john a. mccann, kemper nat'l insurance cos., ma …...16-2.4.3.1 quarterly a visual .., and a...

Report of the Committee on

Fire Doors and Windows

Harold D. Hicks, Jr . , Chair Adant ic Code Consul tants , PA[SE]

T h o m a s H. Allen, Smoke Guard Corp., ID [M] Rep. Amer ican Inst. of Arclfitects

Richard B. Alpert, Tr iad Fire Protection Engr Corp., PA[SE] Calvin A. Banning, Duke Engr & Services, TX [SE] Walter S. Beattie, CIGNA Property & Casualty, PA [I]

Rep. Amer ican Insurance Services Group, Inc. Gregory J. Cahanin , St. Petersburg, FL [II]

Rep. Louis iana State Fi remen 's Assn. Paul R. ColemaM, Sisters of Providence, OR [U}

Rep. NFPA Healda Care Section Richard Cookson, The Cookson Co., AZ [M]

Rep. Amer ican Rolling Door Inst. Edward A. Donoghue , Edward A D o n o g h u e Assoc., Inc., NY [M]

Rep. Nat'l Elevator Industry Inc. (Vote Ltd. to Elevator Issues)

Philip C. Favro, Philip C. Favro & Assoc., CA [SE] David A. Gilda, Builders Hardware Mfrs. Assn., CT [M]

J oe C. Goldman, Kemper Nat'l Insurance Co., CA [I] ffrey E. Gould, Factory Mutual Researcb Corp., MA [I] ayne D. Holmes , HSB Professional Loss Control Inc., CT [I]

T h o m a s R. Janicak, Ceco Door P roduc t s / A Uni ted Donfinion Co., TN [M] Rep. Steel Door Inst.

Donald L. King, Steelcraft Mfr. Co., OH [M] Rep. Insulated Steel Door Systems Inst.

William E. Koffel , Jr. , Koffel Assoc., Inc., MD [SE] JRoseph G. Lesniak, Door & Hardware Inst., VA [M]

ober t Do Lichfield, Bechtel Hanford Inc., WA [U] George E. Meyer, Warnock Hersey, Inc., CA [RT] Ronald Rispoli, Entergy Corp., AR [U] Joseph N. Sa in t , Sa i n t Divis ion- Chase Industries, TN [MI

Rep. NAAMM David A. San Pat io , T he Maiman Co., M e [M]

Rep. Nat'l Wood Window & [)nor Assn. Emmanue l A. Sopeju, I Inderwriters" Laboratories of Canada,

()N, Canada [RT] Richard P. Thornber ry , The (.'ode Consor t ium, Inc., CA [SE] J ames j . Urban, Underwri ters Laborator ies Inc., IL [RT] Ronald C. Walling, R & R Wailing Assoc., (;A [SEI

Alternates

Rober t A. Bullard, KHB C o r p , Inc., FL [M] (Alt. t o J . G. Lesniak)

John P. Cauley, Factory Mutual Research Corp., MA [l]- (Ah. to J. E. Gould)

Diane Dollber, HSB Professional Loss Control, TX [1] (Alt. to W. D. Holmes)

Howard J. Gruszynski , Underwri ters Laboratories Inc., IL [RTI (Ah. to j . j . Urban)

Steven C. Hahn , Pacific Rolling Door Co., CA [M} (Alt. to R. Cookson)

Stan Horsfal l , Curries Co., IA [M] (AlL to T. R.Janicak)

Richard A. H u d n u t , Builders Hardware Mfrs Assn., NY [M] (Alt. to D. A. Gilda)

J a m e s J . Husom, Warnock Herse7 Int'l, Inc., WI [RT] (Alt. to G. E. Meyer)

Fredrlck C. I res , Schindler Elevator Corp., PA [M] (Ah. to E. A. Dona ghue ) (Vote Ltd. to Elevator Issues)

John A. McCann , Kemper Nat'l Insurance Cos., MA I l l (/kit. to J. C. Goldman)

Brian W. Melly, Triad Fire Protection Eflgr (;orp., I'A I SEI (Alt. to R. B. Alpert)

Allan P. Rhodes , Duke Engr & Services (DE&.~;). (;A i.'~EI (Air. to C. A. Banning)

Julie Ruth, Nat'l W o o d Witictow & D o . r Assn.. II, I MI (AIt. to D. A. Sail Pat io)

No nvot ing

John G. Degenkolb, (]arson City, NV (Member Emeritus)

Start Liaison: J ames D. Lake

This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A k~ to cb*ssifications is Jound at ttwfront of this book.

Committee Scope: This Commit tee shall have primary responsibility for d o c u m e n t s on tile installation and maintenm~ce of fire doors, windows, shutters , and other e q u i p m e n t used to restrict die spread of fire. inc luding a r rangenlen ts for automat ic opera t ion in c,'~se of fire. This includes installation to protect bui ldings against external fire and to restrict the spread of fire within buildings. Vault and record room doors are covered by the Technical Commi t tee on Record Protection.

This por t ion of the Technical Commi t tee ReporI ot tll~ Commi t tee on Fire Doors and Windows is presented 1o~ adopt ion in 2 parts.

Part 1 of this Report o n ( ~ [ l l l l l n t c i l [ . ¢, W~LK pre[i ,ne(l i) ~, tilt Technical Commi t t ee on Fire Doors and Windows. ,tHi| doculneulLs its act'i0n Oil the Clilnlllenls re,zeived tin ils Rt-i.itll'l till Propoglls on NFPA SIJ-lt.l~.lS, S tandard for Fire Doors and Fire Windows, as pliblished itl lhc Rel, lr i - n I'rl~tl~lsals h~l the 1908 Fall Meeting.

] 'his docurnent when adop ted will be retiiled as NFPA 811. S tandard for Fire Doors. Fire Windows and Smoke Control Door Assemblies .

Part I of this Report on C o m m e n t s ha.s been submi t ted t(~ letter ballot o f the Technical Commit tee on Fire Deors and Windows, which consists o f 27 vot ing members, The results o f the balloting, ~ffter circulat ion of any uegative votes, ~.an be found in tbe report.

Part II of this Report oil ( ;omroents was prepm'e,l by the Technical Commi t t ee on Fire Doors and Windows, and d o c u m e n t s its action on the commen t s received on its Report on Proposals on NFPA 105-1993, R e c o m m e n d e d Practice for the Installation of Smoke-Control Door Assemblies , ;~.s publ ished in the Report on Proposals for the 1998 Fall Meeting.

Part II of this Report on C o m m e n t s has been submi t ted to letter ballot of the Technical Commi t t ee on Fire Doors and Windows, which consists of 27 voting members . The resuhs of the balloting, ,alter circulation of any negative votes, can lie f ound in the report.

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PART I

(Log #3) 80- 1 - (Entire Document): Accept SUBMrl"rER: Jeffrey E." Gould, Factory Mutual Research Corp. COMMENT ON PROPOSAL NO: 80-1 RECOMMENDATION: The revised wording in the rewritten document is incorrect as follows:

1-10.2 All detectors including fusible links, shall not be placed in the dead air space... (The word "not" has been mistakenl,/ omitted from the proposal.)

1-10.6.1" Exception No. 4: For shutters, fusible links shall be located in

dae proximity of dte shutter near the tog.p_ of the opening m~d... (The word "top" has been misspelled ms tip in the proposal.)

16-2.4.3.1 Quarterly a visual .., and a functional test in accordance witb ]..~2.4.3.2 shall be performed. (The wording references 15-2.4.3.2 which does not exist. Section 16-2.4.3.2 is the correct reference.)

16-2.6.2 Devices that utilize ma open fl,'une shall not be used to test.,. (The words "be used" are misspelled in the proposal.)

A-l-10.6.1 The arr, 'mgements shown._ (The proposal shows Paragraph A-I-10.5.1 as tbe paragraph number which is incorrect. The wording refers to Paragraplt 1-10.6.1, riot 1-10.5.1.) SUBSTANTIATION: In rewriting tbis document, several typograpltical errors, omissions, or incorrect references have been ntade. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 26 NOT RETURNED: 1 Goldman

(Log #14) 80- 2 - (1-3.4 Exception): Reject SUBMITTER: Richard E. Thonnings, American Insurance Services Group, Inc. COMMENT ON PROPOSAL NO: 80-5 RECOMMENDATION: Insert a new Appendix A note as follows:

A-1-3.4 Exceotion. Access doors modified for an electrically coqtrolled lock or latch may void the listin~ for the door assembly. Refer to t i e specific lisdn~ for additionM information. SUBSTANTIATION: Proposal 80-5, Log #38, identifies a real world problem which needs to be recognized by NFPA 80. Art appendix item would at least call attention to the issue. The Committee's action witb tiffs proposal appears to be inconsistent with its action regarding Proposal 80-51, Log #39. The Committee, as a minimum, should form a task group to investigate this issue more dmroughly in order to determine F, ½ate a tio.

EE ACTION: Reject. COMMITTEE STATEMENT: NFPA 80 currently requires listing of all devices ,associated with fire doors. A list of specific devices in die appendix is not necessary. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NEGATIVE: 1 NOT RETURNED: l Goldman

EXPLANATION OF NEGATIVE: BEATTIE: The isstie of voiding tim UL listing is valid, not only

with locks, but also with many other modifications. The ,after market lock installation is a particularly common problem, and this would address that problem specifically.

Access Door, Horizont:d. An access door installed m thv borizontal plane used to protect openings in P,;'c :'a~c:! P,.~;:':: ~:; ceilings of fire rated floor-ceiling or roof-ceiling asseml~lies.

Floor Fire Door Assembly. A combiuatiotJ o1 a fire do t . , frame, hardware, and other ao:essories, installed in a honzqmt,d Diane. that provide a specific degree OI life IeSlSt~lllt e D) ,l through oDenin~ in a fire rated t oo l , SUBSTANTIATION: This revisitm ot NFPA xo provuh.s ,t differentiation between access doors in ceilings of fire faled l](~t,i- ceiling and r o o f ceiling ~semblies and a floor fire dooF whwh protects a through opening fl'om one story to ,tnotber. l'he differences between the two ,tpplications may he ilnporL~tnt leot e~m]ple, the exception for latching found it] Parag~lph 11-2.3 was probably meant to apply only to acce~ doors in suspeDded ceiling systems, yet the current NFPA 80 format results in the exception applying to both acces.s doors and fire doors at through penemit ions of a floor. Adding separate definitions tol access doors and floor fire doors provides tile opportunity for differing requirements for floor tire doors and access doors. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: There is no clear distinction o1 tlus product definition used for listing purposes. Therefore, the Committee is not convinced of the need for a separate defimtiolJ and recognition in tile standard at this time. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 23 NEGATIVE: 2 ABSTENTION: 1 NOT RETURNED: 1 Goldmmt

EXPLANATION OF NEGATIVE: BEATTIE: Mr. Belles' reasoning appears v:did, and the

definition should be added to avoid confusion. FAVR(): I disagree with the Committee Acti,m oi~ this ut.m.

It is my feeling that the proposed defiuititm is b~)th clear ,ttld necessary. Without a definition, authorities baviugjurisdicu,,u frequently have difficulty interpreting code intent and pl(q ~t'l applic~ttion of certain requirements. The mclusioll - I this definidon will help obviate the ueed for this kind ul ,llflicult iuterpretation. EXPLANATION OF ABSTENTION:

K()FFEL: In accordance with tile policy estatdished by Iht' Standards Council, I abstain becaltse of a cliellt iDterest ill lilt" issue being addressed.

(Log #(X.;3) 80- 4 - (1-4 Smoke-Control Door Assembly): Accept SUBMITTER: Technical Committee on Fire Doors and Windows COMMENT ON PROPOSAL NO: 80-2 RECOMMENDATION: Revise the defimtion of Smoke-Control Door Assembly :us follows:

Smoke-Control Door Assembly. Any combination of a side- hinged swinging door, f~mm, Itardware, and any other accessori~r that togetber provide for the corttrol of smoke movement througl] the assembly as determined by tests conducted in accordance with UL 1784. SUBSTANTIATION: Clarification of the type of door tllat is covered by tiffs sumdard. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: "~7 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 26 NOT RETI IRNED: 1 Goldman

(Log #2) 80- 3 - (1-4 Access Door; Access Door, Horizontal; and Flour Fire Door Assembly): Reject SUBMITI'ER: Donald W. Belles, Donald W. Belles & Assoc., Inc . /The Bilco Co. COMMENT ON PROPOSAL NO: 80-5 RECOMMENDATION: Revise Section 1-4, Definitions, ,Ls follows:

Access Door. A door assembly, for insudlation in fire-rated walls or having a specific listing for installation it] fire rated ~;:;r~ e+ ceilings of fire rated floor-ceiling or roof-ceiling assemblies, that is used to provide access to sh,'ffts, chases, attics, spaces above ceilings, or other concealed spaces.

I I ,~;¢ #51 80- 5 - (i-7.4): Reiect SUBMITTER: ~lte Steel, SAFTI, A Dtv -1 ()'Kt.ctlv 4 h~, COMMENT ON PROPOSAL NO: S(~lh RECOMMENDATION: Reject t'lol)t)sal NIl-It b,i tilt. rt..uS,,lln discussed below. SUBSTANTIATION: i ' r ,posal ~(~-I~) t'lhnnmles lilt' II~l~ S, tlmlt- inch size limit on glazing iD I-houJ alld I-I ./~ ImuF d,mrs I his Js a subsutntial technical change whMi tile ( ' A ) l l l l l l l l l ~ U ,I.I I el,lt-d without any support ing technical data to sutx~lanti:ne it. Thv existing limit is based on the well-established t~u:~ that glaziltg *.m allow significant transmissioD of radiant heat, and 100 st. IHch area linfit is necessary for l-hour and 1-1/2 hour fife doors [,q provide adequate fire protection.

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N F P A 8 0 - - F 9 8 R O C

Tile fact dlat doors can pass dae fire test widl larger areas of glazing does not justify removing dre area limit widiout considering dae radi,'mt heat performance of file glazing. Several fire-rated glazing materials have been tested in l -hour and 1-1/2 hour fire doors in sizes much larger fll~m 100 sq. inches. Aldmugh some products can also reduce radiant heat significandy, odlers transmit dangerous amounts of radiant heat. While removal of area limits may be jnstified when applied to glazings fllat restrict radiant heat transfer, Proposal No. 80-16 removes die area limit for all glazing, ,and compromises fire protection.

Radiant heat transmission is a critical fire protection consideration in locations where higher fire resistance is needed to retard fire spread. It is also an import2mt life safety factor, where safe patlls of egress rot!st be maintained. Even if glazing is rated for extended 60 and 90 mimtte periods because it can silty in the frame tllat long, it may not restrict radiant heat for any ;mmtmt of time. Studies of radiant beat hazards and issues of lile safety cited in Appendix J to NFPA 80+ Standard for Fire Doors and Fire Windows, underscore the importance of radiant heat protection.

To understand the significance of radiant heat performance in terms of increasing human life s~ffety and limiting property dmnage, cortsider the following data: The human threshold of "unbearable pain" for exposure to radiant heat may he reached at 5 Kilowatts per square meter. Spontaneous ignition of easily ignitable fuels occurs at ! 0 kW/sq, meter. For normal fuels, die energy flux is 20 kW/sq, meter, and for difficult to ignite fuels, fl~e energy flux is 40 kW/sq, meter. (See National Institute of Standards and Technology, FASTLite: Engineering Tools for Estimating Fire Growd~ and Smoke Transport, Special Publication 899.)

Fire-rated glazing products are available today which meet tile temperature rise requirements of NFPA 251 (250 degrees Fahrenheit), and reduce radiant heat flux to 0 Kilowatts per square meter at 60 to 90 mimttes. However, od]er products like wired glass and ceramic glazings transmit d,'mgerous amounts of radiant heat - well above tile 5 to l0 Kilowatts of radiant heat ex osure sufficient to cause unbearable pain, and tile 40 KiPowatts needed for ignition of difficult to ignite fuels.

In fire tests conducted by Soudrwest Research Institute (SRI) for d~e U.S. Coast Guard to measure radiant heat transmission of wired glass and ceramic FireLite glazing products, the radiant beat flux of die products was measured at 1.5 meters. SRI reported die following radiant heat flux data: wired glass measured 39 - 48 Kilowatts per square meter at only 37 minutes, and ceramic FireLite measured 75 Kilowatts per square meter at 60 minutes. There was almost a 100% increase in radiant heat flux through the glazing in d~e last 15 ntinutes of the 60-minute fire tests. 1 The radiant heat flux of die glazing was 34% bigber than the steel door.

Ceramic FireLite products bare been tested to 1296 sq. incbes per lite in a 60-mimtte door, and 100 sq. in. pet" lite in a 90- minute door. According to recent promotional materials, wired glass has now been tested in a 60-minute door to 950 sq. in. per lite up to a maximum of 1920 sq. in. per door, and in a 90-mimite door to a maximum of 2208 sq. in. per door (552 sq. in. per lite). The proposed change will allow use of these materials in fully- glazed fire doors widlout regard to the signific~int increase in ' radiant heat transmission through the door assembly and resulting reduction in fire protection.

Proposal 80-16 drastically changes the glazing limit from small vision panels to fitll-sized glazed fire doors - widlout technical justification. No technical data was submitted in suppor t of tile change. The only substantiation cited by the Committee is "bringing NFPA 80 up to current industry practice." That is not an acceptable basis for cbanging the limit widmut adequately addressing tl~e radiant beat issue.

The Committee's proposed antendinent maintains die 100 sq. in. limit in doors required to meet temperature rise criteria. However, tl~e risks of radiant heat transmission from fully-glazed doors in other locations is equally unacceptable, b ~ e d on the test data cited above. The Committee needs to consider the radiant heat performance of glazing and maintain existing limits except for glazings which provide radiant beat protection, which someproduc t s on tile market do in fact offer. The Committee shou lda l so require more stringent performance criteria for glazing in doors rated over one hour in excess of 100 square inches in accor~mce with tl~e door componen t acceptance criteria in NFPA 252 which prohibits any openings.

Tile proposed change should be disapproved mid tile issue returned to the Technical Committee for furfller study. The Technical Committee needs to develop appropriate radiant heat performance criteria as tile hasis for glazing area limitations, consistent widl available test data for products :dready on tile market. There is no justification for removing limits on glazing without requirements for radiant heat protection.

1 The reports from Southwest Research Institute are unclas,sified Federal Government Property and can be obtained tbrougil the National Technical Information Service in Springfield, Virginia, Report Numbers CC~D-37-95 (Governmet~t Access!tin N,+ AlL A302226) [FireLite], and CC-D-38-95 ((;overllll |elll A('t+eSSi,,ll No. AD-A302316) [wired glass]. COMMITTEE ACTION: Reject+ COMMITTEE STATEMENT: The issue ol heal tratlSlel I1~ u,~l beell colnpleteiy resolved h)r tile tire (J(l(~l itsell ['ht'lt:ll~l~' i! t~ not appropriate to restrict glazing p~ trill, Is !ll,tl .tJ t , ,ti~.ti,lt- ,,1 providing the salne level of pl ~teCtlOtl tit .tt t ~!+lalJ~ ¢+ wilh thcH listings. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 23 NEGATIVE: 2 ABSTENTION: 1 NOT RETURNED: 1 Goldman

EXPLANATION OF NEGATIVE: HOLMES: As the snbmitter clearly states, and provides

quantitative evidence and documentation, radiant heat transfer is a critical fire protection consideration for devices and equipment. including fire doors, to prevent fire spread. Some, but not all glazing materials dir t will be allowed by the proposed cbmtge. provide resistmtce to radiant heat transfer. Many of die glazing materials that will be allowed by the proposed change will allow dangerous amounts of radi:mt heat trarlsfer. This is clearly unacceptable for fire doors whose sole function is to prevent spread of fire through door openings.

I agree widl tile Committee Statement d)at "The issue of heat transfer has not been completely resolved for die fire door itself.' However, I conclude that it is entirely appropriate to restrict glazing products to 100 sq. in. based on the submitter 's statement and tile Committee Statement quoted in the previous sentettce.

THORNBERRY: I voted negatively on this comment since I had voted negatively on die original ballot for tile ROP on Proposal 80-16 (Log #25), and I have not as yet changed my mind. In lact, the cotnmentor for dais item reinforces my reason for voting negatively originally, ,as well as for the R()C. EXPLANATION OF ABSTENTION:

KOFFEL: In accordance with the policy established I,v tht' StancLards Council, I abstain because of a client illleresl iii the issue being addressed. However, [ also feel compelled t- t~tlel ;t comment opposed to the proposed Committee Actium. Pl<q~J~sal 80-16 CLog #25) offered no supportit!g i'atiOllalt. |or the illtle~L.se in the permitted size of the vision panel other than products .trt+ now available that can meet the c!'iter~a+ This is !rot tlew information and the standard has recognized st!oh new technology. The proble!n wifll Proposal 80-16 (Log #25) is tim! it does not limit !be characteristics of the glaziug material to be used.

A review of prior Committee Actiot~ on similar proposals attd comments reveals the following actions, ,all of which are contrary to tile action taken on Proposal 80-16 (Log #25) and Comments 80-5 (Log #5) and 80-7 (Log #CC4).

(Log #13) 80- 6 - (Table I-7.4): Reject SUBMITTEd: Richard E. Thonnings, American Insurance Services Group, Inc. COMMENT ON PROPOSAL NO: 80-16 RECOMMENDATION: Delete new foomote #4 added by committee action: "C!."~e~ :z.:ate.~.al~ exceed!ng lO0 ~q. :n. it: ::re::

S U B S T . ~ T I A T I O N : It is not clear what action the committee is actuMly taking. It appears ,as though a significant cbattge is occurring without any support ing teclmical data. Therefore, kee l) existing language. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Actiou . i t Comment 80-5 (Log #5).

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NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: BEATTIE: Mr. Thonnings request for substantiation is

tounded. HOLMES: See my Explanation of Negative Vote on ( ' o m m e m

80-5 (Log #5). THORNBERRY: See my Expl:mation of Negative Vote on

Comment 80-5 (Log #5). EXPLANATION OF ABSTENTION:

KOFFEL: See my Explanation of Abstention on Comment 80-5 (Log #5).

mechanism. Where tile wire cable makes a change in direrllC~Jt. such as where it p:~ses tlarough a wall in a )ipe sh:eve (NFI'A mJ- 1995, Figure B-30), a kink in tile wire caMe is formel . Kinks ,tls(. have occurred at tile point where the wire calde chaliges dilecli~m at a stud [NFPA 80-1995, Figure B-3q(a)l, "J ,t! .ttt ew'h, dt ~NFI'A 80-1995, Figure 46). The kink can be so .gel ill the wirc cahh. Ill,tl it canIIOt lllOVe in relation to tile sleeve. Stlld, Ol eveh~Jll Wllt'll I h l r

disc link separates. The provisiotl o1 a pulley al a oh;topic -I direction would prevent tile kinking. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: Proposal 80- I ~ (Log #t ;P7) wz~s simply a reorganization of the requirements tot placetlleill . l detectors. This conlnlent introduces new material and will Im held for the next cycle. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 2b VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 95 NOT RETIIRNED: 1 (;oldman

(Log #CC4) 80- 7 - (1-10.1): Accept SUBMITTER: Technical Conunittee on Fire Doors and Windows COMMENT ON PROPOSAL NO: 80-18 RECOMMENDATION: Delete text as follows:

1-10.1 This section provides information on the placement of detectors, for -o;;~:;gi=g t2rc ~c.c.rz ::".d; f.rc ~c.c.r !=~;'. 'are,

SUBSTANTIATION: The rest of the section contains the

~]~l ecific requirements. It is not necessary to list all of tile doors in is paragraph.

COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #CC8) 80- 10- (4-1.4): Accept SUBMITTER: Technical Committee on Fire Doors and Windows COMMENT ON PROPOSAL NO: 80-1 RECOMMENDATION: Add text as a new second sentence to Section 4-1.3:

When in the closed oosition, the clear,'mce between the wall and tile door or the frame and the door shall not be more than 3/4 in. (19.05 mmL rSee Figures B-37(dL B-37(e) and B-37(f3.[ SUBSTANTIATION: In tile movement of language for user- friendliness this language was inadvertently omitted. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: "/h VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: I (;oldnum

(Log #CC5) 80- 8 - (1-10.6.1 Exception No. 2): Accept SUBMITTER: Technical Committee on Fire Doors and Windows COMMENT ON PROPOSAL NO: 80-18 RECOMMENDATION: Add text as follows:

Exception No. 2: For vertically sliding tin clad and sileet metal doors, one fitsible link shall be located at die center near tile bottom of the door and additional links shall be located at or near tile ceiling on each side of file wall. (See Figures B-45 and 13-46.) SUBSTANTIATION: This material is part of rite reorganization of NFPA 80. It is important to identify die specific type of door. This was not necessary in tile older edition ,x~ these requirements were located in die chapter on vertically sliding fire doors. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 26 VOTE ON COMMITTEE ACTION:


(Log #(,(:9) 80- 11 - (5-3.2): Accept SUBMITTER: Teclmic:d Committee otJ Fire Doors and Winch,ws COMMENT ON PROPOSAL NO: 80-1 RECOMMENDATION: Revise text as follows:

5-3.9 Glea~mces. Tile clearances between tile door and tile w,~l when tile door is in die closed position x:::] L'ct-.;'ee:: :!~c A-.e.c.r ~m~ ;i!l shall not exceed 3 /8 in. (9.53 ram). SUBSTANTIATION: Tile sill clearance requirements are now covered in Section 1-11.4. This language was not deleted :Lg originally intended. COMMITTEE ACTION:. Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: '26 VOTE ON COMMITTEE ACTION:


(Log #1) 80- 9 - (1-10.6.2 (New)): Hold SUBMITI'ER: Todd E. Schumann, HSB Industrial Risk Insurers COMMENT ON PROPOSAL NO: 80-18 RECOMMENDATION: Add new Paragraph 1-10.6.2 widl text as follows:

Where fusible links are used. the medium used to connect tile filsible links to tile releasin~ mechanism shall be rone. flexible wire cable, or chain. A duller shall be used at a change of direction for flexible wire cable. SUBSTANTIATION: The standard lacks a general comment as to what type of rnateri'.ds ~-an be used to connect fitsible links with tile releasing mechanism. Paragraph A-~4.1 addresses rope, wire cable, and chain, but only as it applies to tile closing mechanism of swinging doors.

HSB Industrial Risk Insurers inspects fire doors and their closing mechanisms in the field. A problem has been noted with tile use of wire cable to connect the fusible links to tile releasing

(Log #CC 11 ) 80- 12 - (6-2.2, 6-2.2.1, 6-2.2.2, 6-2.2.3): Accept SUBMITrER: Technical Gommittee on Fire Doors and Windows COMMENT ON PROPOSAL I"40:80-1 RECOMMENDATION: Revise this section by deleting Sections 0- 2.2.1, 6-2.2.2, and 6-2.2.3 in their entirety and changing Section 6- 2.2 to read ,as follows: 6-2.2 Sills. Sills shall be installed in accordance widl Section 1- 11.2. SUBSTANTIATION: It is the intent of file Committee t~, m,,vc all sill requiremenm to one section in Chapter I. This sec~i,m in Chapter 6 was overlooked in tile chatJge. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 26 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: I Goldman

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N F P A 8 0 ~ F 9 8 R O C

(Log #0) 80- 13- (6-3.3): Accept in Principle SUBMITrER: William E. Koffel, McKeon Rolling Steel Door Co., Inc. COMMENT ON PROPOSAL NO: 80-36 RECOMMENDATION: Accept the proposal to revise the subsection to read ,as follows:

6-3.3 Frames. Frames shall not be required for rolling steel door installations in masonry w~dls. Where frames or jambs --:n!v are provided, only minimum 3/16 in. (4.76 ram) nominal strnctural steel or formed steel plate shall be used. Attachment of frames or iambs to the wall shall be in accordance witia the dogr manufacturer 's li~ting- SUBSTANTIATION: Door frames, jambs, and their at tachment to the wall can significantly ,affect the performance of a fire door during either the fire test exposUre or an actual fire. This is evidenced by the requirements in Chapters 2 and 3 for swinging fire doors which contain specific requirements for labeled frames and requirements for installing die frames. Subsection 2-6.2 requires the medmds of anchor ing die frame to be in accordance with the listing.

Section 6-3. I permits doors in walls other than masonry only if the door a~embly is listed for such construction. Therefore, ' the proposed text is merely editorial and only reinforces that the installation will need to be in accordance with the listing requirements. COMMITTEE ACTION: Accept in Principle.

I Rewrite Paragraph 6-3.3 as follows: 6-3.3 Frames. Frames shMI not be required for rolling steel

door installations "n ..'naaanry :;~.!!a. Where frames or jambs are provided, only min imum 3/16 in. (4.76 ram) nomina/s t ruc tura l steel or fo rmed steel plate shall be used. Atw, c!z.'ncn: af Frames or jambs tv 5:e -;.~!! shall be in accordance with the door manufacturer 's listing. COMMITTEE STATEMENT: Not all doors in walls other than masonry walls require frames. The change to the tltird sentence is editorial. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 26 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 24 ABSTENTION: 1 NOT RETURNED: I Goldman

EXPLANATION OF ABSTENTION: KOFFEL: See my Explanation of Abstention on Comment 80-3

(Log #2).

80- 14- (6-5.5): Reject (Log #7) SUBMITTEd: William E. Koffel, McKeon Rolling Steel Door Co., Inc. COMMENT ON PROPOSAL NO: 80-39 RECOMMENDATION: Revise text as follows:

6-5.5 Rolling steel fire doors shall have an average closing speed of not less than 6 in. /sec nor more flaan g4.J.~ in./sec. SUBSTANTIATION: In rejecting the proposal, the Technical Committee stated that there was insufficient information given to justify the change. While a comprehensive search of injury data has not been performed, we are aware of at least one incident involving the injury of a woman in a public office building. In Richland County, South Carolina, the taxpayers had to finance a $215,000 repair to a 5 year old building wlaere the woman was injured. The repair project involved the replacement of 12 rolling steel fire doors. The manufacturer of the original doors defended the installation by saying, "They were put in according to code...from our standpoint everything that was done for the doors was clone properly."

This incident indicates that manufacturers will rely on tile requirements of NFPA 80, and therefore, the closing speeds should be reduced to protect the public. Also, it should be noted daat dais is an average closing speed, and therefore, at times, the doors may be closing nmch more rapidly. COMMITTEE ACTION: Reiect. COMMITTEE STATEMENT: There is still insufficient evidence that a reduction to 19- seconds will prevent injuries There is no proof that tile door in the incident reterenced perlormed within the 6-12 second parameters. Tile Committee feels that a 6-12 second range is very restrictive. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 26

VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 72 NEGATIVE: 1 ABSTENTION: 2 NOT RETIlRNED: 1 (;oldlnan

EXPLANATION OF NEGATIVE: CAHANIN: lntormatlon presented to the ( ,ommiuee ill tht'

ROP stage and outlined a87ain ]n the R()P Comment~ by (;. J. Cahanin significmltly demonstrate titat closing speeds present a hazard to occupas]ts and contribute to door ulainte~lance and

rational failures. LANATION OF ABSTENTION:

COLEMAN: The submitter 's comments and my own personal experience reflect a need for this issue to receive tiJrther study. Until a study is done to substantiate injury reports. 1 don ' t feel 1 can vote for or against titis proposal.


(Log #8) 80- 15 - (6-5.6 (New)): Reject SUBMITTER: William E. Koffel, McKeon Rolling Steel Door Co., Inc. COMMENT ON PROPOSAL NO: 80-40 RECOMMENDATION: Add the following text:

6-5.6 All rollin~ steel fire doors shall be constructed witll atJ automatic resettin~ mechimism or a mechanism which allows resettin~ without tile need of a skilled techtfician or tools. SUBSTANTIATION: Tile original proposal indicated tb,u ,h,,,a's requiring the manual resetting of mechanical torsion sprinRs art.

~ rohibited. This restriction w~Ls a significan! concef|l expressed y several Comnlittee inelnbers. Tile colnlnelll does lit[ illClllde

this text. Instead, the comment focuses on the proMems associated with

door designs which require special expertise to reset the d .or . In tile past, there has been resistance to incre~tsed functional tesl frequencies due to tiae cost and complexities associated wilb testing, or resetting, certain doors. There h:t~ als, reportedly been failures of doors which have not been properly reset because facility personnel do not have the proper tools or knowledge to reset the door.

As proposed, the comment does not require automatic resetting doors. Instead, the comment requires doors that will either automatically reset or can be easily reset by facility personne l This shottld greatly improve the reliability of such doors which may be serving ,as a critical fire protection feature of a building. COMMITTEEACTION: Reject. COMMI'I~I'EE STATEMENT: The recommendat ion may be misleading. Properly tested doors always require manttal resetting. Simple devices are ,already available for operation and resetting of these doors. The submitter did not define a "skilled technician." NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 26 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: ALPERT: I agree with tile opinions of Mr. Holmes and others

that rolling steel doors are not being tested and maintaitted due to the difficulties involved in resetting them. I believe tins revision would solve this problem and lucre,me tht' reliahilil/ ,~1 these doors.

BEATTIE: I feel that this proposal is valid. "l'l~e w~u'd "~lw,-ial" should be inserted in lront of "ttmls" to read "...wirhmH tin" net.d of a skilled technician or special tools." It the doters are eltsih reset without tile use of skilled techt , cians or special tools, |llefJ testing would be easier to perform, and less costly. Doors slmuht be able to be reset using COllnnoll tools that a inecbD.iIit" would normally have in a maintenance shop.

While Mr. Koffel does not define "skilled technician," the American Heritage Dictionary defines "skilled" its "1. Having Ol showing skill; expert. 9 Requiring specialized ability or n-aining: a skilled trade." The sante volume defines "teclmician" :L~ "a. An expert in a teclmique, as: technical process: a dental technician. b. One who is known for skill in an intellectual or artistic technique." We should not have to require a person with specialized abilities or training to reset a fire door

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N F P A 8 0 ~ F 9 8 R O C

CAHANIN: Technology exists from several manufacturers of existing doors and can be developed by other manufacturers - to insure that resetting of rolling steel fire doors is correct and will result in proper operation of dae door in tile event of a fire.

C, OULD: The failure rate of fire doors, when tested for automatic closure, is to o high. Testing done to date shows that doors that are tested regularly perform mucb better titan doors tl~at are not tested regularly. Building owners appear to be resistant to conduct testing because of tile time :rod expense involved. If doors were to be made automatic resetting, this would lower the time and expense involved and increase tbe likelihood that doors will be tested. The statement for prohibiting torsional springs is not needed as it is not important what method is used to accomplish antomatic closure.

HOLMES: I believe daat dae Committee should Accept the new text for 6-5.6 as originally proposed by Mr. Degenkolb. Current technology provides for rolling steel doors that do not require manual resetting and that do not require skilled technicians or special tools to reset. NFPA 80 should be revised ,as proposed to recognize current technology. Industry data clearly indicates an unacceptably high rate of failure of rolling steel doors during testing. More frequent testing is prudent, and automatic resetting or easily implemented resetting procedures will facilitate more

ent testing • ATION OF ABSTENTION:

K()FFEL: See my Explanation of Abstention on Comment 80-3 (Log #2).

(Log #12) 80- 16- (6-5.6 ,and Exception (New)): Reject SUBMrVrER: Richard E. Thonnings, American Insurance Services Group, lnc. COMMENT ON PROPOSAL NO: 80-40 RECOMMENDATION: Accept tl~e proposed new Section 6-5.6 and add an exception as follows:

6-5.6 Rolling steel fire doors shall include an automatic resetting mechariism or a mechanism wltich allows for resetting withm;t a need for a skilled technician or special tools.

Exception: Doors with manual reset mechanism are permitted

~ rovided monthly fimctional testing is performed. UBSTANTIATION: The explanation of negative votes by

Technical Committee members Beattie. Gould, and Holmes, along with Cahanin's explm~ation of abstention demonst~tte tl~e signific~mce of requiring doors to have an automatic resetting mecltanism. Clearly d~ere is also a benefit for tiaose doors wida manual reset. The TC should be looking to encourage doors witla automatic reset while also recognizing d~e benefit of properly maintained doors with utanual reset. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action on Comment 80-15 (Log #8). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 26 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: BEATTIE: Mr. Thonning ' s proposal is sound, and is in line

with Mr. Koffel's proposal of 80-15 (Log #8). CAHANIN: Mr. Thonning ' s sut~stantiation is valid and should

stand for the proposed change. GO11LD: See my Explanation of Negative Vote on Comment

80-15 (Log #8). HOLMES: See my Explanation of Negative Vote on Connnent

80-15 (Log #8). THORNBERRY: I agree with the tri ter negative voters.

Ahltough Comment 80-15 (Log #8) is similar to this comment, I believe tills comment is better since it refers to "special" tools and also allows for an exception where monthly testing is performed on the doors. This comment appears to be a reasonal~le

oproach to addressing this important issue. LANATION OF ABSTENTION:


(L.p. #2a) 80- 17 - (Chapter 11): Reject SUBMITTER: Donald W. Belles. [)~HJahl W. Belles & Ass,. Inc . /The Bilco Co. COMMENT ON PROPOSAL NO: s{~-5 RECOMMENDATION: Revise Chapter I I ol NFPA xO ,L', t.ll~r~s

C, hapter 11 InstallatiotJ ~f Access Doors anti Floor Fire i)oo]s 11-1 Scope. This section covels the insrallatl.o ~1 b~}tb

horizontal and vertical access doors in fire-rated w, dls. :]:;~:;:;. ~-M floor-ceiling ~msemblies, and the i[lstallation ol flooJ hre do,,r~.

11-2 General. 11-2.1 A-': z: Access doors alto floor fire doors shall be ,tit

integral unit including the door, f~tme, binges, latch, and closing device (where required) bearing a label that reads "Frame and Fire Door Assembly."

Exception: A vertical access door shall be permitted to have hinges that are not part of the labeled ,assembly, provided the hinges coctform to Table 2-8.1.1.

11-9.2 Access doors and floor fire doors shall be sell-closing, 11-2.3 Access doors and floor fire doors sball be self-latching. Exception: A horizontal access door that does not open

downward and tltat remains in place when an upward force of I PdSf (48 N / m 2 ) is applied over the entire exposed surface ol tile

nor shall not be required to be self-latching. 11-2.4 Self-closing acces, s doors and floor fire doors dial are

intended to be used to allow a person to enter the concealeci space behind the door completely shall be openal)le Irom the inside without die use of a key or tool.

11-3 Horizontal Access Doors and Floor Fire Doors. 11-3.1 Door assemblies used in fire-rated floors or floor-t eiling

or roof-ceiling assemblies shall be tested in the horizontal position in accordance with the procedures described in NFPA 251, Standard Methods of Tests of Fire Endurance ~)1 BuilditLK Construction and Materials, ,tnd shall bear the [;tt~el r,.~quirt.d |~,r horizontal access doors or floor fire doors.

11-3.~ A horizontal access d.o~ and floor tire th.~oJ sb,tlt tpc.tl ,t label that includes the additional wt)r'~litJg "F,H H~r'i/,JrJl:d Installation."

11-:~.3 A horizontal access door and a floor life dool ,d~all I~,. used in a fire-rated floor or floor-ceiling or root:ceiling ~tssciHlfl,, only where it h~Ls been tested Find listed f,}r USe ,L~; ;t I'l)lll])()ll¢'lll Ill the `assembly.

I 1-3.4 Horizontal access doors and t o o i- fire dools shall t.,~ bt required to be snbject to tbe bose streant test. SUBSTANTIATION: This revision of NFPA ~,0 plovt(les .~ differentiation between access doors in ceilitigs of fire raleH llo,~l- ceiling and roof-ceiling `assemblies and a floor fire do~r which protects ;t througll opening from one story to another. The differences between t!le two applications may be important. For example, the exception for latching found in Paragraph I 1-~'.3 was probably meant to apply only to access doors in suspended ceiling systems, yet the current NFPA 80 format results in the exception applying to both access doors and fire doors at through penetrations of a floor. Adding separate definitions for access doors and floor fire doors provides the opportunity for differing requirements for floor fire doors and :.recess doors COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action on Comment 80-3 (Log #2). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 26 VOTE ON COMMITTEE ACTION:

AFFIRMATWE: 23 NEGATIVE: 1 ABSTENTION: 1 NOT RETURNED: 1 Goldman

EXPLANATION OF NEGATIVE: FAVR(): 1 disagree with the Cotnunntlee AftioH ou~ tills ineNc {

believe thai the proposed definition (see ( ;onmwm ~0-3. 1.,~ K #2) and the resulting changes m Cbapter I I will clariP¢ H~e i;;lel;~ ,11 tile st i tnclard, a n d ease the b u r d e r l a l ld e n b a l l ( ' e rile el lb)rct ' l l le l l l capabilities of and~orilies havingjm'isdict~o~ EXPLANATION OF ABSTENTION:

K()FFEL: See my Expla~atio~ of Al,st,~ai,,, , , . ( . , , . , ,win ~o-3 (Log #2).

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N F P A 80 ~ F 98 R O C

(Log #4) 80- 18 - (Chapter 15)i Reject SUBMITTER: Douglas S. Erickson, American Society for Healthcare Engr COMMENT ON PROPOSAL NO: 80-2 RECOMMENDATION: Reject NFPA 105 from becoming a s tandard ~mdincorpora ted ,nto NFPA 80. SUBff rANTIAT1ON: In the committee 's statement~ it states that the commit tee feels that there is a need to have NFPA f05 become a standard. The ASHE members |~p would like to see documenta t ion as to why this needs to g o from a manual to a chapter within NFPA 80. If this new standard is going to require gasl[eting of all corridor doors in a health care fa'cility, whe~¢;r . sprinklered or not, the expense for no additional l ife/fire safety is going to be in the h u n d r e d s of millions of dollars. Where is the justii~cation for adding these new requirements? The health c ~ e industry is against this new chapter and its requ i rement for , gasketing doors in corridors. This will be a main tenance nightmare and the NFPA's fire data does not indicate that fl~ere will be an increase in the level o f safety to our patients or staff.

With this commit tee I know i am figl~ting a losing batde, as more is always bet ter and common sense never enters into the equation, so ! submit this comment with the full understancllnl~ it will be rejected with a shor t commit tee s ta tement saying gaskenng is nec~sary. Well let our organization tell you. it is not necessary and our excellent fire history is a g o o d indicator of our success without having to follow NFPA 105. 1 guess the price of providing health 'care and insurance will jus t have to go up to handle the increased cost of installing more expensive dobrs and maintaining a system that will not w~thstand tire constant traffic. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: R ecjuirements for smoke coutrol

• door assemblies are in current e d l d o m o f bu i ld ing Codes and in the drafts o f future bui lding codes. Moving the recommendat ions from NFPA 105 to NFPA 80 gives the AHJ the in format ion necessary to de te rmine compliance with codes. NUMBER O F O D M M r r T ] ~ MEMBERS ELIGIBLE T O VOTE: '26 VOTE ON COMMFri3EE ACTION:

AFFIRMATIVE: 2~ NEGATIVE: NOT RETURNED: 1 Goldman

EXPLANATION OF NEGATIVE: COLEMAN: The Commit tee Sta tement references the issues

being covered in SOME BUILDING CODES and in DRAFT form in others. 1 though t we were working on a code related to FIRE SAFETY and no t writing a budding code.

From the sounds of the Committee Statements they are fishing for a substantial reason to include NFPA 105 into NFPA 80 and coming up short. The reason should be based on NEED,. REASON, and suppor ted by factual cost effective justification based on fire losses. I have no t seen such a document . By adding NFPA 105 to NFPA 80 we would be changing the c o n t e n t s o f 105 from a r e c o m m e n d e d practice to a standard.,

The issue, I feel, requires more study with considerations for type of building, occupancy, fully or partially sprinklered, e tc , in NFPA 105 before the p roposa l i s put forward to the membersh ip for adopt ion as a single standard.

KOFFEL: i do no t disagree with the Commit te e Sta tement that codes require doors which are capable of resisting the passage of smoke. F o r this reason, d m n g i n g the nature of NFPA 105 from a manual to a s tandard has merit. However, my concern is the incorporat ion of the requirements into NFPA 80. There are two PnOtentiai problems associated with incorporat ing the materi,'d

to NFPA 80, one of wifich the Commit tee can control and one whid~ is beyond their control. Not all such doors are required to have a fire protection rating. While the Committee can control the lafiguage and address it, there will be some shortcomings. However, as written, non-rated doors-will no t require a lately, which is contrary to many of the codes which may reference the document . What the Commit tee cannot control is the misapplicat ion.and misinterpretat ions that are going t o occur. Do all fire doors have to meet this criteria? Why does one go to a fire door s tandard for non-rated doors? It would be much cleaner to keep the two separate. COMMENT ON AFFIRM~TWE:

THORNBERRY: I agree with the Commit tee Sta tement but I feel that it does no t go far enough to r e spond to the commentor ' s substantiation. I believe the commento r is in er ror in assumit~g that all corr idor doors in health care facilities will be required to be gasketed whether s~p~rinkle~:ed. . ° r not. The proposed revisions to NFPA 80 only mandate ~ k e u n g for smoke control doors that are also fire doors. Gasketmg is no t manda ted if a nonfire rated

d o o r is used for a smoke control d o o r provided it can succes~ully demons t ra te that it n iee= the .per formance criteria for a maximum leakage rate of 3 cfm per sq. ft. o f door opening under the test eonditions_specified. 1 believe that this can b e accomplishcdwith reasonably t ight f i tt ing doors. Since NFPA I01 does not specify f ire doors for room to corr idor doors, then ! do not see where it will be an automatic given that such doors will be required to have gaskets to meet the criteria for a smoke control door assembly in accordance with the new Clmpter i5 proposed to NFPA 80.

(L .g #9) 80- 19- (15-2.4.3): Reject SUBMITrER: William E. Koffel, McKeon Roiling Steel Door Co., Inc. COMMENT ON. PROPOSAL NO: 80-49 RECOMMENDATION: Revise text as follows:"

15-2.4.$ All horizontal and verdcal sliding ~uld r . l l iug firt. d.,,r.~ shMI be inspected "and tested in accordance with the ininillt|llli requirements established by this section: Resetting of tile rtqt.~L~t. medlan i sm sba$1 be done in accord~mce witil die lit;tOll|;| "flll't'l "'q instructions` A written record si~dl be !n~urnan|ed ~ll(| silall t . . available to die authority having jurisdiction.

Excemion: Elevator doors. 15-2.4.3.1 , ~ l ~ l ~ ''~ . . . . . "' a visual inspection ot horlz,Jnlal

sliding or vertical sliding mid roiling :cc.fi:.g fire d o o r s sb~l be performed. The inspection shall include fails, guides, brackets, counterweights, protective enclosures or lzousings, and fusible links. Where damage to componen t s is found it shall be repaired arid a functional test in accordance with 15-2.4.$.2 shall be PeExrfOrmed.

cel~ion: . [de~or -doo l~ Monthly inspections are not reauired in accordance with 15-~.4.5.3.

15-2.4.3.2 ~ t l i g l ~ . £=.~" : : : : = ~ y , a functional test-of liorizontal sliding or vertical sliding and rolling fire doors shall be per formed to confirm i~roper operat ion and full closure. Electrical components re_stalled in accordance with NFPA 72, National Fire Alarm Code, shall be tested in accordance with those requirements .

Exception: ~ Ouarterlv functional tests are not reauired in accordance with 15-2.4.~.K

!g-2.4.$3" Imnect ion f recmenci~ o f no t less than one her auar ter and func~tionai test fr~auenciea of no t lem than bne her year shall be fiermitted wilen ~ on a nerformance based" oraacam ~mmroved by the authorhv havin~ Jurisdiction.

"" A-[5-2:4.~.~3 Hi~torlcal oerfnrmance andrel iabi l i tv data may be used to d o c u m e n t an ira[ruction or test freouencv other thaws What is reouired by ParammDl~ 15-2.4.$.[and 15~_4.$.~. If the doors are insnected auarterlv and subjected to gu annual functioital tesl and the r~nl ts-are acceptable to both file buii¢tin~ o ~ ] e r mid the authori t~Jlavingturisdicdon, the reduced fi~¢que,~Cy sllould be acceptable. To de te rmine if the results are acceptable one shon'ld ewaluate ti~e overall f i re protect ion objectives, tile crinoid ~ e c t o f the doors in achieving ' the fil-e nrotection objectives, and the risk associated with failure -of the doors . " SUlkgTANTIATION: The Committee l~as acknowledged in the Commit tee Statement the need for more freqt,en~ testing arid the need for visual inspections. However, the inspection frequencics proposed do no t appear to be consistent with frequencies required for o ther fire protect ion features. For example, a supervised control valve on a sprinkler system must b e insL~ected. monthly, and yet a fire door which could be serving a similar cole in controlling the spread of fire need ooly be inspectedr quartedy.

The FM data reviewed by the Commit tee dear ly demonstra ted increased reliability when the inspection and testing programs are properly p e r f o r m e d . There is, however, a lack of sufficient reliability information on the componen t s of the doors to calculate a specific inspection a n d t e s t i n g frequency. To potentially reduce t h e b u r d e n of the increased inspection and testing frequencies, an alternative has been proposed to allow for a r educed f requency where historical data and reliability information is used to documen t a different frequency.

The commen t also corrects one editorial error (changing roofing to rolling in 15-2.4.3.1) and relocating the exception for elevator doors. Since elevator doors are exempt from both tile inspection and testing requirements , it is more logical to locate the exception as part o f paragraph 15.2.4.3.

79

N F P A 80 - - F 9 8 R O C

COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee Action on this Proposal changed die section to require more f requent testing. The Committee does not feel dlat increasing tile frequency even further is better when tile new requirements have not even been implemented. The Committee also does not feel that decreasing the frequencies based on rather nebulous record keeping requirements is appropriate. There are a number of factors that impact on the proper operation of these doors that cmmot be determined by simply looking at tile door. NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 26 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE = BEATTIE: I agree with Mr. Koffel. The logic in Iris

substantiation is well founded. CAHANIN: A more f reqnent inspection of fire doors will not

produce an undue burden for tbe increased levels of dependability and safety which will be acltieved. The proposed inspection frequencies are in line with requirements for other types of fire protection equipment in otber standards.

FAVRO: I disagree with tile Committee Action on this item. 1 believe the proposal has merit in tlaat it will promote more vigilant maintenance of fire doors. Also, dtis proposal provides an ,alternate where adequate maintenance is undertaken; and it provides an incentive for audmrities having jurisdiction to examine the performance and performance capabiliti~es of these doors before granting such alternates.

HOLMES: Inspection and testing data indicate an unacceptably Itigh failure rate of fire doors during inservice inspection aa)d testing. Increased inspection and testing requirements will help to discover deficiencies and facilitate repairs prior to a fire emergency. The proposed performance-based provision in proposed 15-2.4.3.3 will allow less f requent inspection and testing if performance-based requirements, acceptable to tiae authority having jurisdiction, are met.

RISPOLI: ! am casting a negative vote with respect to Counnent 80-19 (Log #9). This item proposes to include requirements to perform periodic f imctional test ing of horizontal and vertical sliding fire doors to ensure operability of ,assemblies. These testing requirements are being considered for incorporation ,x~ a result of a limited industry survey which indicates dlat certain components may incur a higher than expected failure rate. The testing requirements as currently proposed are overly prescriptive and do not consider specific user preventative maintenance programs. These prevenu~tive maintenance progrmns typically are intended to reduce the likelihood of componen t failure ,and identify negative trends in door performance. In order to credit decreased failure i=ttes associated with implementing such a program, a performance based option should be permitted as an alternative to the prescriptive requirements being proposed. Inclusion of tiffs additional provision is in accordance witll NFPA's goal to establish performance based codes. The Committee's substantiation to reject file inclusion of a performancg option is based solely on a concern over "nebulous record keeping." Tile acceptability of documentat ion justifying reduced inspection frequencies should be left to the Authority Having Jurisdiction. Some industries trend tile performance and failure rates of door assemblies from cradle to grave and subject their assemblies to periodic inspections utilizing consistent acceptance criteria. This approach provides more statistically robust faihtre data for these components than the ONE Factory Mutual spot check that is being cited ,as tile sole reference for implementing more stringent inspection frequencies. EXPLANATION OF ABSTENTION:

K()FFEL: See my Explanation of At~stention on Comment 80-3 (Log #2).

(Log #11 ) 80- 20 - (15-2.4.3): Accept in Principle SUBMITTER: Richard E. Tbonnings, Anlerican ln.kurance ,Services Group, Inc. C O M M E N T O N PROPOSAL NO: 8t~49 RECOMMENDATION: Revise the Committee's new wording tot 15-2.4.3, 15-2.4.3.1, and 15-2.4.3.2 by deleting references m horizontal or vertical sliding and rolling. Tbe new text should ,q}plv to ALL fire doors.

S U B S T A N T I A T I O N : The comments (m att]rnhnive Iw Bt.,ntit. and Gould suppor t this action. COMMITTEE ACTION: Accept in Principle Revise text as follows:

15-2.4.3 All !:.~riz~;;~::::~ u:-;.c:tic:2 alidi::?.:, ,11:.~- I . . . . . . . . . , . i t ; . . . . . . . . . r-, " " "

automatic closin~ doors shall be iospected ;toll le:.;lt'd ill accordance with the I l l i O i l l l U l l l f e q u i f e l l l e l n S eSLitl~lished l)\ ih l .~

section. Resetting ot tile relea.se mecllauism sl]:dl br d ( . . , H~ accord~.lnce with tlae n l a n u f a c n l r e r ' s i n s l l ' U C t i o n s . ,,~ W l i l l ( - i i

record shall be available to tile authority havillg.lufisdicli-lL 15-2.4.3.1 ~narterly, a visual ins[)ectio[l of ha;riza;~;:a~ ;;: ;.~-:':i: .~!

.a:.l; . . . . . . . I ...n:..~ ~..... atltomatic closin~ dc, ors shall I)e performed. The inspection shall include falls, gmdc.~, I)rat'Kel:~ counterweights, protective enclosures or housings, and toslhle links. Where damage to components is Iouml it shall he rep:tH~d and a flmctional test in accordance with 16-2.4.3.2 sball be performed.

Exception: Elevator Doors 15-2.4.3.2 Semi-annually, a functional test of tile l~;riz-.;:::al ol

ve~icM a!i~".ng ~.4 . ~ n : ~ ~.~.. automatic closin~ doors shall be . . . . . . . . . . . ~ . . . . v performed to confirm proper operation arid fidl closure. Electrical components installed in accordance witll NFPA 72, National Fire Alarm Code, shall be tested in accorcktnce with those requirements.

Exception: Elevator Doors. COMMITTEE STATEMENT: The closing mechanisms on all automatic closing doors is tbe main concern of this section. NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 26 VOTE ON COMMITTEE ACTION:


CO MMENT ON AFFIRMATIVE: THORNBERRY: The Committee Action needs to be darified

since it references Chapter 16 whereas d~e commentof references Chapter 15, al though dae sections are identical. Apparently. the confusion arises because the present version of NFPA 80 contains the text in Chapter 15 whereas tbe proposed reformatted version of NFPA 80 willcontain the proposed wording in Chapter lb. Tills is fllrther confused by tile Connnittee's ( :ommenr 80-21 (I.,,K #CCI) which proposes to modify the same sectlou usm RIh,. Chal)ter 15 reference ol tile present standard.

(Log #t J,:l ) 80- 21 - (15-2.4.3 Exception): Accept SUBMITTER: Technical Couunittee on Fire Doors alld Wiodows COMMENT ON PROPOSAL NO: 8(v49 RECOMMENDATION: Modify this section as ~nllows: .

Delete tile exceptions for elevators ire Sections 15-2.4.3.2 aod ]5- 2.4.3.3 and add the following to Section 15-2.4.3:

Execution: Elevator doors. SUBS'FANTIATION: This is an editorial change to make the section easier to read. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 26 N()T RETIJRNED: 1 Goldman

(Log #t ,(:10) 80- 22 - (15-2.5.4(b)): Accept SUBM1TTER: Technical Committee oil Fire Doors and Windows COMMENT O N PROPOSAL NO: 80-51 RECOMMENDATION: Add fleW text to ,'Section 15-2.5.4(h) u, read :Ls follows:

(h) Filling tile screw or bolt holes with th~ same tmttelial as d w door or frame. SUBSTANTIATION: It is tile Committee's intent (,, oM; ,t]l,~ filling to o c c u r i l l s c r e w a l l f | h o h h o l e s , l'lns S t q ' t l o l l d l J v ¢, I I [ l l

apply to larger boles in fire ti()t)r.~ COMMITTEE ACTION: Ac(:epl. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 26 N()T RETIlRNED: I (;oldlnalJ

80

N F P A 8 0 / 1 0 5 ~ F98 R O C

(Log #CC7) 80- 23 - (15-4): Accept SUBMITrER: Technical Committee on Fire Doors ,and Windows COMMENT O N PROPOSAL NO: 80-2

I RECOMMENDATION: Revise text as follows: 15-4 Air Leakage Test. Smoke-control door assemblies shall

have an ,air leakage radng of not greater than 3 c fm/sf of door opening when tested in accordance with UL 1784 under the following conditions, and :!w2l ~c !.z=cd :zcard'z;gly. S U B S T A N T I A T I O N : Adding "assemblies" is editori,'fl. Deleting text removes language that is redundant to the requirements in Section 15-8. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 26 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETIIRNED: 1 Goldman

(Log #10) 80- 24- (15-4.2): Accept in Principle SUBMITTER: Joseph N. Saino, C h ~ e Industries COMMENT O N PROPOSAL NO: 80-2 RECOMMENDATION: Revise text to read ,as follows:

Tile chamber air temperature during the test shall be at ambient temperature.

Exception*: Where test data exists to verify that ambient teinperature results in higher leakage rates, additional tests at elevated temperatures need not be conducted. S U B S T A N T I A T I O N : NFPA 105 requires tests at ambient and elevated temperatures unless the above exception is tn~e. COMMITTEE ACTION: Accept in Principle. Revise text ,x~ follows:

15-4.2 Tile chamber air temperature dnring the test shall be at ambient temperature and elevated temperature of 400°F +/- 10°F.

Delete the exception in its entirety and accompanying appendix note. COMMITTEE STATEMENT: This change meets the submitter~s intent of using the correct information from NFPA 105. Also, ANSI/BHMA A156.22, Standard for Gasketting, currently establishes testing criteria at ambient and elevated temperatures, further support ing the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 26 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETURNED: 1 Goldman COMMENT ON AFFIRMATIVE:

THORNBERRY: Since the Committee Action deleted the exception in its entirety, then fl~rther action is necessary to Appendix A. Either Appendix A, Section A-15-4.2, Exception should be deleted o._£ the asterisk ,'ffter the Exception in Section 15-4.2 should be relocated ,after the Section number 15-4.2 and the Appendix A, Section A-15-4.2, Exception revised to delete the word "Exception" so that the text would rem,'fin ,as explanatory material regarding this issue. As it stands now, it is not clear to me what action is being taken with the Appendix A infornlation.

PART il

(Log #C('I ) 105- 1-(2-1.1): Accept SUBMrI~ER: Technical Committee on Fire Doors and Windows COMMENT ON PROPOSAL NO: 105-3 R E C O M M E N D A T I O N : Add new text to Paragraph 2-1.1 as follows:'

2-1.1 The installation of fire door assemblies and side hin~ed ~wiflgklg smoke control door assemblies in corridor walls are covered in NFPA 80. Standard on Fire Doors and Fire Windows and Smoke Control Door Assemblies. S U B S T A N T I A T I O N : Because of the magnitude of tile changes in NFPA 80 the Committee teels that it is important to make a complete reference in this sectiou. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 26 VO TE O N COMMITTEE ACTION:


(Log #cc6) 80- 25- (15-5.5): Accept SUBMITrER: Technical Committee on Fire Doors and Windows COMMENT O N PROPOSAL NO: 80-_'2 RECOMMENDATION: Add text ,xs follows:

15-5.5 Where fire doors are used as a part of a smoke-control door assembly, closing mechanisms shall be designed to cause the door to close and latch. S U B S T A N T I A T I O N : This wording is necessary to claril~/the

eration of closing mechanisms. MMITTEE ACTION: Accept.

NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 26 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 NOT RETIIRNED: 1 Goldman

81

Report of the Committee on

Subterranean Spaces

Fred N. Kis.sell, Chair I I.S. Nat'l Inst. for Occupational Safety and Health. PA [RT]

Alex S. Boyer, Ill, (~rmar Group, Inc., MO [U] Rep. Int'l Assn. of Refrigerated Warehouses

Mark S. Broeker, Zurich-American Insnrance Group, Mr) [I] oseph A. Cappuccio, RolfJensen & Assoc., Inc., VA[SE] onaid D. Cummins, Louisville Fire & Rescue, KY [E]

Michael Earl Dillon, Dillon Consulting Engr, Inc., ( ~ [SE] Charles J. Doughty, Nat'l Underground Storage, Inc., PA[M] James c . Duddy, Kansas City Missouri Fire Dept., MO[E] William A. Eppich, The Protectowire Co., Inc., MA[M] Deane IL Holmes, AON Risk Services, Inc., MO [I] LisaJ. Krause, Hunt Midwest Real Estate Development, Inc.,

MO [l J] Ronald J. Land, DynMcDermott Petroleum Operations Co.,

L A [ l q Jim D. Lewis, American Fire Sprinkler Corp., KS [IM] Tracy K. Lundin, Sverdrup Civil, Inc., MA [IM1

Rep. American ITnderground-Construction Assn. Roy Marshall, State of Iowa, IA [E]

Rep. Nat'l Assn. of State Fire Marshals Francis A. McGarry, Frank McGarry, Assoc., Inc., NY [SE] Anthony Meister, Fire Protection and t.~de Consultants, Inc.,

MO [SE] David A. Melzer, Midl,'md Commerical Properties, Inc.,

MO [U] Richard S. Michael, Wyandotte County Health Dept., KS [E] Andy Miller, Hallmark Cards Inc., MO [I~]

Rep. NFPA Industrial Fire Protection Section Jack Poole, Poole Fire Protection Eng., Inc, KS [SE] Edwin A. Rust, II, Kansas City Kansas Fire Dept., ILS [E] Howard (Mike) Thomas, ILS. General Services Administration,

MO [U] B.J. Walker, Walker & Assoc., MO {SE] Ronald R. Walker, American Forest & Paper Assn., ( A [ M ] William D. Wall, Int'l Conference of Building ()ffidaIs, MO[E]

Rep. Int'l Conference of Building Officials Newn L. Wolfe, Jr., u.s. Dept. of the Army, MD [U] Donald R, Woodard, Donald R. Woodard AICP, MO [U]

Rep. Underground Development Assn.

Alternates

Bruce L. Abell, l'oole Fire Protecfi.t~ Engr, hu.. K?; ISF (Alt. to J. Poole)

Terry Brown, (2u'mar (;fOUl), lu~., M() It I I (AIt. to A. S. Boyer)

Sam W. Francis, /Mner]cmJ Forest &: Paper Assl,.. PA I M (Air. to R. R. W,'dker)

Gary W. Kile, Sverdrup Civil, Inc., MA I IMI (Air. to T. IC Lundin)

Charles P. Lazzara, U.S. Nat't hast. tot ()cctlpatiollal S~det'¢ and Health, PA [RT] (Alt. to F. N. Kissell)

Charles A. Rouh, American Fire Sprinkler Corp., [~S [IMt (Alt. to J. D. Lewis)

Tom Steadman, Hunt Midwest Real Estate, Mr) It 1] (Alt. to L.J. Krause)

Paul J. Villotti, Fire Protection and Code Consultants, Inc., MO [SE] (A/t. to A. Meister)

St,aft Liaison: James D. Lake

This list represents the membership at the time the Committee n,a.~ balloted on the text of this edition. Since that time, changes in the membership may have occurred. A k~'y to classifications is found at the front of this book.

Committee Scope: This Committee shall have primary responsibility for documents on safeguarding life and property against tire, explosion, and related hazards associated with occupancies located in subterraneatJ spaces not addressed by other documents.

Tills portion of the Technic~d Committee Repot1 ol the Committee on Subterranean Spaces is preseuled tot a(tol,~iou.

This Report on (;omnmnts v~,ts prepared by the Technical Committee on Subterranean Spaces ~tnd documeuls its action on tile comments received on iL~ Reporl oil Prop,~s, tls on NFPA 520-1999, Standard on Subterranean Spaces. ~u, published in tile Report ou Proposals for the 1998 Fall Meeting.

This Report on Comments has been submitted to letter ballot of the Technical Committee on Subterranean Spaces, which consists of 28 voting members. The results of the balloting, ,after circulation of any negative votes, can be found in the report.

82

john a. mccann, kemper nat'l insurance cos., ma …...16-2.4.3.1 quarterly a visual .., and a...

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