Blog of Aaron J.: egress

In his serial, The Caves of Steel, Isaac Asimov writes of a future crowded nation where underground living is commonplace. However, in Beijing this is a current reality. Nearly one million people live beneath the city. These people are referred to as the shuzu, or “rat tribe”, and they take advantage of the bunkers and fallout shelter systems that were dug in the late 1960’s to 1980’s. These subterranean dwellings present multiple issue to the fire protection and life safety of occupants. NFPA 101, Life Safety Code, Chapter 11, Section 7, provides the basic requirements for life safety within underground and limited access structures.

Underground structures are defined as, “a structure or portions of a structure in which the floor level is below the level of exit discharge”. A limited access structure is, “a structure or portion of a structure lacking emergency access openings”. To qualify as an emergency access opening the window, panel, or similar opening must meet the following criteria:

minimum dimensions of 22" width x 24" high
bottom of opening less than 44" AFF
unobstructed, identifiable, and accessible from both the interior and the exterior

It is important to clearly define whether the space is considered an underground or limited access structure. Each of these have their own, and overlapping, fire protection and life safety requirements. Both structure types must meet all of the following requirements:

Fire sprinkler system is required (with some exceptions, noted in 101:11.7.3.4)

Sprinklers may be omitted if the following applies:

Occupant load is 50 or fewer for new structures, 100 or less for existing
If the structure is permitted to have a single exit (per occupancy use), and the common path of travel does not exceed 50 feet.

Emergency lighting is required, throughout

In addition to these requirements, structures that expressly meet the definition of underground structure must comply with these additional requirements.

Automatic smoke venting systems (required, if following applies):

Occupant load is greater than 100 persons
Occupiable floors are greater than 30 feet below exit discharge
Space contains combustible contents, interior finishes, or construction

Exit stair enclosures are required to have code compliant signage that points to the direction of exit discharge

This is only an encapsulation of the fire protection requirements as outlined in the Life Safety Code. There are many other factors to be considered for safe underground dwelling. Aside from the building code, loads, and material requirements, there are very real emergency response issues. These challenges include ventilation, communication, orientation, access and egress, and patient removal. In areas of occupied subterranean environments departments should be aware of their existence and have robust plans for the maintenance and enforcement of codes and standards, and emergency response.

One of my first large projects in my new position was to ensure that the facility was compliant with all egress and fire door inspection requirements. Having personally conducted inspections of all 200 doors on the facility, I became intimately familiar with the requirements of NFPA 101:7 and NFPA 80. Recent editions of NFPA 101 require that egress and fire doors be inspected annually.

NFPA 101:7.2.1.15:

Where required by Chapters 11 through 43, door assemblies for which the door leaf is required to swing in the direction of egress travel shall be inspected an tested not less than annually in accordance with 7.2.1.15.2 throught 7.2.1.15.8.

NFPA 101:7.2.1.15.2:

Fire-rated door assemblies shall be inspected and tested in accordance with NFPA 80, Standard for Fire Doors and Other Opening Protectives.

NFPA 80 clearly outlines how these annual inspections are to be conducted and what components must be inspected.

NFP 80:5.2.41 clearly states that fire doors must be inspected annually. Some occupancy types require more frequent inspections (NFPA 409 requires monthly visual inspections, for example). Although there are several fire door inspection agencies, organizations, and certification courses around, NFPA 80 does not require a special certification, it merely states a person "with knowledge and understanding of the operating components of the type of assembly being subject to testing". It is also not the AHJ's job to conduct the fire door inspection, it is on the building owner to have the inspections conducted and a record available for the AHJ.

One of the most important considerations is to ensure that the inspections (and any deficiencies) are clearly documented, and all required components are thoroughly inspected. One of the best forms for this is available for free from www.idighardware.com, it is a single checklist (each door on the facility should have its own inspection sheet), that thoroughly lists all inspection criteria.

NFPA 80 Inspection Form

**Using Target Solutions for inspections? E-mail me to receive a fire door inspection template.**

Another important form to have available is an inventory sheet of all facility doors, here is a simple one that I created for use on our facility (feel free to steal):

Egress/Fire Door Inventory Sheet

Inspection records are required to have 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

(9) Type and description of each inspected and tested fire door assembly

(10) Verification of visual inspection and functional operation

(11) Listing of deficiencies

Doors should be inspected from both sides to ensure compliance. Inspections should denote the following deficiencies (NFPA 80:5.2.3.5):

(1) Labels are 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 allowed.

(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.

(13) Any signage is properly affixed to the door (per NFPA 80:4.1.4).

Fire doors must not exceed allowable clearances between the door and the frame, the door and the sill, or between two doors. The required maximum clearances are as follows:

the clearance under the bottom of the door must not exceed 3/4"

if bottom of door is more than 38" AFF clearance cannot exceed 3/8"

clearance at top of a steel door or between pairs of doors must be 1/8-1/16"

wood doors must not exceed 1/8"

There are several useful tools for checking these clearances quickly and reliably (much better than using a tape measure and "eyeballing" it). I personally use, and recommend, this this one from Aegis Fire Barrier Consultants, or this one from DoorGap Gauge.

All inspection records are to be kept for three years.

The most important part of any inspection program is, not just documenting deficiencies, but ensuring that they are corrected. It is only when these fire doors are properly installed and maintained that they can effectively accomplish their intended purpose.

Further reading:

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