To some degree, existing fire-resistance-rated assemblies and their components have been forgotten. That’s what this article is about: maintaining protection using fire-resistance-rated assemblies in existing buildings.
Fire test standards for protection
Structures can be built with wood, steel and concrete, or concrete as the base fire-resistance element or assembly. For a concrete assembly to provide a fire-resistance-rating, it maintains a certain thickness of concrete with a specific aggregate required. Sometimes, Sprayed Fire-Resistive Materials (SFRMs), Intumescent Fire-Resistive Materials (IFRMs), Boards and Wraps, Concrete alone, or Masonry gypsum panel assemblies can provide the fire-resistance protection. Wood assemblies might be protected with Type X or Type C gypsum panels.
The assemblies and building elements are fire tested in accordance with ASTM E119, Standard Test Methods for Fire Tests of Building Construction and Materials, or UL 263, Standard for Safety of Fire Tests of Building Construction Materials.
The ASTM E119 and UL 263 fire tests were developed to provide proof that the material used on the structure will keep the assembly or building element under acceptance criteria temperatures from ASTM E119 or UL 263 standards.Exceeding temperature thresholds causes loss of structural strength and the resultant sagging, expansion, and possible breaking of beam/column connections supporting a building. The fire testing becomes the determining factor for suitability for use of the products in specific fire-resistance applications – and provides a comparison basis for different fire-resistance assemblies.
The picture below shows an ASTM E119/UL 263 full scale Fire Test apparatus that evaluates a horizontal assembly, where size is critical. A small-scale furnace will not deflect under loading. The full-scale furnace, approximately 10’ x 18’, with a load applied via the ‘rams’ shown represents more real-world conditions. Without a load, fireproofing could pass an hourly fire test, but could fail under real-world conditions.
Why do we bring this up? It’s important to ask the question to see if the materials have been tested in assemblies that comply with code and standards requirements – and provide safety in the real world.
The ASTM E 119 and UL 263 test standards are also the basis for those items that protect breaches in the fire-resistance-rated assembly – Fire Dampers, Fire Doors, Firestopping, and Fire-Rated Glazing.
Why talk about installation in an article about maintaining protection/maintenance?
It’s because NFPA 1, The Fire Code puts responsibility on the Building Owner to assure that the products were installed correctly in the first place.
From 2018 NFPA 1, The Fire Code:
126.96.36.199 Required fire-resistive construction, including fire barriers, fire walls, exterior walls due to location on property, fire-resistive requirements based on type of construction, draftstop partitions, and roof coverings, shall be maintained and shall be properly repaired, restored, or replaced where damaged, altered, breached, penetrated, removed, or improperly installed. [2018 NFPA 188.8.131.52]
Additionally, NFPA 1’s General section in Chapter 12 states, “This Chapter shall apply to new, existing, permanent or temporary buildings”. This, and the “improperly installed” statement in 184.108.40.206 are very broad statements. Improperly installed means “improperly installed” all the way back to the original construction.
Fire-Resistance of any type – walls, floors, doors, fire dampers, firestopping – has been marketed as being ‘easy’. Certain materials are easier to install than others, but the listings for fire-resistance are all complex with strict tolerance rules.
The listings and manufacturer’s installation instructions are complex – especially to those who don’t know fire-resistance. That’s why in another sentence in NFPA 1, the person that reviews the fire-resistance-rated assemblies shall:
220.127.116.11.1 The person responsible for conducting the visual inspection shall demonstrate appropriate technical knowledge and experience in fire-resistance-rated design and construction acceptable to the AHJ. [2018 NFPA 1, 18.104.22.168.1]
NFPA 1 also states the frequency of visual inspection for fire-resistance in High-Rise Buildings is required once every 3 years.
What does NPFA 101 say?
22.214.171.124 Whenever or wherever any device, equipment, system, condition, arrangement, level of protection, fire resistive construction, or any other feature is required for compliance with the provisions of this Code, such device, equipment, system, condition, arrangement, level of protection, fire resistive construction, or other feature shall thereafter be continuously maintained. Maintenance shall be provided in accordance with applicable NFPA requirements or requirements developed as part of a performance-based design, or as directed by the authority having jurisdiction. [2018 NFPA 101, 126.96.36.199]
Although NFPA 101 does not designate a period of frequency, it does require that the Building Owner continuously maintain protection of the fire-resistance-rated assemblies. Continuously maintained. That’s strong language, very performance-based, similar to the National Fire Code of Canada.
Then, the International Fire Code, states:
701.1 Scope. The provisions of this chapter shall govern the inspection and maintenance of the materials, systems and assemblies used for structural fire-resistance, fire-resistance rated construction separation of adjacent spaces and construction installed to resist the passage of smoke to safeguard against the spread of fire and smoke within a building and the spread of fire to or from buildings. New buildings shall comply with the International Building Code [2021 IFC, 701.1]
The charging language in the code also has some directions for the Building Owner – clearly stating that there be an inventory and records kept:
701.6 Owner’s responsibility. The owner shall maintain an inventory of all required fire-resistance-rated construction, construction installed to resist the passage of smoke and the construction included in Sections 703 through 707 and Sections 602.4.1 and 602.4.2 of the International Building Code. Such construction shall be visually inspected by the owner annually and properly repaired, restored or replaced where damaged, altered, breached or penetrated. Records of inspections and repairs shall be maintained. Where concealed, such elements shall not be required to be visually inspected by the owner unless the concealed space is accessible by the removal or movement of a panel, access door, ceiling tile or similar movable entry to the space. [2021 IFC, 701.6]
Note that the IFC requires records of inspections and repairs be maintained. This means the Authority Having Jurisdiction (AHJ) can, at any time, ask for the fire-resistance-rated and smoke-resistive inventory and annual visual inspection records for a building where the requirements apply. If NFPA 1 or 101 is used in the jurisdiction, the AHJ might also ask, “How does the Building Owner and Manager make sure the individual providing the visual inspection is competent?”
Fire-Resistance Sections in IFC
The International Fire Code (IFC) also takes fire-resistance and breaks it into sections by assembly and protection discipline. For assemblies, Exterior Walls, Fire Walls, Fire Barriers and Fire Partitions, Smoke Barriers and Smoke Partitions, Horizontal Assemblies, and Shaft Enclosures are mentioned.
For breaches in these assemblies – Penetrations, Joints and Voids, Door and Window Openings, Duct and Air Transfer Openings, Concealed Spaces – protection must be maintained. There is even a separate section that addresses structural fire-resistance, Spray Fire-Resistive Materials, and Intumescent Fire-Resistive Materials. In other words, there is a specific section for each of the fire-resistance disciplines.
Just before the ‘Owner’s Responsibility’ section, it states that “materials, systems and devices used to repair or protect breaches and openings in fire-resistance-rated construction and construction installed to resist the passage of smoke…shall be maintained….”
From the International Property Maintenance Code:
703.3 Maintenance. The required fire-resistance rating of fire-resistance-rated construction, including walls, firestops, shaft enclosures, partitions, smoke barriers, floors, fire-resistive coatings and sprayed fire-resistant materials applied to structural members and joint systems, shall be maintained. Such elements shall be visually inspected annually by the owner and repaired, restored or replace where damaged, altered, breached or penetrated. Records of inspections and repairs shall be maintained. [IPMC 2018, 703]
From the United Arab Emirates Fire and Life Safety Code of Practice, similar language to the IFC:
3.7.2. The condition of installed firestop systems shall be visually inspected by the owner or owner’s representative annually. Damaged, altered or breached firestop systems shall be properly repaired, restored or replaced to comply with applicable codes as per the guidelines of Civil Defense. [UAE Fire and Life Safety Code of Practice]
NOTE: The owner might have fire-resistance educated staff provide the inspection or hire a Specialty Firestop Installation Contractor or Special Inspection Agency to perform the annual visual inspection as the ‘owners representative’.
In Saudi Arabia, Section 107.1, Maintenance states:
107.1 Maintenance Safeguards. Where any device, equipment, system, condition, arrangement, level of protection, or any other feature is required for compliance with the provisions of this code, or otherwise installed, such device, equipment, system, condition, arrangement, level of protection, or other feature shall be continuously maintained in accordance with this code and applicable referenced standards. [Saudi Arabia Fire Code]
In the National Fire Code of Canada – a performance-based code – it expects fire separations – fire-resistance-rated walls, floors, and roofs tested in accordance with CAN/ULC-S101, Fire Endurance Tests of Building Construction and Materials – to perform. Period.
188.8.131.52 –Damage to Fire Separations–Where fire separations are damaged so as to affect their integrity, they shall be repaired so that the integrity of the fire separation is maintained…
What’s a Building Owner and Manager to do?
AHJ and Building Owner and Managers, what does compliance look like? It’s clear, fire-resistance-rated and smoke-resistive assemblies clearly need to have protection maintained. In some cases, products need routine maintenance. Where products don’t require maintenance, the tested and listed system will need to be visually inspected to be sure alterations that would violate the listing haven’t taken place. In other words, the protection needs to be maintained.
One might think, “NFPA 1, the International Fire Code, National Fire Code of Canada, UAE Life Safety Code of Practice, Saudi Arabian Fire Code are not in my jurisdiction, so who cares?”
Building Owners (and Managers) should think of these codes and standards as references that can be used in legal proceedings should there be loss of life or property and fire spread through assemblies or if structural collapse occurred. These documents published standards, adopted by jurisdictions. They should guide the Building Owner’s maintenance policies.
Building Owner & Manager Action Items
There are some key steps the Building Owner and Manager needs to consider to comply with the various Fire Codes and Standards to maintain protection of fire-resistance-rated and smoke-resistant assemblies in buildings. Here’s a step-by-step recommendation:
- Build a Fire-Resistance and Smoke-Resistant Assembly Inventory – It’s hard to manage anything that is not ‘inventoried’ or known. What should be part of this inventory? Here are some possible items that make up a fire-resistance inventory:
- Life Safety Drawings, or other plans, showing which walls and floors are rated – fire, smoke, sound, etc.
- Tested and Listed Systems (Listings) if not incorporated in the Manufacturer’s Installation Instructions.
- Manufacturer’s Installation, Maintenance, and Repair Instructions
- Manufacturer’s Product Data Sheets
- Manufacturer Safety Data Sheets, where applicable.
- Build an action-oriented schedule for ‘visual inspection’ and survey.
- Assign a Champion – A fire-resistance/smoke-resistant champion to manage and be responsible for ensuring that inspections, repairs, and recordkeeping take place on a timely basis.
- Educate the inspection and repair staff
- The FREE FCIA Barrier Management Symposium online is a start. Check it out at www.FCIA.org.
- Educational webinars at FCIA, NFCA, Door groups, Gypsum Association, AMCA, DASMA, AWCI, Damper Manufacturers UL, Intertek, and Fire-Rated Glazing Manufacturers who participate at FCIA’s Barrier Management Symposiums
- Maintain continuous protection through visual inspections and repairs to the fire-resistance-rated and smoke-resistant assemblies.
- Keep easily retrievable Inventory & Inspection / Repair Records for Building Owner and Manager value and for Fire Marshal / AHJ Inspection.
- Repeat the process for the life of the building
Throughout the Codes and Standards, ‘inspections’ are referenced. These seem to be described as visual inspections, rather than destructive testing of various assemblies, a survey. The assembly seems to comply or seems not to comply.
This visual inspection sounds simple, but it is not, once the details are known. Why? Not all construction industry personnel or Building Owner Facility Engineering staff understand what a fire-resistance-rated or smoke-resistant assembly is, nor what can happen if it’s altered, breached, or penetrated.
Check out the UL Product iQ to learn more about the systems. These systems, a part of the ‘inventory’, are the basis from which to visibly compare if the assembly – fire door, firestopping, fire-rated glazing, fire dampers, etc., – seem to visually comply or visually not comply.
What about fire damper repairs? Can’t we just invent something? No, fire dampers must be repaired in accordance with their listing, which is incorporated in the Manufacturer’s installation.
What about fire-rated glazing? Can I just fix the frame hole with a putty of some kind? Simply put, contact the manufacturer of the frame for repair instructions.
How about the gypsum wallboard holes? Can I just scab patch these with the simple patch method? Nope, the furnace pressures might push the patch held by wallboard compound and paper out of the wall, and the hose stream test will blow the patch right through the assembly.
What about extending the door bottom with metal plates? There are metal extenders that have been tested at fire test laboratories available for this repair. Again, the listing and Manufacturer’s instructions are needed for this.
How about just patching fireproofing – Intumescent Fire Resistive Materials or Spray Fire Resistive Materials, Boards/Wraps – with whatever we can find that looks like the stuff on the beams, columns, or assemblies? Nope, the materials in the tested and listed system need to be used to maintain the integrity of the tested and listed structural building element or assembly until they are no longer made. (Read more at Life Safety Digest Fall 2018.)
Can we patch firestopping with any red firestop sealant? No, only the firestop sealant that is in the tested and listed system can be used to maintain firestop protection. Again, get with the Specialty Firestop Installation Contractor who will provide the Manufacturer recommended repair for the firestop product referenced in the firestop system.
Barrier/Separation Management Systems
FCIA Firestop Contractor members (and others) have invested in software that helps the Building Owner or Manager track the maintenance of these barriers, walls, assemblies and protective materials, systems, and devices. Many of these companies service all aspects of the fire-resistance-rated and smoke-resistant assemblies.
Whichever method is chosen, a management system needs to be in place at the building to assure the fire-resistance-rated and smoke-resistive building elements and assemblies work when called upon by fire. People and continuity of their operations/life in their homes and properties count on it working just as well as the fire suppression system, the fire detection and alarm system, and any other feature in the building. It’s all expected to work. Our lives depend on it.