Date of inspection.
- Name of the inspector(s).
- Deficiencies discovered during the inspections and testing.
- Space to record “…when and how the deficiencies were corrected.”
Additionally, paragraph 19.6.5 under Maintenance requires maintenance work on dampers to be “…documented in accordance with 188.8.131.52 and 184.108.40.206.”
Paragraph 220.127.116.11 contains a new requirement for the retention of inspection records. Inspection records are required to be maintained for a minimum of 3 cycles. In other words, a minimum of 12 to 18 years depending on type of building. Previous editions of NFPA 80 required the records to be maintained and available for the AHJ’s review, but did not specify a retention period. One of the reasons for specifying a minimum retention period is that AHJs might not be able to inspect each building in their jurisdiction every year. They need to know that the fire dampers are monitored and maintained, as required by NFPA 80, during the intervening periods between AHJ inspections. Another reason for the retention period is that it gives AHJs historical data regarding the effectiveness of the building’s maintenance program.
Test Methods of Fire Dampers
Section 19.5.2 Test Method contains new and expanded requirements that describe how the testing of dampers is performed. These new requirements are divided into two sections, one for dampers with fusible links (see Section 18.104.22.168) and one for dampers without fusible links (see Section 22.214.171.124).
According to the committee’s statement regarding these changes, the new testing requirements “…provide necessary clarification as to what steps need to be taken during the inspection and testing; guidance that was not provided in earlier editions of NFPA 80.” These new testing requirements are more prescriptive than those in the 2013 edition of NFPA 80.
Mark the following correction in your copy of NFPA 80. At Section 126.96.36.199 Periodic Testing for Dampers that Do Not Use a Fusible Link to Operate, strike out the following statement: “Once the fusible link is removed, it shall be verified that the damper closes completely without assistance.” This statement seems to be carried over from the last edition of NFPA 80. Evidently, it was missed during the editing process.
Other Changes in Chapter 19
Fire dampers that are activated by smoke detectors require an additional system test “…in accordance with NFPA 4” (see paragraph 188.8.131.52). NFPA 4, Standard for Integrated Fire Protection and Life Safety System Testing (2015 edition) contains system-wide testing that includes smoke detectors. NFPA 4 is a new standard that you might not know about, its effective date is May 19, 2014. Previous editions of NFPA 80 required smoke detector actuated fire dampers to be tested in accordance with NFPA 72, National Fire Alarm and Signaling Code.
A subtle change is found in paragraph 184.108.40.206 that resolves conflicting requirements with other standards. Access panels on fire dampers are required to be “…labeled with the words “Fire Damper” in letters not less than 1/2 in. (13 mm) in height.” Previous editions of NFPA 80 limited the minimum height of the lettering to 1 in. (25.4 mm).
Take time to read Chapter 19 closely. Be sure to read the associated annex comments to better understand the context of its requirements.
Important Notice: NFPA’s code and standard development processes includes a process referred to as a Tentative Interim Amendment (TIA) process. The TIA process can be initiated by any interested party who discovers and identifies valid omissions, conflicting requirements, and other technical issues that significantly affect the application of a code or standard. The technical committee responsible for affected code or standard reviews the proposed TIA. Once a TIA is approved by the technical committee, it is posted on the document pages on the NFPA website. TIAs modify the affected code or standard, making their requirements enforceable. Eventually, the provisions of a TIA are incorporated into the affected code or standard. In the case of the new NFPA 80, there is a pending TIA that addresses several corrections for Chapter 19, Installation, Testing, and Maintenance of Fire Dampers. Click here to open the pending TIA. Any interested party can submit comments on pending TIAs to NFPA until the posted closing date.
Chapter 20 Fabric Fire Safety Curtains
Two important changes occurred in Chapter 20. The first change appears in paragraphs 220.127.116.11 and 18.104.22.168. These provisions cover the plans, specifications, and installation of fabric fire safety curtains. The new NFPA 80 requires the people performing this work to be qualified persons (see 3.3.96) who are also certified by a third-party. In most cases, NFPA codes and standards do not expressly require qualified persons to have third-party certification. Chapter 20 is an exception, due to the complexities of these types of systems.
The next change is found in Section 20.7.3 Emergency Operation. Paragraph 22.214.171.124 includes two provisions for the activation of emergency operation of fire safety curtains. The curtains can be activated manually or by rate-of-rise heat detectors that are located above the stage. Previous editions of NFPA 80 included a provision for the use of fusible links in the emergency lines. Fusible links are no longer permitted to be used to as part of the emergency operation system. Accordingly, former provisions that covered the use of fusible links (paragraphs (126.96.36.199.2 and 188.8.131.52.3 in the 2013 edition) were deleted. The reason cited by the committee in its statement regarding this change is excerpted below:
“A study, published by NFPA, has determined that ‘It is not likely that the descent of the fire safety curtain would be triggered by fusible links provided along the fire safety curtain release line due to their slow thermal responses. Further, the actuation of the release line fusible links is estimated to be preceded by the activation of sprinklers leading to cooling of the fusible links.’ Fire Safety in Theaters – A New Design Approach, Final Report Published by: The Fire Protection Research Foundation, Quincy, MA, Sept. 2009.”
We have completed our review of the changes in Chapters 7 through 20. Be sure to review each of these chapters in your copy of NFPA 80 to better understand their context.
New Chapter 21 Fire Protective Curtain Assemblies is covered in the next article.