By Brad Keyes / Special to Healthcare Facilities Today

Q: If a door is a fire-rated door is it required to be maintained as a rated door in compliance with NFPA 80, regardless if its location doesn't require a rated door? I was told by a facilities employee that there isn't any information that he can find that states this. Really my fight with him is simple that a fire rated door regardless of location and function needs to meet the standards at all times i.e. door closer, holes in door and frame etc.

A: Your friend may have a point… According to the 2012 Life Safety Code, section 8.3.3.1, openings required to have a fire protection rating must meet the requirements of NFPA 80. So, based on this passage, if the fire door is installed in a non-rated barrier, one could assume that testing the fire doors would not be required. 

But one would be wrong. According to section 19.2.2.2.1 of the 2012 LSC, doors must be in compliance with section 7.2.1 of the same code. Section 7.2.1.15.2 says fire rated doors assemblies must be inspected and tested in accordance with NFPA 80. This section does not differentiate whether the door is in a fire-rated barrier or not. Therefore, all fire rated doors must be inspected and tested (and maintained) in accordance with NFPA 80. 

The requirements of the occupancy chapter always over-rule the requirements of a core chapter when the two chapters conflict. So, in this case, section 19.2.2.2.1 has precedence over section 8.3.3.1, and requires all fire rated door assemblies, regardless if the door is installed in a fire-rated barrier or not, to be tested and inspected in accordance with NFPA 80. 

You win… your friend loses… Start planning on testing all of the fire doors and have your first test completed by November 1. 

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