Q: I'd like some clarification concerning the new requirement for annual fire door inspections: NFPA 101 2012, Chapter 18.104.22.168 States "Where required by Chapters 11 through 43, the following door assemblies shall be inspected ....". I haven't found anything in Chapters 18 or 19 that specifically require the annual inspection. Additionally, the NFPA 101 Handbook specifically states that only occupancies requiring inspections are Assembly, Educational, Day-Care and Residential board and care. My question is where is the specific reference that is requiring hospitals to conduct annual fire door testing?
A: You almost had it correct…Section 22.214.171.124 of the 2012 LSC is a sub-heading titled “Inspection of Door Openings”. What you stated was actually section 126.96.36.199.1 which does not refer to fire-rated doors, but to certain doors in high-traffic areas, or doors of high importance, such as doors equipped with panic hardware, doors in exit enclosures, electrically controlled doors, or doors with special locking arrangements. Now some of these doors may be fire-rated, but section 188.8.131.52.1 does not specifically refer to fire-rated doors. Therefore, that is why this section is only required if the occupancy chapter requires it and you’re correct in saying the healthcare occupancies do not require it.
But look at section 184.108.40.206.2 which says “Fire-rated door assemblies shall be inspected and tested in accordance with NFPA 80…” This is the section that applies to all occupancies because it does not say “Where required by Chapters 11 through 43…” Section 220.127.116.11.1 in the existing healthcare occupancy chapter says doors must comply with section 7.2.1. So… you still have to test and inspect your fire rated door assemblies on an annual basis, because section 18.104.22.168.2 says you have to.
Brad Keyes, CHSP, is the owner of KEYES Life Safety Compliance, and his expertise is in the management of the Life Safety Program, including the Environment of Care and Emergency Management programs.
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