With the lengthy list of responsibilities that facility managers have to contend with, it can be difficult to stay current with the latest changes to fire and life safety codes that can potentially impact your facility. However, over the last 10 years, changes to the building and fire codes as well as litigation resulting from preventable injuries and fatalities have prompted a renewed focus on importance of maintaining fire and egress protection, as well as ensuring accessibility for building occupants. It’s vital for builders and property managers to be familiar with the requirements affecting door openings and be proactive in addressing any shortcomings.
Fire Door Inspections
One of the most notable changes impacting commercial facilities relates to fire door inspections required by NFPA 80 - Standard for Fire Doors and Other Opening Protectives. Although the most recent edition of this standard may not have been adopted in your jurisdiction yet, you can be sure that it will be in the next few years so it’s a good idea to become familiar with the new requirements in order to begin planning for their impact.
While the annual documented inspection and testing of fire door assemblies was already required in the 2007 and 2010 editions of NFPA 80, the 2013 edition requires that door, shutter and window assemblies be inspected and tested once the installation is complete (5.2.1), as well as any time maintenance work is performed on fire door assemblies (22.214.171.124).
Two new requirements have been added to the original 11 inspection criteria. These require that labels be clearly visible and legible and that signage affixed to the door meets the requirements of section 4.1.4. Any deficiencies must be immediately repaired.
Another important change involves who may perform the inspection. While previous editions of NFPA 80 require that the individuals conducting inspections have the necessary knowledge and understanding of the type of door being tested, the 2013 edition now requires that inspections be performed by a “qualified person,” which is defined as follows:
Qualified Person. 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.
The inspector must perform a visual inspection prior to testing and make note of any damaged or missing parts. The door must also be closed by all possible means of activation and of course records documenting these tests and the inspection itself must be maintained.
Another change found in the 2013 edition pertains to field modifications. Chapter 4 - General Requirements, addresses the issue of which modifications are acceptable in the paragraphs related to Appurtenances. However, Chapter 5 states that when it becomes necessary to make a field modification not covered by that section, the listing laboratory shall be contacted through the manufacturer and provided with a written or graphic description of the proposed modification. If the proposal meets with the laboratory’s approval, they may then give written authorization to perform the work without conducting a field visit or relabeling the opening. The laboratory may also choose to provide an engineering evaluation in the event that the manufacturer is no longer available.
These secondary locking devices installed in addition to the existing door hardware have been getting a lot of attention in the news lately as an inexpensive means of providing protection for occupants during active shooter events, particularly in schools. Significantly less attention has been paid to the fact that these devices are not compliant with the model codes and could hinder both the occupants’ egress and the ability of staff and emergency responders to gain access in an emergency.
Proponents of these products have argued that because they are not permanently installed on the door, they are therefore not subject to the jurisdiction of code officials or to the same requirements as traditional door hardware. However, code officials are quick to point out that most codes make no distinction between temporary and permanently-installed devices and they routinely issue citations for the use of “temporary” padlocks and chains on egress doors.
It’s also important to note that no active shooter has ever defeated a lock and successfully gained access through a locked classroom door. Conventional locksets can be combined with impact-resistant glass to provide an effective means of preventing unauthorized access while still meeting code requirements for free egress, fire protection, and accessibility. Electrified locks with the capability of remote lockdown may also be an appropriate choice. Several state jurisdictions are in the process of reviewing or changing the relevant codes, and proposals have been submitted to strengthen the model codes used nationwide, so it’s important to keep abreast of the code requirements that have been adopted in your facility’s jurisdiction.
While the use of impact-resistant glass can be an effective means of enhancing security in schools and other facilities, glass that is not impact-resistant such as traditional wired glass, is extremely hazardous to building occupants, particularly when it is installed in schools. In 2002, Emory University conducted a study of Consumer Product Safety Commission (CPSC) injury data which estimated that there are an average of 2250 wired glass injuries in schools each year. Although this is significantly fewer than the 320,000 annual glass injuries in all building types that were noted in the first study that took place in the 1960s, it still works out to a little more than 12 completely avoidable injuries or even fatalities every day that school is in session.
In 1972, the Consumer Product Safety Commission was formed and immediately set out to create some much-needed safety glazing standards. However, a court battle between Japanese wired glass manufacturers and the CPSC ultimately forced the commission to abandon its efforts to impose regulations on the glazing used in fire doors.
More than 20 years later, the first edition of the IBC, published in 2000, still permitted the use of traditional wired glass in fire door assemblies. It would take three more years before the 2003 edition prohibited the use of non-impact-resistant wired glass in any doors or other hazardous locations in ‘educational’ occupancies, and the 2006 edition prohibited the use of traditional wired glass in hazardous locations (including swinging doors) in any occupancy type.
While changes to the impact-resistance requirements for glass and glazing primarily affect new buildings and renovations, existing buildings should also be reviewed as injuries from this glass have resulted in lawsuits and settlements – regardless of whether the glass was code-compliant when originally installed. Courts have recently ruled that building owners have a responsibility to be aware of the hazards posed by this type of glass, and may therefore be held liable.
There are several new requirements within the 2010 Americans with Disabilities Act (ADA) Standards for Accessible Design that facility managers may be unaware of despite the fact that these changes have been in effect since 2012. As these violations can be particularly expensive to repair, it’s vital to ensure you are up to speed on what these new regulations entail.
Low energy automatic operators are just one example of a recent accessibility change. These products are now required to be activated by a knowing act, such as pushing a button or using an access control reader. It's important to note that use of a motion sensor is not considered a knowing act and, if used, will require the automatic door to be outfitted with additional safety features such as guide rails and sensors to detect a person in the path of the door.
The accessibility requirements for manual doors have also been changed. They are now prohibited from having projections on the push side of the door, from the floor to 10 inches above. This will impact narrow bottom rails, as well as surface-mounted vertical rod and panic devices as well as other types of projecting hardware.
Conflicts within the codes can also make accessibility standards difficult to understand and apply. For instance, the allowable operable force for door hardware is not addressed in A117.1 - Accessible and Usable Buildings and Facilities, but it has traditionally been mandated at a 15-pound limit. However, the ADA now requires a maximum of five pounds of force to operate door hardware, which can make specifying compliant panic hardware quite difficult. Further complicating matters, some states have established their own accessibility standards, many of which differ from the ADA or A117.1. Although enforcement varies by jurisdiction, the best way to avoid problems is to always follow the most stringent requirements. The local Authority Having Jurisdiction (AHJ) can also provide assistance in determining exactly what is required.
Lori Greene is the manager of codes & resources for Allegion, PLC. More information about the topics in this article can be found on her blog at www.idighardware.com.