Downgrading Fire-Rated Door Assemblies
by Brad Keyes, CHSP, on Jul 26, 2019 1:00:39 AM
Q: My boss has hired an outside company that has advised him to rip fire rating labels off of doors and frames that we have maintained properly for decades. We do have automatic sprinklers in all areas. It does not feel appropriate to simply downgrade hazardous rooms, corridors, and elevator lobbies. My boss refuses to contact the AHJ and will only refer to his outside company. Is this appropriate and something I can sign my name too? Thank you for any information.
A: Well… maybe yes and maybe no.
All fire rated doors must be inspected based on 2012 LSC section 126.96.36.199 and 188.8.131.52, regardless if they are located in a fire-rated barrier or not. So, if your facility has a fire-rated door installed in a barrier (i.e. a corridor wall) that is not a fire-rated barrier, then the door assembly still has to be tested and inspected even though it is not located in a fire-rated barrier.
If you have a lot of these situations, then it can be costly to test and inspect fire-rated doors where you don’t have to, so the easy solution is to remove the fire-rating label from the door and frame. If you do that, then you don’t have to test and inspect the doors as they are no longer fire-rated assemblies. But you must be very cautious before you take such action and make doubly-sure that the door assembly is no longer needed to be fire-rated.
But you said something in your question that disturbs me… You said: “It does not feel appropriate to simply downgrade hazardous rooms, corridors, and elevator lobbies.” This statement is very troubling as you are not permitted to downgrade features of life safety that were required at the time of design or construction, unless it is a change with new construction standards. So, here is a possible scenario that may apply to your facility: When your facility was originally constructed, it was required to have all hazardous rooms be 1-hour fire-rated and fully protected with sprinklers. Today, that same room is now considered ‘existing conditions’ by definition since the 2012 LSC was adopted in July 5, 2016, and your facility was constructed prior to that date. According to the 2012 LSC, existing conditions hazardous rooms are permitted to be 1-hour fire-rated or sprinklered; not both. But section 184.108.40.206 of the 2012 LSC says no existing life safety feature shall be removed or reduced where such feature is a requirement for new construction. The 2012 LSC still requires sprinklers and 1-hour fire rated hazardous rooms, so you are not permitted to down-grade the fire-rated doors to a hazardous room just because it now qualifies as existing conditions.
You have every reason to be questioning this strategy. I suggest you and your boss contact your AHJs for guidance, or at least get some decent advice from a consultant. This outside company that you refer to… are they a qualified Life Safety company to be offering advice like this?
Some AHJs will not allow any down-grading of fire-rated door assemblies even if the doors are not required to be fire-rated, so make sure you check with them before removing any labels.