New for 2001: More Codes Featuring Positive Pressure.

JUST WHEN YOU THOUGHT THE CHANGE IN fire door testing and certification was being sorted out things are about to get complicated again. The 1997 Uniform Building Code (UBC) has just recently started to really take hold in the areas of the country where it has been adopted. However, the 1997 UBC is already an orphan--an obsolete building code that has been bypassed by its own creators. By the end of this year, as many as 14 states may have adopted (or be in the final stages of the adoption process) the 2000 International Building Code (IBC 2000). About half the states could be using the IBC by the end of 2002. Some of these states will be replacing the 1997 UBC with the IBC 2000 code. By the end of 2003, it is expected that most of the states in the country will be using some version of the IBC. (See figures 1-3 on page 12.) The other two major model codes--the National Building Code (BOCA), and the Standard Building Code (SBCCI)--are also destined for the scrap heap. Only the International Code" family of bui lding codes are being supported by the three model code agencies.

This means that the fire door requirements will include "positive pressure fire testing" and "smoke and draft control" certification in parts of the country that have been out of the ICBO Uniform Building Code process so far. In addition, the IBC's requirements and language differ somewhat from the UBC system, so we will need to tinker a bit more with testing, certification, labeling and installation issues.

NFPA 5000--back to multiple model codes?

Not complicated enough for you? Well, NFPA (the National Fire Protection Association) has recently published the first draft of its "brand new" NFPA 5000 Building Code. This is a model code that is intended to compete head-on with the IBC. The reasons for this development would take up an entire article to discuss in detail. Suffice it to say that NFPA and ICC (International Code Council) disagree on how codes should be developed. The ICC (an organization of building officials) believes that the building officials themselves should have the final say on the content of codes. NFPA believes that codes should be developed by committees that include representatives of all interest groups using a consensus process.

In addition, the ICC published its own "International Fuel Gas Code" which is nearly the same as the NFPA "National Fuel Gas Code" (NFPA 54). NFPA then issued a notice that they planned to rename the "National Electric Code" (NFPA 70) the "International Electric Code." This upset the ICC because they trademarked the use of the term "International" in building code titles. Now both organizations are touting their system as one that supplies a complete and coordinated set of codes. Needless to say, the "one-country, one-code" concept that led to the formation of the ICC has suffered a major setback. The building industry seems to overwhelmingly be calling to these two groups to get together and settle their differences so that the "one model code" concept can get back on track.

The NEPA code is not scheduled for completion until 2003, so a lot could change. The NFPA 5000 draft is largely a compilation of sections from older codes. The fire door section in the draft references ASTM E152 as the test standard, which is an indication that the sections involved are quite out of date. ASTM withdrew ASTM E152 in 1995. However, it appears that "positive pressure" and "smoke and draft" will be part of the fire door performance criteria no matter what the ultimate code situation is. There is little doubt that, as NFPA goes through the review and comment process with NFPA 5000, there will be persuasive proposals to update the fire door test requirements to the current positive pressure standards.

Code agency merger

The three model code agencies, ICBO, BOCA and SBCCI, have started exploring a merger. If no major obstacles are encountered, this could become a reality in 2002. A merging of these organizations of building officials would seem to be good news for the building industry, since it would tend to reduce the possibility of conflicting code interpretations. It should also make it easier to obtain truly national acceptance of building materials and products with a minimum level of redundancy in the review process.

Enforcement issues

It may come as a surprise to much of the door and hardware industry that the change to positive pressure fire testing of doors that was part of the 1997 UBC has not been noticed or enforced by very many building officials. They have, however, noticed the new "Smoke and Draft Control" requirements. In fact, most of the enforcement issues that we hear about are based on the smoke and draft requirements. There is relatively little recognition that the fire testing has actually changed under the new codes among Authorities Having Jurisdiction (AHJ).

This is quite understandable. After all, the change to positive pressure fire testing occurred through the addition of just a few words to the existing code language and revision of the UBC test standard (and the issuance of UL 10C). The impact is not obvious to anyone who is not intimately familiar with the test procedures and how assemblies respond to these conditions. Building officials do not generally spend a lot of time reading the test standards that the code references. The smoke and draft control revisions, on the other hand, added substantial new language to the body of the code and specific direction regarding the need for new labeling information. This is the type of information that building officials quickly pick-up on because it requires them to perform a specific check in enforcing the code.

The reality is that even if the AHJ does not realize that a change has been made and therefore does not scrutinize affected construction for the correct compliance indications, the builder and architect can still be held accountable for code compliance. Just because you don't get caught in a code violation during construction doesn't mean that you can't be held accountable and perhaps liable when the violation is discovered. It is, therefore, wise to make sure that you understand the code and provide compliant products and assemblies, even if the code official is not up to speed on the details. In fact, it is in everyone's interest to do whatever they can to educate AHJs on the finer points of the new requirements and labeling procedures.

Other significant changes

We have focused for the last few years on the positive pressure testing and smoke and draft control requirements. From a testing and certification point of view, this has been where the action is. That is, most manufacturers of fire door assembly components have had to get their products re-evaluated for performance under the new procedures. At this time, there are many products that carry positive pressure fire resistance and smoke and draft control ratings.

There is another code change coming that has not received a lot of attention yet, but is of considerable significance. That is the treatment of sidelights and transoms in the IBC 2000. The change essentially eliminates the sidelight and transom portions of the assembly from the "20-minute without hose" allowance. This means that, under the new codes, the door itself may be allowed to have a 20-minute rating and be exempt from the hose stream test, but the rest of the assembly must meet the window test requirement of 45 minutes fire exposure followed by the hose stream test (see IBC 2000, 714.2.3). This is a very significant change in that many assemblies that pass the "20-minute-no-hose stream" test will not meet the 45-minute with hose stream test requirements. Many glazing systems that are acceptable for "20-minute-no-hose stream" applications will not meet the more demanding test requirements.

This code change has not resulted in substantial new testing since there are 45-minute or higher rated assemblies already available that can be used to meet this requirement. Most of the "20-minute-no-hose stream" rated assemblies cannot be easily redesigned to meet the much more stringent 45-minute requirement. The net result is that, to comply with the new code requirements, you need to use a 45-minute minimum rated doorframe/sidelight/transom assembly in which you can install a "20-minute-no-hose stream" rated door. By the way, the glazing used in the door can also be "20-minute-no-hose stream" rated.

This change can be seen as a response to a concern that the "20-minute-no-hose stream" rating was being extended to parts of the assembly that really should not be exempted from the regular fire resistance test requirements. Large multiple light assemblies that might exceed 100 square feet could leave a breach of this size in a rated fire wail shortly after 20 minutes into a fire. This would seem to compromise the integrity of a fire barrier beyond that which was envisioned by the code writers.

NFPA 80 and NFPA 105

NFPA 80 was revised in 1999 but did not include any acknowledgement of the "positive pressure" issues. NFPA 105 is a document that provides recommendations for smoke and draft control properties of door assemblies, but it is not in step with the new codes. The NFPA committee responsible for both documents has started the process of updating and coordinating these important standards. The first step in this process is to rework the revision schedules so that the two documents are handled in the same NFPA revision cycle.

An attempt to address smoke and draft control within NFPA 80 was abandoned when the proposals were voted down by the NEPA membership in 1999. In fact, a complete rewrite of NFPA 105 has recently been sent back to the committee for additional review. One issue here is whether or not to include coverage for doors other than side hinged swinging doors and door openings that are not required to be fire rated. The issue is further complicated by the question of whether NEPA 105 should be a "recommended practice" as it is in the current edition, or a "standard." Since it would be likely to be referenced in both the Life Safety Code (NFPA 101) and potentially in future editions of model codes, the distinction is critical in terms of the level of enforcement.

What is clear is that the NEPA 80/105 committee recognizes the need to address the installation and coordination issues that are necessary to assure that assemblies comply with the code requirements. It may be a few years off, but we can expect that the next version of these standards will provide significant additional help to installers and AHJs in assuring that positive pressure and smoke and draft assemblies are properly installed.

In a separate process, revisions to NEPA SO that deal specifically with "Positive Pressure" have been proposed by the task group. These changes are not too complicated; they essentially define what a positive pressure assembly is and require appropriate labeling and installation instructions to be provided.

There are some other code revisions contained within the IBO that will have an impact to some degree on the fire-rated door and hardware industry.

Sprinkler tradeoffs

The IBC adopted most of the code provisions of the BOCA National Building Code that allow for reductions in the need for passive fire resistant construction when buildings are equipped with automatic active fire suppression systems--a.k.a. "sprinklers." The concept behind these tradeoffs is that, while much more expensive than the difference between ordinary and fire resistant construction, sprinkler systems have proven to be very effective at limiting the spread of fire, property damage and loss of life. Therefore, to encourage their use, architects and building owners should receive some building cost offset if they are willing to pony up for the sprinkler system.

The "sprinkler" supporters were quite successful in selling this concept to the code writers. If fact, they were so successful that the IBC adopted a number of changes that mandated the installation of sprinklers in many occupancy classifications. This, of course, means that it is no longer a matter of the architect's or building owner's choice. If a building must have sprinklers, and having sprinklers reduces the need for fire resistant construction, then there will be less fire resistant construction.

Now this situation makes some engineers and building officials nervous. The reason is that there are a number of instances in which sprinkler systems can be completely ineffective. For example, in seismically active areas such as much of the West Coast, earthquakes often cause both fires and breaks in water mains. Most sprinkler systems require a reliable supply of water through regular mains to function (although some do not). Another worrisome scenario is the well-planned, "professional" arson fire. In this case, the arsonist simply breaks through the sprinkler system locks and closes the main water supply valve.

In addition, there was a recent incident wherein over 8 million defective or suspect sprinkler heads were recalled. It was estimated in this case that as many as 30% of these devices might not function in a fire.

Supporters of passive fire protection systems such as fire-rated walls and floor/ceiling systems argue that this type of construction has a quite small marginal cost above that of ordinary, non-fire-rated construction. They argue that both types of protection have their place in the same building design. One system simply backs up the other. However, as things now stand, the use of the IBC would mean less demand for fire resistant construction products in areas that switch to the IBC from the UBC or the SBC. There would be little effect in areas that currently use the National Building Code.

Exit device requirements

The IBC increases from 50 to 100 the occupant load that requires the use of panic or fire exit hardware. This applies to Group A (assembly), Group E (educational) and Group H (high-hazard, except H-4) occupancies. This change will have some effect in reducing the demand for these hardware types. The effect will be most apparent in small educational facilities such as daycare centers and assembly buildings with typically moderate occupant loads such as smaller restaurants, taverns and bars.

There are, doubtless, many other changes from the existing codes that will not become apparent until specific situations come up in the field. The IBC is a different document than any of its three predecessors. In many ways, it is improved by simpler, clearer language and reduced redundancy. But, it must be viewed as a living document that will evolve over time. Certainly the change that occurred in the 1997 UBC and that has carried through to the IBC regarding positive pressure fire door testing and smoke and draft control assembly certification has been a very big change for the industry to absorb. This process will continue to involve ever-increasing market areas. But the good news is that no additional major changes appear to be coming. Therefore, we should be able to remain focused on the task at hand--namely refining our products and systems to provide a workable and reliable mechanism that assures compliance with the codes as they now exist.

Rick Curkeet is the Chief Engineer for Building Products for Intertek Testing Services (ITS) North American operations. ITS is a leading third-party testing and certification agency for building materials and products, and it owns and administers the use of the familiar Warnock Hersey "WHI" certification mark. Mr. Curkeet is a Registered Professional Engineer (PE) and has more than 20 years of experience in the building products testing and certification field.