How Not to Interpret the Life Safety Code

codewatcher lifesafetycodes

Applying a life safety code provision out of context can cost a lot of money.

Recently I taught the Life Safety Code Essentials seminar in Atlanta. Afterward, it occurred to me that while it might seem rudimentary to some, I see enough people trying to use the Code this way that it warrants a blog post.

Let’s say you have an existing five-story building with two exit stairs, each enclosed with 1-hour fire barriers and 45-minute rated doors. You want to determine if this arrangement complies with the 2015 edition of NFPA 101, so you go to the index and look up ‘Enclosures, Exit,’ which directs you to 7.1.3.2. There you see 7.1.3.2.1(3):

(3)*The separation shall have a minimum 2-hour fire resistance rating where the exit connects four or more stories, unless one of the following conditions exists:

(a) In existing non-high-rise buildings, existing exit stair enclosures shall have a minimum 1-hour fire resistance rating…

Since your building is existing and you determine it does not meet the definition of ‘high-rise’, 1-hour enclosures are sufficient. So far so good. Now what about those 45-minute doors?

Back to the index and under the entry for ‘Fire door assemblies’ you find a reference to Table 8.3.4.2, Minimum Fire Ratings for Opening Protectives in Fire Resistance-Rated Assemblies and Fire-Rated Glazing Markings. The table provides the minimum fire protection ratings for opening protectives in fire barriers having various fire resistance ratings and applications. In the row for ‘Vertical shafts (including stairways, exits and refuse chutes)’ and 1-hour walls and partitions, you find an entry indicating 1-hour fire door assemblies are required. Looks like those 45-minute rated doors need to be replaced with 1-hour doors. In a five-story building with two stairs, you’re looking at something like ten doors – not necessarily an inexpensive proposition.

Or are you? This example is based on an activity the students complete in the seminar, and about nine times out of ten, this is the answer they come up with. My response is always, “You can’t use the Code with blinders on. How did you get to Table 8.3.4.2?” In many cases it’s via the index. However, the index is only informational; it points to relevant Code sections. There is nothing mandatory about the index. A table or figure in an NFPA code means nothing until a mandatory code paragraph sends you to the table or figure – typically the paragraph with the corresponding number. If you look at paragraph 8.3.4.2, you find:

8.3.4.2* The fire protection rating for opening protectives in fire barriers, fire-rated smoke barriers, and fire-rated smoke partitions shall be in accordance with Table 8.3.4.2, except as otherwise permitted in 8.3.4.3 or 8.3.4.4.

This is the mandatory requirement that tells you opening protectives need to meet the ratings provided in Table 8.3.4.2. But what about, “except as otherwise permitted in 8.3.4.3 or 8.3.4.4?” Let’s take a look:

8.3.4.3 Existing fire door assemblies having a minimum 3⁄4-hour fire protection rating shall be permitted to continue to be used in vertical openings and in exit enclosures in lieu of the minimum 1-hour fire protection rating required by Table 8.3.4.2.

We can stop there, because 8.3.4.3 gives us the answer: existing ¾-hour, or 45-minute fire door assemblies are permitted in existing 1-hour exit enclosures. If you went straight to Table 8.3.4.2 without looking at paragraph 8.3.4.2 (and subsequently 8.3.4.3), you might have needlessly spent a bunch of money replacing a bunch of perfectly acceptable fire doors without gaining a whole lot of additional protection. Don’t read the Code with blinders on. Look at every requirement in context.

Here’s another example, based on a question I had in the office yesterday. You want to determine if your new building needs elevator lobbies, so again, the index entry for ‘Elevator lobby’ points to 7.2.13.3:

7.2.13.3 Elevator Lobby. Every floor served by the elevator shall have an elevator lobby. Barriers forming the elevator lobby shall have a minimum 1-hour fire resistance rating and shall be arranged as a smoke barrier in accordance with Section 8.5.

Looks like you’ll be constructing rated elevator lobbies with rated doors on every floor level. But are they really needed? If you look at the heading of 7.2.13, it reads, “Elevators in Towers.” The provisions of 7.2.13, including 7.2.13.3, are specific to elevators serving as a second means of egress from towers, such as airport traffic control towers. This is a unique application and elevator lobbies are not generally required by NFPA 101 in typical buildings. Again, applying a code provision out of context could have unnecessarily cost a lot of money.

This content was originally generated by NFPA. For additional blogs and forum discussions, visitNFPA Xchange.