Decoded: Double-Egress Pairs in a Health Care Occupancy

In the 2021 edition, Section 709.5 Exception 1 exempts smoke barrier doors in some health care occupancies from the requirements that apply to smoke barriers in other locations.

A Double Egress Pair
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Smoke barriers are designed and constructed to restrict the movement of smoke, and are used to subdivide a building into smaller smoke compartments. In health care facilities, patients can be moved from one smoke compartment to another, to be protected by the smoke barrier until they are able to be evacuated.

The International Building Code (IBC) requires smoke barriers to have a 1-hour fire resistance rating, with the exception of steel smoke barriers in Group I-3 buildings (detention and correctional occupancies). According to the IBC table entitled, Opening Fire Protection Assemblies, Ratings, and Markings (Table 716.1(2) in the 2021 edition), a 1-hour smoke barrier is required to have a 20-minute-rated fire door assembly, which is tested and listed to provide protection for a minimum of 20 minutes.

There is an IBC exception to this requirement for smoke barrier doors that has been one of the most confusing and widely debated door-related sections in the code.  This section has been modified over several editions of the IBC with the goal of clarifying the intent of the code, but the progression of the changes may have temporarily made the requirements more difficult to interpret.

In the 2021 edition, Section 709.5 Exception 1 exempts smoke barrier doors in some health care occupancies from the requirements that apply to smoke barriers in other locations. The occupancies in the exception are Group I-1 Condition 2 (buildings where there are people receiving care who require limited verbal or physical assistance in order to evacuate), Group I-2 (including hospitals, nursing homes, psychiatric hospitals, foster care facilities, and detox facilities), and ambulatory care facilities (these occupancy types were modified in the 2015 edition).

In these locations, the doors are not required to be fire door assemblies. The exemption from the fire rating applies to pairs of “opposite-swinging doors” installed across a corridor – commonly called double-egress pairs. The 2015, 2018, and 2021 editions of the IBC clearly state that these doors are not required to be protected in accordance with Section 716 – in other words, they are not required to be opening protectives, also known as fire door assemblies. Editions of the IBC prior to the 2015 edition did not specifically state this.

The doors are required to be automatic-closing, actuated by smoke detection, and must be “close fitting within operational tolerances.” Louvers, grilles, and center mullions are not allowed, and undercuts are limited to 3/4-inch. The frame must have stops at the head and jambs, and the doors must have astragals at the meeting edges or rabbeted meeting stiles to help slow the spread of smoke. These doors are also required to have a vision panel with fire-protection-rated glazing in fire-protection-rated frames.  In the 2018 edition, a change was made that allows factory- or field-applied protection plates that are not required to be labeled.

By adding the requirements related to clearances, glazing, and automatic-closing devices, the code has taken a door without a fire label, and turned it into a door that will behave like a 20-minute door. And what about positive-latching hardware, which is a requirement for fire doors? The 2003 and 2006 editions of the IBC specifically state in this section: “Positive-latching devices are not required.” In the 2009 edition, this was changed to, “Where permitted by the door manufacturer’s listing, positive-latching devices are not required.” But if these doors are not fire rated, what “listing” is the code referring to? This section also limits the glazing – “the area of which shall not exceed that tested.”  Again, what test?  There is still a little more work to be done on this section to make sure it’s completely clear.

The 2021 edition of NFPA 101 requires doors in this location to be “substantial doors, such as nonrated 1 ¾-inch thick, solid-bonded wood-core doors, or shall be of construction that resists fire for a minimum of 20 minutes.”  Other criteria include:

  • Protective plates of any size, without a listing, are permitted.
  • A pair of swinging doors or a horizontally sliding accordion door or folding door assembly may be used.
  • Swinging doors must be double-egress pairs – each leaf swinging in the opposite direction.
  • Minimum clear width of swinging doors ranges from 32 inches for a 6-foot corridor to 41 ½ inches for an 8-foot corridor (consult NFPA 101 for sliding door requirements).
  • Clearance at the bottom of the door is limited to ¾-inch.
  • A single door is allowed if the door is not in a required means of egress from a health care space.
  • Doors must be self-closing or automatic-closing.
  • Latching hardware is not required.
  • Head and jamb stops are required on the frame.
  • The meeting edges must be rabbeted, beveled, or equipped with astragals.
  • Center mullions are prohibited.
  • Vision panels are required, consisting of fire-rated glazing in approved frames, with the bottom of at least one vision panel in each leaf at a maximum height of 43 inches above the floor.

While NFPA 101 is clearer and does not include some of the conflicting language that has been in the IBC, questions remain.  It is very common to find double-egress cross-corridor doors in existing health care facilities with inconsistent door and hardware applications.  The doors may be labeled as fire doors, in which case they will typically have positive-latching hardware and meet all of the other requirements of NFPA 80 – Standard for Fire Doors and Other Opening Protectives.  For several years, many door manufacturers used the equivalent of a construction label, which stated that the doors were constructed as 20-minute doors, but positive-latching hardware was not required – this is another common situation in existing buildings.  According to the current codes, these doors would not required a label of either type, but must meet all of the criteria stated in the adopted code.

Keep in mind that this article addresses double-egress cross-corridor doors in a smoke barrier.  Door assemblies in other configurations may have different requirements.  For example, a pair of doors serving a suite may look like cross-corridor doors, but they are typically subject to the requirements for corridor doors – which would include positive-latching hardware.  When in doubt, contact the adopted code(s) or the Authority Having Jurisdiction (AHJ) for assistance.

This article was originally published on https://idighardware.com.