Annual Fire Door Inspecting and Testing

Fire door assemblies are critical components to protecting occupants and buildings during event of a fire event. They may be less talked about than more commonly recognized building fire protection systems such as automatic sprinklers, fire alarms, and smoke detectors, but fire doors, if installed and maintained properly, will keep fire contained to the area of the building in which it started, allowing occupants more time to move to a point of safety quickly, while simultaneously protecting other areas of your facility from spread of fire. Over time, fire doors can be subjected to significant wear and tear. While considered passive fire protection systems, fire doors, depending on their location, may open and close hundreds of times per day for necessary building operations and movement. Thus, the reason that facility personnel play such a critical role in ensuring that fire doors are maintained in good working condition after they are installed. Ongoing scrutiny by the facility manager ensures that wear and tear on fire doors does not lead to any unsafe breaks or damage, or at the very least, provides building personnel with the best opportunity to identify where repairs or replacements are needed.

Fire Inspections

Beginning with the 2007 edition of NFPA 80 Standard for Fire doors and Other Opening Protectives, requirements for periodic fire door assembly inspections (FDAI) have been included in the standard. In each of the subsequent editions, the inspection requirements have been modified and expanded. When an adopted code references one of these editions of NFPA 80, the inspection criteria become enforceable by the Authority Having Jurisdiction (AHJ). The International Fire Code 2009 edition was the first to adopt these requirements by reference to NFPA 80 2007.

NFPA 105 Standard for Smoke door Assemblies and Other Opening Protectives requires smoke door assemblies to be inspected and tested in accordance with the inspection requirements of NFPA 80. As there are various types of doors that are commonly called “smoke doors,” it is important to note that the inspection requirements apply to smoke doors that are required by code to comply with NFPA 105.

National fire protection association [ NFPA ] standards on fire doors and other opening protective requires a visual inspection and operational testing of fire doors at any of the following times: upon completion of installation of the new fire door assembly, annually as part of the required periodic inspection, and after any maintenance corrections have been performed on the door assembly. To complete a visual inspection, a list of 13 items, at a minimum, must be verified.

At the time of the inspection, fire doors should also be tested to ensure that they will operate properly. Inspection entails verification that the door is self-closing and self-latching without encountering any obstructions. If a fire door is power-operated or automatic-closing, it should also be verified that the door self-closes by all means of activation. Records of these inspections and tests must be signed and maintained at the facility and kept for verification by the local Authority Having Jurisdiction (AHJ).

During the life of the fire door, proper maintenance is also required to uphold the fire door assembly in good working condition and to increase the chances that it will perform properly in a fire. Fire doors with operational deficiencies or extensive damage run the risk of leaving an opening unprotected during a fire and can ultimately void the protection that fire door assemblies offer. Repairs should be made, and any defects that could interfere with operation should be corrected without delay. If you are considering any modifications to a fire door that may void the label on that door take caution.

Safety begins with facility managers or designated safety personnel overseeing and scheduling the necessary inspections and ensuring that any deficiencies and maintenance issues are corrected in a timely manner. It is also the responsibility of building staff to designate in-house expertise or hire external contractors who are qualified to do general maintenance of fire doors within their facility.

The second line of defense lies with those who perform fire door inspections and testing. These professionals are deemed qualified if they possess a recognized degree or certificate, or if they have achieved some professional standing or skill that underscores that they have the knowledge, training, and experience necessary to assess and provide fire door inspections.

Qualified fire door inspectors may be external vendors by the facility to perform the required inspections and testing on all fire door assemblies throughout the building. Any way you look at it, they must be educated on the provisions of NFPA 80 and the components and operation of fire door assemblies.

Where is it stated in the codes that fire door assemblies must be inspected annually?

The detailed requirements are found in NFPA 80, which is referenced by the model codes. The adopted fire code is typically enforced throughout the life of the building, so requirements for annual inspections would be found in the fire code rather than the building code. The majority of states adopt either the International Fire Code (IFC) or NFPA 1 Fire Code which references NFPA 101 Life Safety Code.

Always consult the fire code that has been adopted where the building is located, as some states and local jurisdictions modify the model codes.

Look for the fire door operational inspection and maintenance requirements written record for fire doors and a reference to NFPA 80. For example, the IFC states: “Opening protectives in fire-resistance-rated assemblies shall be inspected and maintained in accordance with NFPA 80.” NFPA 1 includes detailed information that is consistent with NFPA 80, as well as additional guidance in Annex A. NFPA 101 references the inspection and testing requirements of NFPA 80 in Chapter 8:

The AHJ completes the fire door safety picture. First, they verify that those performing routine inspections at the facility are competent to do so. Then they ensure that fire door inspections have occurred at the required intervals and that the records have been retained to properly document inspections.

When working together, building owners, fire door inspectors, and AHJs make certain that fire door assemblies throughout a building remain in full working condition and that they are fully capable of operating properly under fire conditions. Beginning with the 2013 edition, NFPA 80 requires fire doors, fire shutters, and fire window assemblies to be inspected and tested upon completion of their installation, and also upon completion of maintenance work.

By reference, the 2015 edition of the IBC and subsequent editions require fire door assemblies to be inspected after they are installed, in addition to the recurring annual inspections required by the fire code.The model codes and NFPA 80 do not differentiate between occupancy types when it comes to fire door assembly inspections; the inspection requirements apply to fire doors in all types of facilities. However, enforcement may vary locally.

Health care facilities that receive funding from the Centers for Medicare and Medicaid Services (CMS) must conduct and document fire door assembly inspections, since the 2016 adoption of NFPA 101-2012. Even if a state or local fire marshal is not widely enforcing the annual inspection requirements, it is likely that hospitals or nursing homes within that jurisdiction must perform fire door inspections due to enforcement by CMS.

NFPA 80 is being adopted into building codes not just as a reference but as a requirement. These codes include: NFPA 101 Life Safety Code, which is used in many jurisdictions; the International Fire Code that is used by states as their fire codes; and the International Building Code, which is perhaps the most widely used building code.

One of the most significant changes that this has for managers is the requirement for annual inspection and testing of all fire doors. In most cases, the building owner is responsible for carrying out and documenting the inspections. The intent of the regulation is to give the authorities having jurisdiction (AHJ) the ability to see and review the fire door inspection documentation, just as they have been doing with sprinkler systems, fire extinguishers, alarms, and other fire safety systems. Fire marshals are asking to see that documentation during their annual inspection of the facility.

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NFPA 80 (Standard for Fire Doors and Fire Door Assemblies) is recognized as the standard that regulates fire doors. It establishes the minimum acceptable performance criteria as well as the test procedures and acceptance criteria for a fire door assembly. There are three main classifications of doors in the industry based on their function: 1) Fire protective assemblies which are basically penetration-rated assemblies, 2) Impact-rated assemblies and 3) Non-rated assemblies.

The importance of fire door inspection and testing, we are committed to providing our customers with the highest level of service available. We take pride in the growing relationships that we have made with building owners throughout your community. Our skilled professionals are qualified to service all types and styles of commercial fire doors, as well as any other services you may require.

Post-fire examinations have shown that fire-related injuries and deaths have occurred as a result of improperly functioning fire doors. Something as simple as a broken door closer or a failed door latch can keep a fire door from properly closing, allowing the spread of flames and smoke through the opening. A well maintained and properly operating fire door would have limited the spread of to protect the building and its occupants.

To stop the spread of smoke and fire, fire doors are located between discrete areas of the building, in corridors between building sections, and in interior stairwells. Similarly, fire doors are located at all points of egress from the building, including entrances, exits, and lobbies. Fire doors and their fire door frames must be labeled, showing the door manufacturer and the fire protection rating of the assembly. Examine all doors and door frames closely for fire door labels. But just because a door does not have a label does not mean it is not a fire door. Unfortunately, over the years, many labels have been painted over or otherwise rendered unreadable.

Inspection Requirements:

• Check that no parts of the door or frame are missing or broken
• Check that no hardware or other items have been added to the door or frame that could interfere with its proper operation.
• Inspect the entire door and frame for open holes or breaks in surfaces.
• Inspect all door hardware, gaskets, and edge seals for damage.
• Check the latching hardware to ensure it secures the door when in the closed position.
• Test the self-closing device to ensure it completely closes the door when activated from a full-open position.
• Inspect glazing and vision panels to ensure they are intact and securely fastened in place.
• Check the alignment of the door, frame, hinges, and hardware to ensure they are secure and in good working order.
• Measure door clearances. The maximum allowable gap under the bottom of the door is three-quarters of an inch. The maximum allowable gap along the top, hinge, and latch edges is one-eighth of an inch.
• Ensure that the inactive leaf of a double door closes before the active leaf.

These steps represent the minimum inspection and testing requirements. The most common defects found during a typical inspection include: failure of the door latch to properly secure the closed door; damaged or missing door closer; painted over or missing door or frame label; blocked door; and an excessive gap between the door and the frame or floor. All identified defects should be corrected as quickly as possible.

When fire door inspections are finished, managers must closely examine the report documents. The report should include a separate page for each fire door. In addition to the items inspected and tested, each page should include a form of identification for the door, such as an assigned number or location, the type of door installed, its fire rating, the date the inspection was conducted, and the name and signature of the person conducting the inspection. An additional comments section should be included to allow inspectors to identify unusual circumstances or conditions.

In addition to each door inspection sheet, it might be necessary to include photographs of conditions of a particular door. Those photographs should be clearly labeled to identify the door, location of the defect on the door or frame, and the condition. The AHJ will request these documents when conducting an annual inspection of a facility.

The first fire door inspection report most likely will include a long list of deficiencies, ranging from minor ones to others that require replacement of the door and frame. Deficiencies also might include failed latches, excessive door to frame and floor gaps, missing fire labels, damages or missing hardware, and improperly blocked doors.

After the implementation of Centers for Medicare and Medicaid Services (CMS) requirements for annual door inspections in health care facilities, an interesting phenomenon has developed. NFPA 101 requires certain fire and smoke door assemblies to be inspected and tested annually in accordance with NFPA 80 and NFPA 105, where required by the occupancy-specific chapter. However, as the NFPA 101 health care occupancy chapters (i.e., chapters 18, 19, 20 and 21) do not directly reference paragraph 7.2.1.15, the annual inspection and testing requirements in that section do not apply to health care occupancies.

Further inspection of the NFPA 101 code requirements reveals that paragraph 8.3.3.1 requires that openings in fire resistance-rated assemblies (e.g., fire barriers) be protected by approved, listed and labeled fire door assemblies in accordance with NFPA 80, regardless of the occupancy. In addition, paragraph 4.6.12.1 further requires that any required feature be maintained in accordance with the applicable NFPA standards.

CMS final rule to amend the fire safety standards and adopt the 2012 edition of NFPA 101 for Medicare- and Medicaid-participating hospitals, critical access hospitals, long-term care facilities, intermediate care facilities for individuals with intellectual disabilities, ambulatory surgery centers, hospices that provide inpatient services, religious non-medical health care institutions, and programs of all-inclusive care for the elderly facilities.

CMS has further clarified that non-rated doors, including corridor doors to patient care rooms, are not subject to the annual inspection and testing requirements of either NFPA 80 or NFPA 105. CMS concluded that in health care occupancies, annual inspection and testing in accordance with NFPA 80 is required for all fire door assemblies and that documentation that the facility actually inspected and performed the necessary maintenance on these doors must be provided. Additional clarification was provided that the required annual inspection.

Paragraph 5.2.4.2 of NFPA 80 outlines the following visual inspection criteria for swinging doors with builders or fire door hardware

• No open holes or breaks exist in surfaces of either the door or frame.
• Glazing, vision light frames and glazing beads are intact and securely fastened in place, if so equipped.
• The door, frame, hinges, hardware and noncombustible threshold are secured, aligned and in working order with no visible signs of damage.
• No parts are missing or broken.
• Door clearances do not exceed three-quarters inch under the bottom of the door (as provided in Section 4.8.4) and one-eighth inch at the top, hinge and latch edges of the door (as provided in Section 6.3.1.7).
• The self-closing device is operational; that is, the active door completely closes when operated from the full open position.
• If a coordinator is installed, the inactive leaf closes before the active leaf.
• Latching hardware operates and secures the door when it is in the closed position.
• Auxiliary hardware items that interfere or prohibit operation are not installed on the door or frame.
• No field modifications to the door assembly have been performed that void the label.
• Gasketing and edge seals, where required, are inspected to verify their presence and integrity.

Similarly, paragraph 5.2.1 of NFPA 105 outlines the following visual inspection criteria for smoke doors

• Doors shall be operated to confirm full closure.
• Hardware and gaskets shall be inspected, and any parts found to be damaged or inoperative shall be replaced.
• Further requirements in NFPA 101 Section 8.5.4 limit the clearances for smoke barrier doors as provided above for fire-rated doors.

Our focus on safety, the trained door systems technician capable of providing the most up-to-dated technology available in the industry. Because of our commitment to customer service, we encourage you to give us a call or contact us via e-mail for further information about our fire door testing services today! For sales, service, repair,installation and fire door, inspection testing call us now, Phone: (832) 232-9150.