On July 28, 2017, the Centers for Medicare & Medicaid Services issued a memorandum on required annual inspection of swinging fire door in healthcare occupancies (Click Here for the full memo). The memo extends the deadline for compliance with the annual fire door inspections for swinging fire doors from July 5, 2017 to January 1, 2018.
The extension is being granted due to conflicting information that was issued regarding the code path and subsequent nature of the door inspections that were required to be performed. The memo clarified that Section 18.104.22.168.1 of NFPA 101 2012 Edition would not apply to healthcare occupancies. This does not mean that these occupancies are not subject to the annual testing requirements of NFPA 80 but rather that they are not subject to the additional requirements layered on top of the NFPA 80 requirements contained in Section 22.214.171.124.1. In addition to swinging fire doors, 126.96.36.199.1 also applied to doors with panic hardware, electronically controlled egress locks, and doors with special locking arrangements such as delayed egress locks and access control locking system. Nonrated doors that contain such devices are not required by NFPA 101 or NFPA 80 to be inspected annually.
Hospitals are still subject to the annual inspection of swinging fire doors from NFPA 80 via Section 8.3.3 of NFPA 101 2012 Edition.
Previously Joint Commission and CMS had issued notices that 188.8.131.52.1 was applicable to Healthcare Occupancies. Due to the confusion created by this clarification, CMS has extended the deadline for compliance.
If you need assistance creating an inventory of fire doors or performing NFPA 80 testing please do not hesitate to contact us. Unlike many fire door inspectors, our work as code consultants and fire protection engineers gives us the expertise to examine your life safety drawings and understand the necessity for walls and doors to be rated by NFPA 101 and the applicable building codes.