Report on Comments A2006 Copyright, NFPA NFPA 80 Report of the Committee on Fire Doors and Windows

Transcription

1 Report of the Committee on Fire Doors and Windows Harold D. Hicks, Jr., Chair Atlantic Code Consultants, PA [SE] Calvin A. Banning, Framatome ANP, TX [SE] Robert M. Berhinig, Underwriters Laboratories Incorporated, IL [RT] Daniel R. Bernacki, International Door Association, OH [IM] Bruce G. Campbell, Hughes Associates, Incorporated, CO [SE] David S. Cha, Northwestern Memorial Hospital, IL [U] Paul R. Coleman, Sisters of Providence Health Care System, OR [U] Rep. NFPA Health Care Section William Conner, Bill Conner Associates LLC, IL [SE] Rep. American Society of Theater Consultants Edward A. Donoghue, Edward A. Donoghue Associates, Incorporated, NY [M] Rep. National Elevator Industry Incorporated (VL to Issue: Elevators) Philip C. Favro, Philip C. Favro & Associates, CA [SE] Jerrold S. Gorrell, City of Phoenix, AZ [IM] Rep. US Institute for Theatre Technology Jeffrey E. Gould, FM Approvals/FM Global, MA [I] Steven C. Hahn, Lawrence Roll-Up Doors, Incorporated, CA [M] () Rep. American Rolling Door Institute Wayne D. Holmes, HSB Professional Loss Control, CT [I] Thomas R. Janicak, Ceco Door Products, TN [M] Rep. Steel Door Institute William E. Koffel, Koffel Associates, Incorporated, MD [M] Rep. Glazing Industry Code Committee Nancy L. Kokesh, Intertek Testing Services, NA Incorporated, WI [RT] Curtis Maffett, City of Columbia, SC [E] Richard N. McDaniel, Virginia Dept. of Housing & Community Development, VA [E] Keith E. Pardoe, Door and Hardware Institute, VA [M] Vernon J. Patton, First Energy Corporation, OH [U] Ronald Rispoli, Entergy Corporation, AR [U] Joseph N. Saino, Chase Durus Industries, TN [M] Rep. National Association of Architectural Metal Manufacturers David A. San Paolo, The Maiman Company, MO [M] Rep. Window & Door Manufacturers Association Michael L. Savage, Sr., Middle Department Inspection Agency, Incorporated, MD [E] Michael Tierney, Builders Hardware Manufacturers Association, CT [M] Robert Van Becelaere, Ruskin Manufacturing, MO [M] Anthony W. Yuen, University of California, CA [U] David F. Mauldin, Schindler Elevator Corporation, PA [M] (Alt. to Edward A. Donoghue) Kurt A. Roeper, Ingersoll-Rand Security & Safety, OH [M] (Alt. to Thomas R. Janicak) Rep. Steel Door Institute Helen Rose, Lorient North America, KY [M] (Alt. to Michael Tierney) Rep. Builders Hardware Manufacturers Association Thomas M. Rubright, William S. Trimble Company, Incorporated, TN [M] (Alt. to Keith E. Pardoe) Rep. Door & Hardware Institute Emmanuel A. Sopeju, Underwriters Laboratories of Canada, Canada [RT] (Alt. to Robert M. Berhinig) James A. Stapleton, Jr., Habersham Metal Products Company, GA [M] (Alt. to Joseph N. Saino) Staff Liaison: Milosh T. Puchovsky Committee Scope: This Committee shall have primary responsibility for documents on the installation and maintenance of fire doors, windows, shutters, and other equipment used to restrict the spread of fire, including arrangements for automatic operation in case of fire. This includes installation to protect buildings against external fire and to restrict the spread of fire within buildings. Vault and record room doors are covered by the Technical Committee on Record Protection. This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book. The Committee on Fire Doors and Windows is presenting two Reports for adoption, as follows: Report I of this Report on Comments was prepared by the Technical Committee on Fire Doors and Windows, and documents its action on the comments received on its Report on Proposals on NFPA 80, Standard for Fire Doors and Fire Windows, 1999 edition, as published in the Report on Proposals for the 2006 June Meeting. When adopted, NFPA 80 will be redesignated as NFPA 80, Standard for Fire Doors and Other Opening Protectives. NFPA 80 has been submitted to letter ballot of the Technical Committee on Fire Doors and Windows, which consists of 28 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. Alternates Scott K. Anderson, FM Global, MA [I] (Alt. to Jeffrey E. Gould) Richard Cookson, The Cookson Company, AZ [M] (Alt. to Steven C. Hahn) John G. Crowther, Framatome ANP, TX [SE] (Alt. to Calvin A. Banning) Michael D. Fischer, Window & Door Manufacturers Association, IL [M] (Alt. to David A. San Paolo) James L. Giles, International Door Association, MN [IM] (Alt. to Daniel R. Bernacki) Report II of this Report on Comments was prepared by the Technical Committee on Fire Doors and Windows, and documents its action on the comments received on its Report on Proposals on NFPA 105, Standard for the Installation of Smoke Door Assemblies, 2003 edition, as published in the Report on Proposals for the 2006 June Meeting. NFPA 105 has been submitted to letter ballot of the Technical Committee on Fire Doors and Windows, which consists of 27 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. 80-1

2 80-1 Log #97 Final Action: Reject All non-nfpa references will be updated to their current editions. (1.5.1 [4.2.1 Draft]) Committee Statement: Submitter: Eddie Phillips, Southern Regional Fire Code Development Committee Number Eligible to Vote: 28 Ballot Results: Affirmative: 27 Comment on Proposal No: Recommendation: Reconsider the original proposal and accept Revise to read as follows: Listed items shall be identified by a label. Labels shall be applied 80-5 Log #3 ( [ ]) Final Action: Reject in locations that are readily visible and convenient for identification by the authority having jurisdiction after installation of the assembly. Labels shall be of metal or plastics and shall have letters that are raised, stamped or diecast. Substantiation: The definition does not speak to the type or makeup of the label. We are taking the annex material and taking the option away to ensure that labels are readable after installation, painting, etc. Committee Statement: The committee believes that the proposed requirement for labels is too limiting. Other means of labeling products such as etching of glass would also be effective. Additionally, the committee is of the opinion that the submitter s recommendation does not address all of the concerns indicated in the substantiation such as the painting or removal of labels. The committee prefers to leave the language as advisory information. Number Eligible to Vote: 28 Ballot Results: Affirmative: 27 Submitter: R. Joseph Pearson, Guardian Fire Testing Laboratories, Inc. / Rep. ASHRAE Comment on Proposal No: Recommendation: Add an exception to read: Exception: Mechanical and electrical rooms that are always locked except when working in the rooms. Substantiation: Mechanical rooms should not have closers on the doors for the safety of the workers doing work in the rooms. These rooms or pipe shafts are dangerous to worn in.! Committee Statement: The proposed language as proposed in section of the draft allows for the AHJ to make appropriate decisions as necessary Log #98 Final Action: Reject (1.13) Submitter: Eddie Phillips, Southern Regional Fire Code Development Committee Comment on Proposal No: Recommendation: Reconsider the original proposal and accept. Add a new Section 1.13 to read as follows: 1.13 Color Coding of Door Operation. All swings and movement areas for three-hour fire doors shall be painted yellow to indicate the clear doors movement areas. Substantiation: The floor marking requirement is needed as a tool to notify occupants of the area that needs to be kept clear for the proper operation of the door. This proposal will permit easier compliance as the AHJ could easily walk into the building and see if items are placed in the prohibited area. The proposal only speaks to three or more hour doors which in most cases are installed in industrial and storage occupancies which are used to these types of warning or cautionary signs. Committee Statement: The committee restates its previous position that it does not believe that the recommendation is enforceable and that it is not practical in all situations requiring a 3-hour door. The recommendation would require all floor coverings such as carpets to be painted or otherwise marked Log #71 Final Action: Accept in Principle (2.2) Submitter: Joshua W. Elvove, US Department of Veterans Affairs Comment on Proposal No: Recommendation: Update all NFPA references as they all are outdated. Substantiation: Per NFPA policy. All NFPA references will be updated in accordance with the Manual of Style. Committee Statement: Meets submitter s intent. Number Eligible to Vote: 28 Ballot Results: Affirmative: Log #CC3 Final Action: Accept (2.3) Comment on Proposal No: 80-4 Recommendation: Update all non NFPA references. Substantiation: This Committee Comment was generated as a result of an editorial review of this document. The recommendation contains recommended editorial changes, that resulted from editing the ROP draft that require Committee review and action Log #2 Final Action: Reject ( (New) ) Submitter: R. Joseph Pearson, Guardian Fire Testing Laboratories, Inc. Comment on Proposal No: 80-1 Recommendation: Add an exception to read as follows: Exception: Mechanical and electrical rooms that are always locked except when working in the rooms. Substantiation: Mechanical rooms should not have closers on the doors for the safety of the workers doing work in the rooms. These rooms or pipe shafts are dangerous to work in! Committee Statement: See committee action and statement to Comment 80-5 (Log #3) Log #73 Final Action: Accept in Part (3.3.x Pass Door (New) ) Submitter: Joshua W. Elvove, US Department of Veterans Affairs Comment on Proposal No: 80-1 Recommendation: Provide a new definition for pass doors as follows: 3.3.x Pass Door. A full-size swinging door in a horizontal sliding door for personnel use. Substantiation: Pass doors are discussed in and but they aren t defined. A definition is needed so code users understand what these are. Note: The Committee is free to revise this definition as they deem necessary. in Part Accept the submitter s recommendation with the following revisions. 3.3.x Pass Door. A full-size swinging door in a horizontal sliding door for personnel use. Committee Statement: The pass door could also apply to vertical sliding doors. The term full-size is ambiguous and not enforceable Log #72 Final Action: Reject (3.3.x Sill (New) ) Submitter: Joshua W. Elvove, US Department of Veterans Affairs Comment on Proposal No: 80-1 Recommendation: Provide a new definition for sills: 3.3.x Sill. The committee is free to develop their own definition. Substantiation: The term Sill is used throughout this document, yet is only defined in two instances: for Rolling Steel Fire Doors and for Service Counter Fire Doors. In all locations within this document other than where the term is specifically used for either rolling steel or service counter fire doors, the term sill isn t defined. A definition is needed for where sills are discussed/installed in instances

3 other than where currently defined (i.e., swinging, lap mounted, horizontal sliding doors; clearances etc.). Committee Statement: The committee does not believe that a definition is necessary. Where defined, it is done so for specific applications Log #CC15 Final Action: Accept (3.3.5 Astragal) Comment on Proposal No: Recommendation: Revise to read as follows: 3.3.5* Astragal. A Astragal. Astragals are used to protect against weather conditions, to minimize the passage of light between the doors, to reduce sound transmission or to retard the passage of smoke, flame, or gases during a fire, and, in the case of a Dutch door, also to ensure that the lower leaf of the door closes in conjunction with the upper leaf Overlapping or Wrap-Around Astragal. A horizontal or vertical molding attached to the meeting edge of one leaf of a pair of doors. to protect against weather conditions, to minimize the passage of light between the doors, or to retard the passage of smoke, flame, or gases during a fire, and, in the case of a Dutch door, also to ensure that the lower leaf of the door closes in conjunction with the upper leaf * Split Astragal. A horizontal or vertical molding attached to both leaves of a pair of doors at the meeting edges for protection against weather conditions. A Split Astragal. Split astragals can also be permitted to may be used where both leaves are active overlapping astragals are not required by the listing of the door. Substantiation: This clarifies the committee s intent with regard to the types of astragals that could used in conjunction with a fire door and the potential reasons for the use of astragals. The committee notes that in some cases the overlapping astragal may be an integral part of the door assembly and that it is necessary in satisfying fire test requirements. The committee also notes that split astragals are not used as part of the fire test protocol. The term wrap-around astragal was deleted as it is not used in the standard. Ballot Results: Affirmative: 25 Negative: 1 Explanation of Negative: HOLMES, W.: In , the words at the meeting edge must be retained. Otherwise, any molding, including decorative molding, attached to one leaf of a pair of doors will be, by definition, an Overlapping Astragal. The definition as revised by 80-9 is incomplete and incorrect. In , the words at the meeting edge must be retained. Otherwise, any molding, including decorative molding, attached to both leaves of a pair of doors will be, by definition, a Spit Astragal. The definition as revised by 80-9 is incomplete and incorrect. This comment should be defeated and the text of NFPA 80 revert back to the current definitions of Overlapping and Split Astragals. During the next revision cycle the committee might consider revising the definition to be something like A horizontal or vertical molding attached to and projecting from the leading edge of both pairs (one leaf of a pair) for doors Log #78 Final Action: Accept in Principle ( Split Astragal, A , , A.6.1.2, 6.4.7, A.6.4.7) Submitter: Joshua W. Elvove, US Department of Veterans Affairs Comment on Proposal No: 80-4 Recommendation: The following five modifications pertain to (split) astragals. 1. Revise the following definition as follows: * Split Astragal. A vertical molding attached to both leaves of a pair of doors at the meeting edge for protection against weather conditions or retard the passage of smoke, flame and gases during a fire. 2. Revise the annex note for split astragals as follows: A Split Astragal. Split astragals can also be permitted to be used where both leaves are active. 3. Insert the following text into : Preparation of fire door assemblies... vision panels, louvers, astragals and split astragals, and the Insert the following text into the second sentence of A.6.1.2: A They also include, but are not limited to, an astragal, a split astragals, an automatic louver, Add an asterisk to and the following corresponding new annex note: A A split astragal may be considered a type of astragal. Substantiation: This proposed intends to clarify that split astragals may be used on fire doors. The function of an (overlapping or wraparound) astragal and a split astragal is basically the same: to protect against weather conditions, or retard the passage of smoke, flame or gases during a fire. (1) The current definition for split astragals doesn t state that split astragals could be used to retard the passage of smoke, flame or gases during a fire, hence the need for new proposed text. This revised definition is needed as some AHJs do not permit split astragals to be installed on fire doors because the current (and currently proposed) definition of Astragals (Split) in NFPA 80 only discusses their use to protect against weather conditions vis-à-vis the current definition in NFPA 80 for Astragals (Overlapping or wraparound) which permits their use to retard the passage of smoke flame or gases during a fire. (2) The new annex note is text that has been relocated from the definition (Section 1.4) of the previous edition of NFPA 80. However, since it refers to split astragals, it needs to be revised to say specifically so. (3) & (4) Split astragals need to be added to the list of appurtenances and normal components of a fire door assembly to indicate that they are permitted. (5) The new annex note in the section entitled Astragals is needed to clarify that a split astragal is a type (or subset) of astragal. With regard to parts 1 and 2 of the submitter s recommendation, see Committee Comment 80-9 (Log #CC15). With regard to items 3, 4 and 5 of the submitter s recommendation, the committee recommends accepting without modification. Committee Statement: See Committee Comment 80-9 (Log #CC15) Log #74 Final Action: Reject ( Bottom Bar (Rolling Steel Door)) Submitter: Joshua W. Elvove, US Department of Veterans Affairs Comment on Proposal No: 80-1 Recommendation: Revise the definition of Bottom Bar is by deleting text as follows: Bottom Bar (Rolling Steel Door). A reinforcing member at the lower edge of the door curtain assembly. Substantiation: The definition for Bottom Bar in as proposed only applies to Rolling Steel Doors. However, the definition for Sill (Service Counter Fire Door) in also includes a reference to bottom bars (as does the definition for Sill (Rolling Steel Fire Door) in ). If bottom bar as defined by is also applicable to Service Counter Fire Doors, then the parenthetical text needs to be deleted as the definition should not be constrained to only Rolling Steel Fire Doors. Note: If the definition for Bottom Bar as currently proposed in only applies to Rolling Steel Fire Doors, then the Committee needs to develop a new definition for Bottom Bar as it applies to Service Counter Fire Doors to distinguish the difference between the two definitions where bottom bar appears in ( and ). Committee Statement: The committee does not believe that the change is necessary. Per section service counter fire doors are categorized as one of three type of fire doors. One of these types is a rolling steel fire door Log #75 Final Action: Accept ( Meeting Edge) Submitter: Joshua W. Elvove, US Department of Veterans Affairs Comment on Proposal No: 80-1 Recommendation: Delete the definition for meeting edge in Substantiation: The definition for Meeting Edge in states: A resilient member used on the leading edges of elevator doors to prevent crushing or shearing of the edges. Elevator doors are discussed in and throughout Chapter 14, but the term meeting edge is not used. In fact, the only places the term meeting edge is used in NFPA 80 are the following three locations: (definition of astragal), in (definition of split astragal), and (clearances). Since these three instances have nothing to do with elevator doors, the existing definition is misleading and/or superfluous. Delete this definition, or revise it to be in line with how the term is used in the three (non-elevator door) instances where it appears in NFPA 80.

4 Number Eligible to Vote: 28 Ballot Results: Affirmative: Log #CC19 Final Action: Accept (3.4 and (New) ) Recommendation: 1. Relocate all of section Fire Safety Curtain Definitions to a new In addition, copy all definitions from existing Section 3.4 and relocate them into section 3.3 in the appropriate alphabetical order. 2. Relocate all of the definitions of section 3.5, Fire Damper Definitions to Section 3.3 in the appropriate alphabetical order. Substantiation: Editorial reorganization Log #38 Final Action: Accept (3.4.2 Bottom Seal (Yield Pad)) Bottom Seal (Yield Pad). Bumper. A filled fabric pocket below the bottom batten or frame member of a fire safety curtain designed to press against the floor. Substantiation: A seal is not quantifiable and therefore an inappropriate and misleading term. Bumper is more descriptive and preferred term for fabric and filler at the bottom of a curtain Log #39 Final Action: Accept (3.4.7 Roller Guide/Metal Track Side Edge Guide System ) Recommendation: Deleted text Roller Guide/Metal Track Side Edge Guide System. Continuous tracks with captive trolleys or rollers at each vertical edge of the curtain. Trolleys or rollers shall be attached to the vertical edge hem or metal reinforcement of the fire safety curtain. Uused to guide and restrain the fire safety curtain. Substantiation: A definition should not contain requirements. The requirements in chapter 20 include this Log #40 Final Action: Accept (3.4.8 Side Guide Cable System ) Recommendation: Deleted text Side Guide Cable System. A taut continuous vertical cable contained within the entire height of each vertical guide pocket. Spool guides shall be attached to the vertical edge hem or metal reinforcement of the fire safety curtain and slide up and down the side guide cable. U at each vertical edge us ed to guide and restrain the fire safety curtain. Substantiation: A definition should not contain requirements. The requirements in chapter 20 include this. The guide cable is not wholly contained in the vertical guide pocket so, besides being a requirement, this could be misleading Log #41 Final Action: Accept ( Vertical Guide Pocket ) Vertical Guide Pocket. A partial enclosure at the side vertical edge of the proscenium, which protects the vertical edges and guides of a fire safety curtain. Substantiation: Change side to vertical edge because commonly the side of the proscenium refers to audience versus stage side and add vertical so it is clear it is to protect the vertical edges and not the top and/or bottom nor all 4 edges Log #CC20 Final Action: Accept (3.5.10, ) Comment on Proposal No: Recommendation: Revise the definition of the term Volume Control Damper as follows: A fire damper, smoke damper, or combination fire/smoke damper that is also used to control the volume of air in an HVAC system. Substantiation: Editorial clarification Log #6 Final Action: Reject (4.4.1) Submitter: Kate D. Steel, O Keefe s, Inc. Comment on Proposal No: Recommendation: Add new text as follows: Only labeled fire-resistance-rated or fire protection-rated glazing material meeting applicable safety standards shall be used in fire door assemblies when permitted by the door listing. The label shall designate glazing as fire protection-rated by including the mark P-xx, or as fire resistance-rated by the mark R-xx, where xx represents the specific rating period. Substantiation: This supplements the TC s action addressing use of both types of rated glazing material in fire door assemblies. Because there is a great deal of confusion over the proper use of these distinct glazing materials in the field, the designations P for fire protection, and R for fire-resistance, will bring much needed attention to the difference, and help users identify the appropriate product use per section and new section Committee Statement: The committee does not believe that the proposed designation for labeling of glazing is helpful. The proposed language is in conflict with the marking designations for glazing described in NFPA 5000 (see ) and other model building codes. In addition, the committee understands that some manufacturers are using the new marking system as included in NFPA Log #CC6 Final Action: Accept in Principle (4.4.1 Exception) Comment on Proposal No: 80-4 Recommendation: Eliminate exception in accordance with the MOS. Substantiation: This Committee Comment was generated as a result of an editorial review of this document. The recommendation contains recommended editorial changes, that resulted from editing the ROP draft that require Committee review and action. Revise and add a new as indicated below. Renumber existing sections accordingly * Only labeled fire resistance rated or fire protection rated glazing material meeting applicable safety standards shall be used in fire door assemblies when permitted by the door listing. (See A Glazing Material.)

5 Exception: Where fire door assemblies are exempt from safety standards Where required, the glazing material shall also meet safety standards. Committee Statement: This action removes the exception in accordance with the Manual of Style and clarifies the committee s intent with regard to safety standards for glazing. Comment on Affirmative: HOLMES, W.: The committee documentation reflects the committee action on a motion at the NFPA 80 ROC meeting. The resultant Committee Comment is shown under the heading of Committee Meeting Action. The Final Action should be cited as Accept rather than Accept in Principle Log #CC18 Final Action: Accept ( and (New) ) Comment on Proposal No: Recommendation: 1 Delete sections , and as shown in the ROP draft in their entirety. 2. Add a new section to read as follows: The clearance under the bottom of a door shall be a maximum of ¾ inch (19mm). 3. Add a new section to read as follows: Where the bottom of the door is more than 38 inches above the finished floor, the maximum clearance shall not exceed 3/8-inch (9.5mm) or as specified by the manufacturer s label service procedure. Substantiation: During fire testing, variations in the gap underneath the door up to ¾ inch, have not been found to have a significant effect on the performance of the door when the gap is located beneath the neutral plane. The neutral plane is approximately 38 inches above the finished floor. Therefore, the committee believes that a maximum clearance of ¾-inch is appropriate for all doors where the gap is located below the neutral plane. Ballot Results: Affirmative: 25 Negative: 1 Explanation of Negative: HOLMES, W.: I would prefer to split my vote; voting in favor of the proposed change to and voting against the proposed new However, since this is a single ballot item, I am compelled to vote negative on Comment No It is reasonable and very appropriate to revise the maximum clearance under the bottom of the door to ¾ inch, regardless of the type of floor or floor finish. However, there is no basis for specifying a smaller and arbitrary maximum clearance of 3/8 inch when the bottom edge of the door is more than 38 inches above the finished floor as stated in the proposed new The reference to a 38-inch high neutral pressure plane in the committee substantiation has nothing to do with the position of a door in a wall and nothing to do with the expected height of the neutral pressure plane in a room fire. Not all fire doors are tested at positive pressure. Most doors are tested at a negative furnace pressure. NFPA 252 allows for fire doors to be tested with the neutral pressure plane in the furnace above the top of the door. When tested at a positive pressure, NFPA 252 allows for fire doors to be tested with the neutral pressure plane in the furnace that is not higher than 40 inches above the bottom of the door. The selection of the height of the furnace neutral pressure plane for testing was made somewhat arbitrarily. It exposes a portion of the door leaf, edges, and frame to a positive furnace pressure but leaves the latch and bottom portion of the door assembly at a negative (cooling) pressure. Positive pressure fire doors tests (when conducted) provide some differentiation of door performance to positive or negative fire pressure exposures but have no relationship to the performance of doors based on their position in the wall of a room or room fire positive pressure gradients. There is no evidence anywhere that would indicate that a room fire is likely to produce a neutral plane at 38 inches above the finished floor. The 38 inch specification proposed in is extremely arbitrary and totally without basis. The location of a neutral pressure plane from a fire in a room on a door installed in the field will be a function of the position of the door, the room geometry, the strength of the actual fire, and any ventilation and cooling affect. One cannot arbitrarily anticipate that a room fire neutral pressure plane will likely be in the inch range. Two illustrative examples: Example No. 1 A small room with a large fire load (perhaps a storage room or flammable liquids storage room). Room has a 12 foot high ceiling and a fire door is provided with the bottom of the door 70 inches above the finished floor. That puts the top of the door near the ceiling and the entire 80-5 door in the top half of the room. A fully-involved fire in this room will likely expose the entire door to a positive fire pressure. Example No. 2 A very large room with a very light fire load (perhaps an elementary school gymnasium). Room has a 30 foot high ceiling and a fire door is provided with the bottom of the door 40 inches above the finished floor. For nearly all credible fires in this room, the neutral pressure plane from the fire will be well above the door and the door will never be subjected to a positive fire pressure. In both examples, proposed would specify an arbitrary maximum bottom-of-the-door clearance of 3/8 inch based on an arbitrary 38 inch maximum bottom-of-the-door height. The substantiation offered is related to positive pressure effects yet one of these door installations will never be subjected to a positive pressure fire exposure. Proposed is not well thought out and is without basis. Further, Regulations Governing Committee Projects, Paragraph states that TC-generated comments shall not introduce a new concept that has not had public review. Comment was generated in response to Proposal This proposal dealt only with under-door clearances, irrespective of the position of the door in the wall. Comment introduces a new concept having to do with clearances related to door position and neutral pressure planes. This is a new concept, and potentially controversial concept, that has not had public review. This Comment cannot be processed under NFPA regulations as a new concept at this time. This comment should be defeated and the subject of door clearance be addressed as new topic in the next revision cycle of NFPA Log #76 Final Action: Accept (4.9.1) Submitter: Joshua W. Elvove, US Department of Veterans Affairs Comment on Proposal No: 80-1 Recommendation: Change the following misspelled word from clsing to closing. Substantiation: Typo. Ballot Results: Affirmative: 24 Negative: 2 Explanation of Negative: CONNER, W.: I agree with Mr. Holmes on this item without reservation. HOLMES, W.: There is no doubt in my mind that any misspelling of closing as clsing should be corrected. It is expected that this will be corrected as part of an editorial review by NFPA staff. However, this Comment is cited as being related to Proposal No The NFPA 80 ROP confirms that Proposal No relates to horizontal access doors in and not to The NFPA 80 ROP also confirms that there was no proposal submitted on Therefore, this Comment No is not in order and I must vote against its adoption Log #99 Final Action: Reject ( ) Submitter: Eddie Phillips, Southern Regional Fire Code Development Committee Comment on Proposal No: Recommendation: Reconsider the original proposal and accept. Revise to read: Door openings and the surrounding areas shall be kept clear of anything that could obstruct or interfere with the free operation of the door. An approved diagram shall be affixed to the door showing the operating space required for the free operation of the door. Substantiation: The floor marking requirement is needed as a tool to notify occupants of the area that needs to be kept clear for the proper operation of the door. This proposal will permit easier compliance as the AHJ could easily walk into the building and see if items are placed in the prohibited area. Committee Statement: The committee reaffirms it position that the recommendation is not practical or enforceable Log #CC7 Final Action: Accept in Principle ( ) Comment on Proposal No: 80-4 Recommendation: Move last part of sentence to Annex A. Substantiation: This Committee Comment was generated as a result of an editorial review of this document. The recommendation contains

6 recommended editorial changes, that resulted from editing the ROP draft that require Committee review and action. Final Action should be cited as Accept rather than Accept in Principle. Revise to read as follows: Log #CC25 ( and ) Final Action: Accept * Paint shall be prevented from accumulating on any movable part [such as, but not limited to, stay rolls, gears, and closing mechanisms.] A Movable parts of the door assembly can include but are not limited to stay rolls, gears and closing mechanisms. Committee Statement: Moves advisory language to the annex in accordance with the Manual of Style. Number Eligible to Vote: 28 Ballot Results: Affirmative: 27 Comment on Affirmative: HOLMES, W.: The committee documentation reflects the committee action on a motion at the NFPA 80 ROC meeting. The resultant Committee Comment is shown under the heading of Committee Meeting Action. The Final Action should be cited as Accept rather than Accept in Principle. Comment on Proposal No: Recommendation: Revise sections as follows: Hinges or pivots employing other antifriction bearing surfaces shall be permitted if they meet the requirements of ANSI A156.1, Standard for Butts and Hinges, and shall meet the requirements of ANSI/ BHMA A , Standard for Self Closing Hinges & Pivots, Grade Spring hinges shall be labeled, and shall meet the requirements of ANSI/BHMA A , Standard for Self Closing Hinges & Pivots, Grade 1. Substantiation: The reference standard was inadvertently placed in the wrong section during the preparation of the ROP Log #CC8 Final Action: Accept in Principle ( ) Comment on Proposal No: 80-4 Recommendation: Move example to Annex A. Substantiation: This Committee Comment was generated as a result of an editorial review of this document. The recommendation contains recommended editorial changes, that resulted from editing the ROP draft that require Committee review and action. Revise and add a new A as follows: * Proprietary-type slip-on door frames [e.g., those for use on prepared openings in drywall construction] shall be installed in accordance with the manufacturer s installation instructions. A An example of proprietary-type slip-on door frames are those for use on prepared openings in drywall construction. Committee Statement: Moves example to the annex in accordance with MOS. Comment on Affirmative: HOLMES, W.: The committee documentation reflects the committee action on a motion at the NFPA 80 ROC meeting. The resultant Committee Comment is shown under the heading of Committee Meeting Action. The Final Action should be cited as Accept rather than Accept in Principle Log #CC9 Final Action: Accept in Principle ( and ) Comment on Proposal No: Recommendation: Change wording to correct table reference. Substantiation: This Committee Comment was generated as a result of an editorial review of this document. The recommendation contains recommended editorial changes, that resulted from editing the ROP draft that require Committee review and action. 1. Revise to read as follows: Hinges. Hinges shall be as specified in individual door manufacturer s published listings or Table INSERT [Use table from the 1999 edition of NFPA 80. Do not include footnotes as they have already been incorporated into the text]. Table Builders Hardware Mortise, Surface, and Full Length Hinges, Pivots, or Spring Hinges for Swinging Doors 2. Revise as follows: Pivot sets made up of components that are smaller or of a lighter gauge than shown in this table shall be permitted to be used, provided... Committee Statement: Table was inadvertently deleted during the ROP stage. Comment on Affirmative: HOLMES, W.: The committee documentation reflects the committee action on a motion at the NFPA 80 ROC meeting. The resultant Committee Comment is shown under the heading of Committee Meeting Action. The Log #77 Final Action: Reject (12.3) Submitter: Joshua W. Elvove, US Department of Veterans Affairs Comment on Proposal No: 80-1 Recommendation: Revise the following text from 12.3: 12.3* Weather Protection. Where r Rolling steel, horizontally or vertically sliding fire shutters are installed on the exterior of a building, they shall be protected against the weather to ensure operation. Substantiation: By definition (see & ), (fire) shutters are (only) used to protect a window opening in an exterior wall. Therefore, some of the existing text is superfluous and should be deleted (i.e., shutters are always installed on the exterior of a building, so all shutters must be protected against weather). Committee Statement: Not all shutters are to installed on the exterior of a building. Some shutters could be installed on the interior side of an exterior wall Log #CC10 Final Action: Accept in Principle ( ) Comment on Proposal No: 80-4 Recommendation: Provide specific reference to in other sections. Substantiation: This Committee Comment was generated as a result of an editorial review of this document. The recommendation contains recommended editorial changes, that resulted from editing the ROP draft that require Committee review and action. 1. Delete without replacement. 2. Add a new A to read as follows: A Where fire door assemblies are installed in front of hoistway doors, the fire doors shall be installed in accordance with the appropriate chapter in this standard for the type of door being installed. Committee Statement: Clarifies committee s intent and complies with the Manual of Style. Number Eligible to Vote: 28 Ballot Results: Affirmative: 27 Comment on Affirmative: HOLMES, W.: The committee documentation reflects the committee action on a motion at the NFPA 80 ROC meeting. The resultant Committee Comment is shown under the heading of Committee Meeting Action. The Final Action should be cited as Accept rather than Accept in Principle Log #4 Final Action: Accept (14.1.3) Submitter: Edward A. Donoghue, Edward A. Donoghue Associates, Inc. Comment on Proposal No: Recommendation: Revise second paragraph to read: ASME A17.1, Safety Code for Elevators and Escalator, 2004 including Addenda ASME A17.1a-2005 and Supplement ASME A17.1S Substantiation: To reference current edition of standard.

7 Number Eligible to Vote: 28 Ballot Results: Affirmative: Log #CC11 Final Action: Accept in Principle (14.3.1) Comment on Proposal No: 80-4 Recommendation: Revise the word substantial, as it is an unenforceable term. Substantiation: This Committee Comment was generated as a result of an editorial review of this document. The recommendation contains recommended editorial changes, that resulted from editing the ROP draft that require Committee review and action. Revise section as follows: Muntins, trim, and vision panel protection shall be of noncombustible material and of substantial construction. Committee Statement: Removes unenforceable language in accordance with the Manual of Style. Number Eligible to Vote: 28 Ballot Results: Affirmative: 27 Comment on Affirmative: HOLMES, W.: The committee documentation reflects the committee action on a motion at the NFPA 80 ROC meeting. The resultant Committee Comment is shown under the heading of Committee Meeting Action. The Final Action should be cited as Accept rather than Accept in Principle. Explanation of Negative: HOLMES, W.: The Committee Comment was to revise the word adequate in The required action would have deleted and shall be adequate for the service at the end of the sentence so it reads Lentils shall be of noncombustible construction. Unfortunately, the way that the Committee Meeting Action and the Committee Statement are presented on the ballot, this does not get accomplished. The ballot item on Comment says to See Committee Comment (Log #CC16) makes several changes but it does not change the reference to adequate. Voting affirmative on Comment as it is presented will not accomplish the intent stated in I am submitting a negative vote Log #CC2 Final Action: Accept ( ) Comment on Proposal No: Recommendation: Revise section as Table which was deleted per ROP Substantiation: This Committee Comment was generated as a result of an editorial review of this document. The recommendation contains recommended editorial changes, that resulted from editing the ROP draft that require Committee review and action. No action necessary as Table was reinserted. See Committee Comment (Log #CC9) Log #CC16 Final Action: Accept (Chapter 15) Comment on Proposal No: 80-4 Recommendation: Revise Chapter 15 to read as follows: Chapter 15 Chute Doors 15.1 Doors Operation. Chute doors shall be of the swinging type that are hinged on the side or bottom for intake and on the side or top for discharge * Fire Protection Rating. Chute doors shall have a fire protection rating of 1 hour or 1 1/2 hours Supporting Construction Walls Door assemblies, where used on walls of other construction, shall be as listed installed in accordance with their listing No part of the assembly shall project into the chute Doors shall be self-closing or arranged for automatic closing operation as described in for swinging doors Sills. Chute door assemblies shall be installed on masonry sills and shall be securely fastened to the sill or the chute Lintels. The lintel shall be constructed of noncombustible materials and shall be adequate for the service Closing Device. Doors shall be self-closing or arranged for automatic closing operation as described in for swinging doors. Substantiation: This action removes ambiguous text and provides for better organization of the chapter. Number Eligible to Vote: 28 Ballot Results: Affirmative: Log #CC12 Final Action: Accept in Principle (15.2.3) Comment on Proposal No: 80-4 Recommendation: Revise the word adequate. Substantiation: This Committee Comment was generated as a result of an editorial review of this document. The recommendation contains recommended editorial changes, that resulted from editing the ROP draft that require Committee review and action. See Committee Comment (Log #CC16). Committee Statement: See Committee Comment (Log #CC16). Ballot Results: Affirmative: 25 Negative: Log #5 Final Action: Accept ( ) Submitter: Edward A. Donoghue, Edward A. Donoghue Associates, Inc. Comment on Proposal No: Recommendation: Revise to read: CSA B44-04, Safety Code for Elevators. Substantiation: To reference current edition of standard Log #8 Final Action: Reject ( ) Submitter: Kate D. Steel, O Keefe s, Inc. Comment on Proposal No: Recommendation: Add new text as follows: (New). Frames installed with fire-resistance rated glazing tested as an assembly in accordance with NFPA 251, Standard Method of Tests of Fire Endurance of Building Construction and Materials, shall be permitted where a fire-protection-rating exceeding 3/4-hours is required. Substantiation: The deletion of former Table creates confusion over the limits on fire windows in openings requiring in excess of a 45- minute fire-protection-rating. This provision parallels the TC s action creating a new addressing the same limits on fire-protection rated glazing in fire door assemblies, and clarifying that glazing in opening protective assemblies requiring a 1-hour or higher rating is permitted when tested to NFPA 251. This addresses current confusion that exists as a result of listings that have been issued for fire-protection-rated glazing products tested in window frames to NFPA 257 for a fire endurance rating period exceeding 3/4-hours, which are not permitted under codes. Committee Statement: The committee does not believe that the proposed text is within the scope of the standard, and further notes that the proposed text does not provide for any clarification. 80-7

8 and fire-protection-rated glazing, and the permitted use of fire-resistance Log #7 Final Action: Reject rated assemblies tested to NFPA 251. This action is consistent with the (17.2.1) TC s action in creating a parallel provision addressing the use of fireresistance Submitter: Kate D. Steel, O Keefe s, Inc. Comment on Proposal No: Recommendation: Add new text as follows: Labeled. Glazing material in fire windows shall be fire protection-rated, or fire-resistance-rated and shall be labeled. The label shall designate glazing as fire protection-rated by including the mark Pxx, or as fire resistance-rated by the mark R-xx, where xx represents rated glazing in sidelight and transom assemblies in openings requiring in excess of 3/4-hour rating. Committee Statement: The committee believes that the proposed text is too limiting and that it is not necessary. the specific rating period. Substantiation: This supplements the TC s action addressing use of both types of rated glazing material in fire windows. Because there is a great deal of confusion over the proper use of these distinct glazing materials in the field, the designations P for fire protection, and R for fire-resistance, will bring much needed attention to the difference. The designations will help users identify the appropriate product use under codes limiting fire windows tested to NFPA 257 to openings requiring a 45-minute or less fire protection rating. Committee Statement: See committee action and statement on Comment (Log #6) Log #9 Final Action: Reject (Table ) Submitter: Kate D. Steel, O Keefe s, Inc. Comment on Proposal No: Recommendation: Revise Table as follows: Fire Window Rating (hr) Table Maximum Area of Glazing Material per light 1/2, 1/3 Limited to maximum area tested. 3/4 Maximum area of individual exposed lights shall be 1296 in. 2 (0.84 m 2 ) with no dimension exceeding 54 in. (1.37 m) unless otherwise tested. 1, 1-1/2 or 3 Not permitted a New footnote: a Except as provided in Section Substantiation: This is an alternative to the TC s action deleting former Table It also clarifies the distinction between fire-resistance rated and fire-protection-rated glazing, and the permitted use of fire-resistance rated assemblies tested to NFPA 251. This action is consistent with the TC s action in creating a parallel provision addressing the use of fireresistance rated glazing in sidelight and transom assemblies in openings requiring in excess of 3/4-hour rating. Committee Statement: The proposed language would impose a restriction that is not intended by the committee. A 60-minute fire protection rated glazing product exists Log #10 Final Action: Reject ( (New) ) Submitter: Kate D. Steel, O Keefe s, Inc. Comment on Proposal No: Recommendation: Add new text as follows: (New) Rating Glazing tested and fire-protection-rated in accordance with NFPA 257, Standard on Fire Test for Window and Glass Block Assemblies, installed in interior fire windows, shall be permitted where a 3/4-hour fire protection rating or less is required Glazing tested as an assembly and fire-resistance rated in accordance with NFPA 251, Standard Method of Tests of Fire Endurance of Building Construction and Materials, shall not be subject to the limits of Section when labeled as a fire-resistance rated assembly. Substantiation: This is an alternative to the TC s action deleting former Table It also clarifies the distinction between fire-resistance rated Log #CC21 Final Action: Accept ( , A (New) ) Comment on Proposal No: Recommendation: 1. Revise section as follows: * The fusible link operating temperature shall be in accordance with NFPA 90A and UL 33 temperature classifications and ratings. for UL Category JGIX. 2. Add new annex text as follows: A Fusible links are marked with temperature ratings. The common temperature ratings of fusible links are as follows: Temp Classification Maximum Ambient Temperature (deg F) Temperature Rating, (deg F) Low Ordinary Intermediate High Extra High Very Extra High Ultra High Substantiation: Provides for more accurate information regarding the temperature rating of fusible links associated with dampers Log #92 Final Action: Accept in Principle (Chapter 20) Submitter: William Conner, Bill Conner Associates LLC Recommendation: The American Society of Theatre Consultants has reviewed and supports the 33 comments submitted on this proposal by ESTA. Substantiation: These are needed and good comments. No action necessary. See committee action and statements to comments on Chapter 20. Committee Statement: No action necessary. See committee action and statements to comments on Chapter Log #95 Final Action: Reject (Chapter 20) Submitter: William Conner, Bill Conner Associates LLC Comment on Proposal No: as result of deleting all materials and fabrication not a part of the installation, testing, and maintenance with struck out and underlined text: 3.4 Fire Safety Curtains Definitions Batten. A horizontal pipe, tube, or other structural shape in a pocket of or attached to a fire safety curtain Bottom Seal (Yield Pad). Bumper. A filled fabric pocket below the bottom batten or frame member of a fire safety curtain designed to press against the floor Fire Safety Curtain. A curtain of fire-resistant fabric and noncombustible framing materials Brail Fire Safety Curtain. A fire safety curtain that folds up and stores in the space above a proscenium opening.