When CMS adopted the 2012 version of the Life Safety Code on July 5, 2016, facilities had one year to come into compliance with the testing of their fire rated door assemblies in accordance with the 2010 version of NFPA 80. As the deadline approached, there was confusion surrounding the process so CMS issued S&C 17-38-LSC which attempted to clarify the requirements, as well as extend the deadline for compliance to January 1, 2018.
Over four years later, the confusion over which fire door assemblies need to be inspected still persists. I want to address one door that I see needlessly inspected as part of the NFPA 80 process, and that is the resident room door. When a nursing home has resident room doors that are labeled as having a fire protection rating, I sometimes see them hire a vendor or have their maintenance staff perform costly, both timewise and moneywise, inspections of all these doors. The idea is to play it safe and ensure that all fire rated door assemblies are accounted for on the annual inspection. I can understand this feeling, but I am a big proponent of saving resources for nursing homes when the life safety code allows us to do so. NFPA 101 (2012) 19.3.6.3.3 says:
“Compliance with NFPA 80, Standard for Fire Doors and Other Opening Protectives, shall not be required.”
A short sentence, but one that can significantly reduce the number of fire door assemblies that a nursing home is required to perform annual NFPA 80 compliant inspections on. Simply put, the facility does not have to perform NFPA 80 inspections on resident room doors.
My focus with this article has been resident room doors, but taking NFPA 101 (2012) 19.3.6.3.3 to its natural conclusion tells us that all corridor doors are accounted for with this particular code. Any door considered to be a corridor door is not required to comply with NFPA 80, and therefore is not required to have an annual NFPA 80 compliant inspection.
Other sections of the code will tell you that there are requirements for corridor doors that you should be aware of, and these doors should be inspected annually. However, the need for costly NFPA 80 compliant inspections is not required.