National Fire Protection Association. 1 Batterymarch Park, Quincy, MA Phone: Fax:

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1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: M E M O R A N D U M TO: FROM: NFPA Technical Committee on Fire Doors and Windows Kristin Collette, Staff Liaison DATE: October 4, 2011 SUBJECT: NFPA 80 ROC TC Letter Ballot (A2012) The ROC letter ballot for NFPA 80 is attached. The ballot is for formally voting on whether or not you concur with the committee s actions on the comments. Reasons must accompany all negative and abstention ballots. Please do not vote negatively because of editorial errors. However, please bring such errors to my attention for action. Please complete and return your ballot as soon as possible but no later than Friday, October 28, As noted on the ballot form, please return the ballot to Diane Matthews either via to dmatthews@nfpa.org or via fax to You may also mail your ballot to the attention of Diane Matthews at NFPA, 1 Batterymarch Park, Quincy, MA The return of ballots is required by the Regulations Governing Committee Projects. Attachments: Comments Letter Ballot

2 Report on Comments June 2012 NFPA Log #11 Michael A. Anthony, University of Michigan / Rep. APPA.ORG - Leadership in Education Association of Education Facility Executives 80-1 Consolidate related material from NFPA 72, NFPA 90A, NFPA 92A and NFPA 105 into this document or create an entirely new document from all of the foregoing. Users of NFPA documents regarding this part of fire safety technology are typically confused by this constellation of documents. It would be cost effective for APPA member institutions - as well as more of a commercial prospect for NFPA - if a Task Group and/or a technical committee could be set up to develop a consolidated document that presents everyone with a win-win-win situation as far as conformity of relevant fire safety codes are concerned. The submitter has proposed no change to any language in the document. The concept being proposed introduces new material which cannot be acted on or solved by the Committee at this ROC meeting. The Committee recommends that the submitter monitor the development of the new NFPA 4 on integrated testing of fire protection systems which may address some of his concerns. In addition, recommendations regarding the work of multiple documents should be sent to the Standards Council, not only to the individual committees Log #6 Marcelo M. Hirschler, GBH International 80-1 Revise text to read as follows: NFPA 251, Standard Methods of Tests of, Fire Resistance of Building Construction and Materials ASTM E119, Standard Test Methods for Fire Tests of Building Construction and Materials (2011) Replace NFPA 251 by ASTM E119 wherever it appears, as follows: 1.1.4, 2.2, , 4.5, , , , A.1.1.1, A.1.14, A.1.3, A , A.4.4.1, A , A , D.10, D.11, I.1, K,6 and L.I.1. When eliminating NFPA 251 from 2.2 and L.1.1, the replacement standard needs to be placed into and L Section , which is an extract from NFPA 220 needs to cease being an extract. NFPA 251 was withdrawn by the technical committee on fire tests and is being replaced in all NFPA documents by ASTM E119, which is technically equivalent. 1. Replace reference to NFPA 251 with ASTM E119 in Chapter 2 and Annex L as noted by submitter. 2. Replace references to NFPA 251 with reference to ASTM E 119 in sections noted by the submitter. 3. Delete extract reference in as follows: Fire Resistance Rating. The time, in minutes or hours, that materials or assemblies have withstood a fire exposure as established in accordance with the test procedures of ASTM E 119 Standard Test Methods for Fire Tests of Building Construction and Materials NFPA 251. [220, 2009] The committee is in agreement with the submitter. The specific revision steps are clearly stated by the committee meeting action. Printed on 10/4/2011 1

3 Report on Comments June 2012 NFPA Log #CC1 Technical Committee on Fire Doors and Windows, 80-1 Revise text to read as follows: ASTM D 4157, Standard Test Method for Abrasion Resistance of Textile Fabrics (Oscillatory Cylinder Method), ASTM D 5034, Standard Test Method for Breaking Strength and Elongation of Textile Fabrics (Grab Test), ASTM D 6193, Standard Practice for Stitches and Seams, 1997 (2004), ANSI/BHMAA156.4, Standard for Door Controls (Closers), ANSI/BHMA A156.17, Standard for Self Closing Hinges & Pivots, References for Extracts in Mandatory Sections. NFPA 72, National FireAlarm and Signaling Code, edition. NFPA 220, Standard on Types of Building Construction, edition. NFPA 5000, Building Construction and Safety Code, edition. Update references to most current edition. Printed on 10/4/2011 2

4 Report on Comments June 2012 NFPA Log #2 John F. Bender, Underwriters Laboratories Inc Revise text as follows: UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL ANSI/UL 9,, ANSI/UL 10A,, ANSI/UL 14C,, 2006 Revised ANSI/UL 33,, UL 555,, 2006, Revised D.2 The hourly designation indicates the duration of the fire test exposure and is known as the fire protection rating. Fire protection ratings of fire doors meeting this standard should be as determined and reported by a testing agency in accordance with NFPA 252, Standard Methods of Fire Tests of Door Assemblies. (See ASTM E 2074, Standard Test Method for Fire Tests of Door Assemblies, Including Positive Pressure Testing of Side-Hinged and Pivoted Swinging Door Assemblies; ANSI/UL 10B, Standard for Safety Fire Tests of Door Assemblies; ANSI/UL 10C, Standard for Positive Pressure Fire Tests of Door Assemblies; and CAN4-S104-M80, Standard Method for Fire Test of Door Assemblies.) D.10 The hourly designation indicates the duration of the fire test exposure and is known as the fire protection rating. Fire protection ratings of windows meeting this standard should be as determined and reported by a testing agency in accordance with NFPA 257, Standard on Fire Test for Window and Glass Block Assemblies. (See ASTM E 2010, Standard Test Method for Positive Pressure Fire Tests of Window Assemblies; ANSI/UL 9, Standard for Safety Fire Tests of Window Assemblies; and CAN4-S106-M80, Standard Method for Fire Test of Window and Glass Block Assemblies.) L UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL ANSI/UL 9, Standard for Safety Fire Tests of Window Assemblies, ANSI/UL 10B, Standard for Safety Fire Tests of Door Assemblies, 2008, Revised ANSI/UL 10C, Standard for Positive Pressure Fire Tests of Door Assemblies, UL 752, Standard for Safety Bullet-Resisting Equipment, 2005, Revised Fire Resistance Directory, Add ANSI approval designation to ANSI/UL 9, ANSI/UL 10A, ANSI/UL 10B, ANSI/UL 10C, ANSI/UL 14C and ANSI/UL 33 and update references to current edition Log #10 Allison C. Carey, Koffel Associates, Inc Revise text to read as follows: Fire Door Assembly. Any combination of a fire door, a frame, hardware, and other accessories that together provide a specific degree of fire protection or fire resistance to the opening. A fire resistance rating provides the same level of protection in the opening as the assembly that was established during the fire test. The fire test for a fire resistance rating limits the temperature transmission to the unexposed side of the assembly. A fire protection rating is determined for opening protectives and does not provide the same level of fire resistance as the assembly. A fire protection rating provides a lesser degree of protection than a fire resistance rating. NFPA 80 does not address fire resistance-rated glazing and certain types of doors. Printed on 10/4/2011 3

5 Report on Comments June 2012 NFPA Log #3 Thomas Zaremba, Roetzel and Andress / Rep. Alliance of Primary Fire Rated Glazing Manufacturers Revise text to read as follows: For new wood doors, glazing materials in vision panels shall be installed in labeled glass light kits or in accordance with the fire door listing and shall be installed in accordance with inspection service procedure and under label service, or by certified or listed personnel, or by approved and qualified persons. The text developed and favorably voted on by the Technical Committee at the ROP was intended to provide greater compliance options by allowing glazing in vision panels to be installed in new wood doors either (i) under label service (as currently allowed), or (ii) by certified or listed personnel. By adding approved and qualified persons to those permitted to install vision panels in new wood doors, an additional compliance option is added with no loss in safety. The term Approved is defined in Chapter 3 to mean [a]cceptable to the authority having jurisdiction and the term qualified person is defined to mean [a] person who, by possession of a recognized degree, certificate, professional standing, or skill, and who, by knowledge, training, and experience, has demonstrated the ability to deal with the subject matter, the work, or the project. Whether or not the Committee ultimately decides to include certified or listed personnel in this section, adding approved and qualified persons expands compliance options while assuring that those installing glazing in vision panels are both acceptable to the authority having jurisdiction and technically qualified to do the work. Accepting this language is essentially going against the committee's language in 2010 edition in which NFPA 80 specifically requires the glazing materials to be installed in accordance with inspection service procedure and under label service. The language added at the ROP for certified and listed personnel provides the necessary criteria to ensure that trained and tested individuals are installing the kits. Adding the proposed text allows other parties to perform installations who may not have the appropriate abilities which also goes against the 2010 language as well as the ROP language. The committee notes that the language "or by approved and qualified persons" is the only language being proposed by this comment. Additional text was inadvertently underlined in the comment but is not new text Log #7 Joshua Elvove, U.S. General Services Administration Reject ROP as modified by the technical committee. Concur with all three committee member s explanation of negative. Without a national recognized certification program in place, one cannot mandate products be installed by such a program. We building owners went through this before with fire extinguishers; let s not do this again for fire doors. Note: I am ok with changing certified or listed to qualified persons since that is a defined and recognized term. Revise text to read as follows: For new wood doors, glazing materials in vision panels shall be installed in labeled glass light kits or in accordance with the fire door listing and shall be installed in accordance with inspection service procedure and under label service or by certified or listed personnel. The committee is in agreement with the submitter. Currently, a glazing installation certification program is not available for review and reference by the committee. The action taken satisfies the submitter's intent. The committee will review this issue again during next cycle to determine if there are established and credible certificate programs in place. Printed on 10/4/2011 4

6 Report on Comments June 2012 NFPA Log #12 Michael A. Anthony, University of Michigan / Rep. APPA.ORG - Leadership in Education Association of Education Facility Executives Modify the proposal by adding the following: Periodic inspections and testing shall be performed not less than annually. Most users of NFPA consensus documents do not have the O&M budget to conform to all of the building codes and related regulations. Owners should have the option to scale their resources according to the degree of hazard and AHJ's should not be put at risk by approving relaxed testing intervals that are practical and result in a net increase in occupant safety. The frequency of fire door inspections can be altered and completed via the performance based option found in Chapter 5. The proposed text is already covered by this option Log #CC2 Technical Committee on Fire Doors and Windows, ***Insert Include LCC2 Here*** This comment further revises Chapter 5 from the work of the committee at the ROP phase. Chapter 5 is being shown as a complete revision as many additional editorial and technical changes were made. Accepted changes from the ROP actions are also included. Editorial revisions were made to clarify the application of the Chapter to include all fire doors, fire shutters and fire window assemblies. Multiple annex notes were added to aid in the application of field modifications, generic use of opening protectives, periodic inspections, and inspection and testing reports. The provisions related to the maintenance of fire doors, fire shutters and fire window assemblies have been moved to the end of the Chapter to be consistent with other inspection, testing, and maintenance documents as well as consistent with the title of the Chapter. Additional details were added to the section on inspections and testing to describe the components of records that are required for initial testing, acceptance testing and periodic inspections. This language adds detail to the standard where it lacked in prior editions. The language recognizes multiple forms of records that are being used in the field today including written records as well as computer records or barcode records. Provisions are also provided regarding record retention and content of the records. Necessary mandatory and advisory text is included on this topic. This chapter is the product of much work and revision completed at both the ROP and ROC meetings of this Committee. It should be noted that additional changes were acted on in public comments regarding Chapter 5. These have not been incorporated here. Printed on 10/4/2011 5

7 1. Delete A Delete Chapter 5 from ROP and replace with text to read as follows: Chapter 5 to Inspection, Testing, and Maintenance 5.1* General. A.5.1 Walls with openings have less fire resistance than unpierced walls. Fire doors, shutters, and fire windows are designed to protect the opening under normal conditions of use, with clear spaces on both sides of the opening. Where the opening is not used and combustible material could be piled against or near the door, window, or shutter, the designed protection cannot be expected Application * This chapter shall cover the inspection, testing, and maintenance of fire doors, fire shutters, fire windows, and opening protectives other than fire dampers and fabric fire safety curtains. A See Chapter 19 for fire dampers and Chapter 20 for fabric fire safety curtains The requirements of this chapter shall apply to new and existing installations Operability Doors, shutters, and windows shall be operable at all times Doors, shutters, and windows shall be kept closed and latched or arranged for automatic closing Replacement. Where it is necessary to replace fire doors, shutters, windows or their frames, glazing materials, hardware, and closing mechanisms, replacements shall meet the requirements for fire protection and shall be installed and tested as required by this standard for new installations Field Modifications * In cases where a field modification to a fire door or a fire door assembly is desired and is not permitted by sections through , the laboratory with which the product or component being modified is listed shall be contacted through 80/LCC2/A2012/ROC 1

8 the manufacturer and a written or graphic description of the modifications shall be presented to that laboratory. (ROP 80-19) A Field modifications beyond the scope of the prescriptive allowances permitted by sections through typically result in voiding the fire rating of the assembly. Section provides an alternative method whereby proposed modifications may be documented and presented to the labeling agency prior to work commencing. Where the proposed modification(s) are within the parameters of the manufacturer s procedures, and will not degrade the fire resistance of the assembly, the labeling agency is permitted to authorize such modifications without a requirement for a subsequent field inspection Field modifications shall be permitted without a field visit from the laboratory upon written authorization from that laboratory. (ROP 80-20) Removal of Door or Window. Where a fire door or fire window opening is no longer in use, the opening shall be filled with fire resistance rated construction equivalent to that of the wall. 5.2* Inspections and Testing. A.5.2 Doors, shutters, and windows are of no value unless they are properly maintained and closed or are able to close at the time of fire. A periodic inspection and maintenance program should be implemented and should be the responsibility of the property management * Upon completion of the installation, door, shutters and window assemblies shall be inspected and tested in accordance with Section A Hinges, catches, closers, latches, and stay rollers are especially subject to wear * A record of all inspections and testing shall be signed by the inspector and kept for inspection by the AHJ. A Newer technology includes use of bar codes and other electronic devices. This section recognizes that completed and filed bar code reports should be considered signed by the inspector Records of acceptance tests shall be retained for the life of the assembly * Unless a longer period is required by 5.4, records shall be retained for a period of at least three years. 80/LCC2/A2012/ROC 2

9 A In many cases AHJs are not able to inspect each building in their jurisdiction each year. Inspection and testing records need to be retained during the intervening periods between the AHJ's formal visits to provide evidence that the inspections and testing were performed as required by this standard. Additionally, maintenance records documenting that the necessary corrective actions have been made in accordance with this standard should be stored with the inspection and testing records for the same period of time. Retaining the records for seven (7) allows the AHJ the ability to look back over an extended period of time to verify that the fire door assemblies are being properly maintained The records shall be kept on a medium that will survive the retention period. Paper or electronic media shall be permitted. [NFPA 72, ] A Installation of new fire door assemblies should be documented in the same manner and level of detail as the periodic inspections and testing of fire door assemblies required by and Records of new fire door assemblies should be retained with the periodic inspections and testing records for the facility A record of all inspections and testing shall be provided that includes, but is not limited to, the following information: (1) Date of inspection (2) Name of facility (3) Address of facility (4) Name of person(s) performing inspections and testing (5) Company name and address of inspecting company (6) Signature of inspector of record (7) Individual record of each inspected and tested fire door assembly (8)* Opening identifier and location of each inspected and tested fire door assembly A (8) Each fire door assembly inspected and tested should be assigned a unique identifier code (e.g., door number as assigned by the facility) that can be used to track the assembly's compliance and maintenance records throughout the lifetime of its installation. Identifier codes could be a door assembly number, bar code, or other code that is unique to each fire door assembly. (9)* Type and description of each inspected and tested fire door assembly A (9) To aid the AHJ during the review of the inspections and testing reports, the records should include a description of the type of fire door assembly. Type 6: Swinging Door with Builders Hardware Type 7: Swinging Fire Door with Fire Door Hardware Type 8: Horizontally Sliding Fire Door Type 9: Special Purpose Horizontally Accordion or Folding Door 80/LCC2/A2012/ROC 3

10 Type 10: Vertically Sliding Fire Door Type 11: Rolling Steel Door Type 12: Fire Shutter Type 13: Service Counter Fire Door Type 14: Hoistway Doors for Elevators and Dumbwaiter Type 15: Chute Door Type 16: Access Door Type 17: Fire Window (10)* Verification of visual inspection and functional operation A (10) Functional operation of fire door assemblies should include testing of the closing device, complete closure of the fire door, and full engagement of latch(es) where required by door type. Functional testing of automatic-closing or poweroperated fire door assemblies and electrically-controlled latching hardware or release devices might need to be coordinated with the facility during other electricallycontrolled system tests. (11) Listing of deficiencies in accordance with 5.2.3, 5.3, and * Upon completion of maintenance work, fire door assemblies shall be inspected and tested in accordance with A Existing fire door assemblies that have been repaired should be inspected and tested immediately upon completion of the repair work to ensure that they are in compliance with this standard Acceptance Testing Acceptance testing of fire door and window assemblies shall be performed by a qualified person with knowledge and understanding of the operating components of the type of assembly being subject to testing. (ROP 80-21) Before testing, a visual inspection shall be performed to identify any damaged or missing parts that can create a hazard during testing or affect operation or resetting Acceptance testing shall include the closing of the door by all means of activation A record of these inspections and testing shall be made in accordance with /LCC2/A2012/ROC 4

11 Swinging Doors with Builders Hardware or Fire Door Hardware Fire door assemblies shall be visually inspected from both sides to assess the overall condition of door assembly As a minimum, the following items shall be verified: (1) Labels shall be clearly visible and legible. (2) No open holes or breaks exist in surfaces of either the door or frame. (3) Glazing, vision light frames, and glazing beads are intact and securely fastened in place, if so equipped. (4) The door, frame, hinges, hardware, and noncombustible threshold are secured, aligned, and in working order with no visible signs of damage. (5) No parts are missing or broken. (6) Door clearances do not exceed clearances listed in and (7) The self-closing device is operational; that is, the active door completely closes when operated from the full open position. (8) If a coordinator is installed, the inactive leaf closes before the active leaf. (9) Latching hardware operates and secures the door when it is in the closed position. (10) Auxiliary hardware items that interfere or prohibit operation are not installed on the door or frame. (11) No field modifications to the door assembly have been performed that void the label. (12) Meeting edge protection, gasketing and edge seals, where required, are inspected to verify their presence and integrity Horizontally Sliding, Vertically Sliding, and Rolling Doors Fire door assemblies shall be visually inspected from both sides to assess the overall condition of door assembly The following items shall be verified: (1) Labels shall be clearly visible and legible. (2) No open holes or breaks exist in surfaces of either the door or frame. (3) Slats, endlocks, bottom bar, guide assembly, curtain entry, hood, and flame baffle are correctly installed and intact, for rolling steel fire doors. (4) Glazing, vision light frames, and glazing beads are intact and securely fastened in place, if so equipped. (5) Curtain, barrel, and guides are aligned, level, plumb, and true for rolling steel fire doors. (6) Expansion clearance is maintained in accordance with manufacturer s listing. (7) Drop release arms and weights are not blocked or wedged. 80/LCC2/A2012/ROC 5

12 (8) Mounting and assembly bolts are intact and secured. (9) Attachments to jambs are with bolts, expansion anchors, or as otherwise required by the listing. (10) Smoke detectors, if equipped, are installed and operational. (11) No parts are missing or broken. (12)* Fusible links, if equipped, are in the location; chain/cable, s-hooks, eyes, and so forth, are in good condition, the cable or chain are not kinked, pinched, twisted, or inflexible and links are not painted or coated with dust or grease. A (12) Fusible links should not be coated with any materials such as fireproofing, drywall compound, or spray texturing. (13) Auxiliary hardware items that interfere or prohibit operation are not installed on the door or frame. (14) No field modifications to the door assembly have been performed that void the label. (15) Verify that doors have an average closing speed of not less than 6 in./sec (152 mm/sec) or more than 24 in./sec (610 mm/sec) Closing Devices All fire doors, fire shutters, and fire window assemblies shall be inspected and tested to check for proper operation and full closure Resetting of automatic-closing device shall be done in accordance with the manufacturer s instructions Rolling Steel Fire Doors Rolling steel fire doors shall be drop tested twice The first test shall be to check for proper operation and full closure A second test shall be done to verify that the automatic-closing device has been reset correctly * Fusible links, release devices, and any other moveable parts shall not be painted or coated with other materials that may interfere with the operation of the assembly. A Movable parts of the door assembly can include but are not limited to stay rollers, gears, and closing mechanisms Periodic Inspection and Testing 80/LCC2/A2012/ROC 6

13 * Periodic inspections and testing shall be performed not less than annually. A Doors subject to high volume use and abuse may warrant an increased frequency of inspection. Components including but not limited to hinges, catches, closers, latches, and stay rollers are especially subject to wear As a minimum, the provisions of Section shall be included in the periodic inspection and testing procedure Inspection shall include an operational test for automatic-closing doors and windows to verify that the assembly will close under fire conditions Assembly shall be reset after a successful test Resetting of the release mechanism shall be done in accordance with manufacturer s instructions * Hardware shall be examined, and inoperative hardware, parts, or other defects shall be replaced without delay. A The determination of the time of required for corrective action should be based on a risk analysis and availability of replacement materials. (from ROP 80-18) Tin-clad and kalamein doors shall be inspected for dry rot of the wood core Chains or cables employed shall be inspected for excessive wear, stretching and binding. 5.3 Retrofit Operators The operator, governor, and automatic-closing device on rolling steel fire doors shall be permitted to be retrofitted with a labeled retrofit operator under the conditions specified in through The retrofit operator shall be labeled as such The retrofit operator shall be installed in accordance with its installation instructions and listing The installation shall be acceptable to the AHJ. 80/LCC2/A2012/ROC 7

14 5.3.5 The retrofit operator shall be permitted to be provided by a manufacturer other than the original manufacturer of the rolling steel fire door on which it is retrofitted, provided its listing allows it to be retrofitted on that manufacturer s doors. 5.4* Performance-Based Option. A.5.4 See Annex J for information regarding performance based inspection, testing, and maintenance options for fire door assemblies As an alternate means of compliance with 5.2.4, subject to the AHJ, fire door assemblies shall be permitted to be inspected, tested, and maintained under a written performance based program Goals established under a performance-based program shall provide assurance that the fire door assembly will perform its intended function when exposed to fire conditions Technical justification for inspection, testing, and maintenance intervals shall be documented in writing The performance-based option shall include historical data acceptable to the AHJ. 5.5 Maintenance 5.5.1* Repairs shall be made, and defects that could interfere with operation shall be corrected without delay. A The determination of the time of required for corrective action should be based on a risk analysis and availability of replacement materials. (from ROP 80-18) Damaged glazing material shall be replaced with labeled glazing Replacement glazing materials shall be installed in accordance with their individual listing Any breaks in the face covering of doors shall be repaired without delay Where a fire door, frame, or any part of its appurtenances is damaged to the extent that it could impair the door s proper emergency function, the following actions shall be performed: (1) The fire door, frame, door assembly, or any part of its appurtenances shall be repaired with labeled parts or parts obtained from the original manufacturer. 80/LCC2/A2012/ROC 8

15 (2) The door shall be tested to ensure emergency operation and closing upon completion of the repairs If repairs cannot be made with labeled components or parts obtained from the original manufacturer or retrofitted in accordance with Section 5.3, the fire door frame, fire door assembly, or appurtenances shall be replaced When holes are left in a door or frame due to changes or removal of hardware or plant-ons, the holes shall be repaired by the following methods: (1) Install steel fasteners that completely fill the holes (2) Fill the screw or bolt holes with the same material as the door or frame 80/LCC2/A2012/ROC 9

16 Report on Comments June 2012 NFPA Log #5 Thomas Zaremba, Roetzel and Andress / Rep. Alliance of Primary Fire Rated Glazing Manufacturers Revise text to read as follows: If where a fire door or fire window is opening is no longer in use removed and not replaced, the opening shall be filled with fire resistance rated construction material equivalent to that of the wall. The Technical Committee s proposal is intended to reorganize and update Chapter 5. In that spirit, of the current code (renumbered as 5.5 in Proposal No ), requires an update. The intent of this section is not to determine when a fire door or fire window is no longer in use. Instead, it is intended to require that, if a fire window or fire door is removed, but not replaced, the opening be filled with rated materials equivalent to the wall. This section of the code should be updated to focus the language of this section on its intended purpose and to delete language that is undefined and unnecessary. Revise text to read as follows: 5.5 Removal of Door or Window. Where a door or window opening is no longer in use, the opening shall be filled with construction equivalent to that of the wall. Removal of Door or Window. Where a fire door or fire window opening no longer functions as an opening, or the door or window is removed and not replaced, the opening shall be filled to maintain the required rating of the wall assembly. The revised text provides additional clarification as to what to do with an opening when a fire door or fire window is removed. It is critical that the door or window be removed in an opening where it is no longer functioning as an opening, such as a door that is no longer needed and is being used as a wall. It is noted that section 5.5 was the section reference from Proposal The section may change with the additional revisions of Chapter 5. Printed on 10/4/2011 6

17 Report on Comments June 2012 NFPA Log #13 Garrett S. Tom, International Fire Door Inspector Association Delete through the manufacturer In cases where a field modification to a fire door or a fire door assembly is desired, the laboratory with which the product or component being modified is listed shall be contacted through the manufacturer and a written or graphic description of the modifications shall be presented to that laboratory. Current practice for requests directed to the listing agency for review of field modifications of fire door assemblies commonly come from building owners, contractors, architects and manufacturers. Deleting the new text through the manufacturer would permit current practice to continue. The proposal as written would be a limitation and is not common and current industry practice based on my previous experience at a listing agency conducting field evaluations. Adding the limitation of contact with the listing agency only through the manufacturer would create issues if the manufacturer is no longer in business. The listing agency review would not be possible. An example would be a fire door frame. The frame is constructed to Subject 63 and the field modification continues to comply with Subject 63. If the frame manufacturer is no longer in business, the frame would need to be replaced at significant expense because the manufacturer would not be available to request the listing agency review. The perception that the manufacturer of the fire rated component is the only entity permitted to contact the listing agency could also be looked upon as a means to require the purchase of a new fire rated component if the manufacturer declined to contact the listing agency. I do support the need for the manufacturer to be involved if proprietary test information must be accessed to evaluate the field modification but not to specify the manufacturer is the only entity who can contact the listing agency. Add new text to read as follows: Field Modifications When the manufacturer is no longer available the laboratory shall be permitted to provide an engineering evaluation supporting the field modification. The submitter is correct in that guidance should be provided in the document to address the condition when a door manufacturer is no longer in business or available. The current requirements on field modifications should be retained as it is the committee's intent that the manufacturer is to be contacted when a modification is proposed for their door or product. Printed on 10/4/2011 7

18 Report on Comments June 2012 NFPA Log #8 Joshua Elvove, U.S. General Services Administration Reject ROP We re seeing a proliferation of requirements that only seek individuals with superior credentials to perform rudimentary tasks. I m ok with upping the credentials of individuals who are tasked to do certain tests that warrant additional education or experience, but come on, for verifying that fire door closes and latches, what type of credentials are necessary? We fought this battle in NFPA 101 for means of egress doors - here s what it says: Functional testing of door assemblies shall be performed by individuals who can demonstrate knowledge and understanding of the operating components of the type of door being subjected to testing. The NFPA 72 TMS committee is correcting this problem now for inspecting and testing fire alarm systems; hence, we don t need to create another problem in NFPA 80 (or 105 if similar text has been proposed there). Use the term qualified persons where such persons are necessary, but give owners the opportunity to use their own staff to do the simple tasks. I am therefore seeking rejection of this proposal; however, I m not adverse to revising the text so that there is a clear division as to what a qualified person needs to do vis-à-vis what an individual with knowledge and understanding. can do. The definition of qualified person as provided in NFPA 80 Chapter 3 is appropriate for this location in the standard. The addition of 'qualified person' does not eliminate any of the individuals mentioned by the submitter as they are still permitted to perform the tasks as noted by meeting the definition of 'qualified person' Log #1 John W. Palmieri, Inspection Help, LLC Add new text to read as follows: (12) Signage affixed to a door must meet the requirements listed in Signage can be added to a fire door at any time and because it can have a significant impact on a door's fire safety rating, it should be part of the minimum inspection criteria Log #14 Michael Tierney, Builders Hardware Manufacturers Association Change to: The length of continuous hinges shall be within one inch of the height of the door leaves. To provide a tolerance for the hinge length reflecting industry practice. Printed on 10/4/2011 8

19 Report on Comments June 2012 NFPA Log #9 William E. Koffel, Koffel Assoc., Inc. / Rep. Won-Door Corporation Revise text to read as follows: Closing devises shall be listed in accordance with UL 864,. When the language was originally included in NFPA 80, UL 864 was the standard established by UL for the motor/control system driving the horizontal sliding fire door assembly. UL 864, is a nationally recognized standard that provides appropriate tests and guidelines to assure compatibility. It further deals with critical functions such as alarm verification, endurance, life safety networks, notification, power supplies, resets, risk of electrical shock, risk of fire, standby power sources, storage batteries, dual power source systems, supervisory signals, and trouble signals. In order to ensure the fire protection integrity and operational reliability of this product category, it is imperative that the closing devices be labeled to a signaling standard. Because the UL 864 standard is not specifically referenced in NFPA, it leaves open a standard against which to do the testing. Holding said closing devices to a nationally recognized standard ensures consistency and reliability for Special Purpose Horizontally Sliding Accordion Style Opening Protectives. The Committee noted that some products have been listed using another UL Standard (UL 325). It is recognized that this is the case but the requirements of NFPA 80 are not retroactive and as such will not impact existing products unless the AHJ determines the lack of compliance with the current provisions represent an unacceptable hazard. It is also recognized that the industry is trending towards the use of UL 864 and that UL 864 is being revised to better address the issues. The 2013 Edition of NFPA 80 will be the edition referenced in the 2015 Edition of the NFPA codes and the I-codes. If the revision is not incorporated into this coming edition of NFPA 80, it will be the 2018 editions of the codes when the revisions could then be incorporated by a reference to the next edition of NFPA 80. Printed on 10/4/2011 9

20 Report on Comments June 2012 NFPA Log #4 Thomas Zaremba, Roetzel and Andress / Rep. Alliance of Primary Fire Rated Glazing Manufacturers Revise text to read as follows: Walls with openings will typically have less be fire resistantce for a shorter period than unpierced walls without openings. Fire doors, shutters, and fire windows are designed to protect the openings under normal conditions of use, with clear spaces on both sides of the opening. Where the door opening is not used and combustible material is could be piled against or near the door, window, or shutter, the fire door may not provide its full level of rated fire protection. designed protection cannot be expected. The Technical Committee s proposal is intended to reorganize and update Chapter 5. In that spirit, A.5.1 needs updating. It is awkward and makes overstatements. First, use of the term unpierced to describe the absence of openings in a wall is inappropriate. The dictionary definition of pierced means: punctured or perforated, as to form a decorative design. Second, it is true that 20-minute doors are permitted in 1-hour rated corridors based, in part, on the assumption that the need to enter and exit through the doorway will naturally prevent fuel loads from piling up against one or both sides of the door. It is also true that piling combustibles against a fire door could jeopardize its designed protection. However, the same is not true of rated windows or shutters. In that regard, windows and shutters are not necessarily designed to protect openings with clear spaces on both sides. Windows and shutters have a higher required fire protection rating and can be expected to perform to those higher levels of performance whether they are in proximity to combustible materials or not. A.5.1 should be updated to be more accurate and include more appropriate language. Revise text to read as follows: A.5.1 Walls with openings have less fire resistance than unpierced walls. Fire doors, shutters, and fire windows are designed to protect the opening under normal conditions of use, with clear spaces on both sides of the opening. Where the opening is not used and combustible material could be piled against or near the door, window, or shutter, the designed protection cannot be expected. A.5.1 Fire doors, fire shutters, and fire windows are designed to protect the opening under normal conditions of use, with clear spaces on both sides of the opening. Typically, fire doors, fire shutters, and fire windows will provide a lesser rating than the wall and generally allow heat transmission through the assembly. Combustible materials should not be piled against or near the door, window or shutter. New annex language clarifies the intended design and function of fire doors, fire shutters and fire windows. Printed on 10/4/