Frequently Asked Questions:
Who has the authority to enforce NFPA 80?
With continued authority, AHJs will confirm that the inspections occurred by reviewing the documentation and verifying that the necessary corrective actions were taken to repair assemblies that were found to have deficiencies. The AHJ community will rely on the expertise of industry personnel to perform and document the inspections.
Who is responsible for the maintenance and care of fire-rated door assemblies?
Responsibility rests solely on the shoulders of the building owners. The role of the inspector is to simply record and report the condition of the door assemblies to the owner. Owners will have to decide if, when and what corrective actions will be taken; otherwise, they will run the risk of being cited for violations by the AHJ.
What role does The Door and Hardware Institute play in inspections?
DHI has created a training program that provides students with door, frame and hardware product and application knowledge. The program culminates in a three-day training class that concentrates on NFPA 80's inspection requirements (including proper documentation practices). This training is open to all interested parties. To get more information regarding the program, send an email to firstname.lastname@example.org or call Cathy Jones at 703.222.2655.
Do New York codes reference NFPA 80?
Building Code of NYS 2010 references NFPA80-2007 eight times in the following sections of the Building Code:
- Mixed Use and Occupancy, Construction: 508.2.2.1 “…Doors shall not have air transfer openings and shall not be undercut in excess of the clearances permitted in accordance with NFPA 80.”
- Opening Protectives 715.4: “...Fire Door assemblies and shutters shall be installed in accordance the provisions of this section and NFPA80”.
- Labeled Protective Assemblies 715.4.5: “Fire door assemblies shall be labeled by an approved agency. The labels shall comply with NFPA 80, and shall be permanently affixed to the door or frame.”
- Glazing Material, Size Limitations 7188.8.131.52: “ “Wired glass used in fire doors shall comply with Table 715.5.3/ Other fire –protection-rated glazing shall comply with the size limitations of NFPA 80”.
- Door Closing, Automatic-closing Fire Door Assemblies 7184.108.40.206: “Automatic –closing fire door assemblies shall be self-closing in accordance with NFPA 80”.
- Fire-Protection-Rated Glazing 715.5: “…Fire-rated protection glazing shall also comply with NFPA 80”.
- Non-wired Glass 715.5.4: “Glazing other than wired glass in fire window assemblies shall be fire-protection-rated glazing installed in accordance with and complying with the size limitations set forth in NFPA 80.
- Horizontal Sliding Doors 1008.1.3.3:”…Horizontal sliding doors shall be installed in accordance with NFPA80 and shall comply with (NYS Building Code) section 715.
Does the Building Code of NYS mandate annual inspections? Does the NYS Building Code reference only “installation” and not “maintenance”?
The Building Code of New York State 2010, as quoted above in Opening Protectives 715.4, speaks to the installation of fire door assemblies.
The Building Code of New York State 2010 does not speak to the maintenance nor inspection of fire door assemblies.
Understanding that the fire code and building code are different, what does the Fire Code of NYS reference.
The Fire Code of New York State 2010, which is derived from the IFC, references NFPA 80 twice in the following chapters:
- Opening Protectives 703.2: “Opening protectives shall be maintained in an operative condition in accordance with NFPA 80…”
- Horizontal Sliding Doors 1008.1.3.3:”…Horizontal sliding doors…shall be installed in accordance with NFPA 80 and shall comply with (NYS Building Code) Section 715.
Any insight into how New York City & Long Island are handling this?
Typically, in NYC, either the city code or the Building Code of NYS is enforced according to which is the most stringent. Long Island would be subject to the Building Code of New York State.
In summary, my overall sense, supported by NYS’s Office of General Services, Division of Design code officials, is that fire door inspections are required according to The Fire Code of New Your State, Opening Protectives section 703.2: “Opening protectives shall be maintained in an operative condition in accordance with NFPA 80…” NFPA 80 requires inspections so that deficiencies in fire door assemblies are identified, and remedied, assuring the fire door assembly is operable. The inspection is required as part of the NFPA 80 maintenance procedure to maintain the fire door assemblies in an operable condition.
Bear in mind, codes are trumped by law. In this case NYSCRR Title 19 requires fire inspections. Arguably, this is not in conflict with either the Building Code nor the Fire Code.