As part of the process through which NFPA staff provides answers to technical questions received from members and AHJs, one stakeholder recently asked about compliance rates for fire door assemblies inspected yearly, as required by NFPA 80, Standard for Fire Doors and Other Opening Protectives. I took the question to mean: “What percentage of fire door assemblies fail the required yearly inspection?”
In my mind, the inquiry asks the wrong question; even if I had the statistics requested, providing them would not be helpful. A fire door assembly can fail the inspection if any of scores of elements/features have anything wrong with them. The failure of some of those features should carry a heavier weight than others, but they don’t; a violation is a violation; any violation fails the fire door assembly. Thus, we are hearing fire door assembly inspectors say things like ___% fail the inspection (I’m leaving it to others to fill in the blank, but I’m often hearing numbers as high as 50, 60, 70, or even 80 percent).
Consider three examples of violations that have differing importance:
- Some metal plates for attaching the arms of a hydraulic door closer to the top jamb/soffit are fabricated with five pre-drilled holes for the passage of screws for attaching the plate; very often one of those holes does not have a fastener; a missing fastener is a violation; such violation fails the fire door assembly. The deficiency can be repaired, almost immediately, using readily available tools, like a drill and screwdriver, and readily available parts, like screws matching those provided by the manufacturer of the closing device. The repair takes almost no time and can be performed without disassembling the fire door. The door assembly can then be removed from the failures portion of the report or, perhaps, not added to the failures report in the first place, especially if the facility performs a pre-inspection prior to the required yearly inspection or has an effective on-going maintenance program.
- A door leaf has sagged, within its frame, such that the clearance is excessive between the top edge of the latch stile and the rabbet at the top of the frame. Relatedly, the clearance is excessive between the upper portion of the edge of the hinge stile and the rabbet at the side of the frame. The clearance violations can be corrected by installing steel shims behind portions of one or more of the hinges. Effective shimming takes considerable skill; the facility has no one on staff who can successfully accomplish the needed shimming; a professional will be brought in to perform the work. The violation cannot be immediately corrected; such condition must be reported as a failure. Had the facility performed a pre-inspection or had an effective on-going maintenance program, the condition could have been noted earlier and corrective action taken so the door would pass the required yearly inspection.
- A fire door assembly has a door leaf that is so warped that the door leaf face is not in alignment with the face of the door frame, meaning that some portion of the latch stile doesn’t contact the stops built into the frame. The gaps are noticeable and, obviously, the fire door assembly will not prevent fire from getting to the unexposed side. The door leaf, at minimum, and perhaps the door frame, must be replaced. Based on availability of a door leaf that meets the facility’s needs, the violation might not be able to be corrected for days or weeks. Such condition must be reported as a failure on the inspection report. Remedial action must commence immediately.
Rather than asking for a statistical report of the overall failure rate of fire door assemblies inspected, a more useful request might be: What percent of the fire door assemblies in a facility would fail a re-inspection conducted a few days after the initial inspection? This would help weed out the noise created by minor violations in contrast with violations that your gut feeling tells you might keep the fire door assembly from performing as intended under fire conditions.
Such question could help to ensure that inspection reports get utilized immediately to commence remedial action, especially for minor issues that might have been avoided by an effective maintenance program or if pre-inspections had been conducted. Where a facility ignores the inspection report and does not immediately correct the violations that are easy to correct, all violations will be considered to carry equal weight. Together, the violations might place the facility into serious non-compliance.
Source: Ron Cote Blog Post on Feb 1, 2018 via NFPA | Xchange™
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