Development of Door Inspection Requirements

You may wonder where the requirement for door inspections comes from. After all, doors have not previously been inspected. Why now? And where is the requirement defined? And what makes this requirement enforceable? Below are answers to these questions.

Why now?

Why are fire and smoke doors (and in some cases, egress doors) now inspected? After all, they’ve never been inspected in the past.

Fire doors (and more recently smoke and egress doors) have always played an important role in building occupant safety. However, following a series of tragedies in the 1990s and early 2000s, building officials noted that non-functional fire doors played a role in the injuries and deaths. As a result, the fire door standard (NFPA 80) was amended in 2007 to include requirements for annual maintenance and inspection.

From 2007 to 2016 - why so long to implement?

To understand why door inspections took so long to implement, one must understand the subtle differences between Standards and Codes.

A Standard is a document that establishes a minimum quality level that ensures products meet requirements. A standard is not legally enforceable until it is incorporated into – or referenced by – a code.

A Code is a document designed to establish a minimum level of standard and quality for constructing and maintaining facilities to protect the lives and property of occupants. Codes come in three main forms - building, fire, and life safety codes. Building codes control the construction phase of a facility, while fire and life safety codes control the year-to-year operation and maintenance phase of a facility.

Codes are legally enforceable once adopted by a jurisdiction into law.

Door Inspections defined in Standards:

Fire door inspections and a definition of inspected features were first established in the 2007 edition of NFPA 80, Standard for Fire Doors and Other Opening Protectives. Subsequent editions of NFPA 80 have maintained and refined inspection requirements.

Smoke door inspections and a definition of inspected features were first established in the 2007 edition of NFPA 105, Standard for Smoke Door Assemblies and Other Opening Protectives. Subsequent editions of NFPA 105 have maintained and refined inspection requirements.

(Remember, Standards are not legally enforceable.)

Door Inspection Standards become Code:

The NFPA 80 -2007 and NFPA 105 -2007 were incorporated into - and referenced by - the 2009 editions of the International Building Code (IBC); International Fire Code (IFC); and Life Safety Code, NFPA 101.

(Recall, Codes are enforceable, but only after being adopted into law by a jurisdiction.)

Jurisdictions Adopt Codes – and enforce them

Jurisdictions (whether Federal, State, County, or Local) typically adopt a code several years after it is published. As of early 2016, most states or local jurisdictions have adopted into the law the 2009 editions of the IBC, IFC, and LSC. (http://goo.gl/r1JrtY)

Healthcare Inspections:

The Center for Medicare and Medicaid Services (CMS) issued a ‘final rule’ on May 4, 2016 adopting the 2012 edition of the Life Safety Code, NFPA 101 -2012. (Press Release)

CMS, The Joint Commission (TJC,) and other accrediting agencies will use NFPA 101 -2012 to assess life safety systems in healthcare facilities beginning as early as July 4, 2016.

CMS and TJC are expected to begin enforcing the requirements for fire door inspections, smoke door inspections, and stairway identification signage starting in January 2017.


What Doors are Inspected?

Let’s start with, what is a fire door?

Although commonly called a “fire door”, the correct terminology is actually ‘fire door assembly’. In its simplest form, a fire door assembly consists of a door, a frame, and builders hardware [hinges, a door control (closer), and a latching device]. Additional items increase the complexity of the assembly.

Do only fire doors require annual inspection?

In the IBC and IFC, there are two general door types that need to be inspected:

  • Fire Doors (per NFPA 80, standard for Fire Doors and Other Opening Protectives), and
  • Smoke Doors (per NFPA 105, standard for Smoke Door Assemblies and Other Opening Protectives)

Fire doors are an important component in the passive fire protection system in all facilities. In addition to annual inspections, NFPA 80 also defines commissioning inspections and documentation following initial installation.

In addition to fire and smoke door inspections, The Life Safety Code, NFPA 101 -2012, also requires inspection of these additional door types (7.2.1.15.1):

1) Door leaves equipped with panic hardware or fire exit hardware

2) Door assemblies in exit enclosures

3) Electrically controlled egress doors (i.e. power operated doors)

4) Door assemblies with special locking arrangements.

The elements of the door to be inspected are defined here.

What is the purpose of fire and smoke doors?

Fire Doors are common and integral to all facilities. Occupants interact with them daily and typically can’t distinguish the difference between a fire door, smoke door, and regular, non-rated door.

The primary purpose of a fire door is to slow (or stop) the spread of fire through a facility so occupants have time to safely evacuate. They commonly protect exit passages (fire escapes).

Smoke doors slow the spread of smoke through a facility, allowing occupants to safely exit a facility.