Maintaining Fire-Resistance Protection In Multi-Family And Other Occupancies
By Bill McHugh
For some reason, fire-resistance-rated assemblies and their components have been forgotten in existing buildings. Maybe it’s that some believe sprinklers will stop the fire. Maybe they believe fire won’t happen in their building. Maybe they just don’t know how important fire-resistance-rated assemblies are?
We hope it’s the latter.
That’s what this article is about. Maintaining protection using fire-resistance-rated assemblies in existing buildings, including multi-family structures.
Fire Test Standards
Multi-family structures, like other occupancies, can be built with wood, steel and concrete, or concrete as the base fire-resistance element that is protected. For concrete to provide a fire-resistance-rating, it maintains a certain thickness of concrete, with a specific aggregate required. Sometimes, Sprayed Fire-Resistant Materials, Intumescent Fire-Resistant Materials, Boards and Wraps or Concrete Masonry can provide protection. Wood is usually protected with Type X or Type C gypsum panels. These 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.
These two tests were developed to provide a comparison between products used as specified, when subjected to the same furnace fire test. There are those that state, ‘furnace testing is not realistic’. What they fail to realize is that furnace testing is used to simulate a building fire – and yes, it is used to compare products exposed to fire in laboratory conditions.
Also, the ASTM E119 and UL 263 fire tests were developed over 100 years ago – and provide proof that the material used on the structure will keep the listed assembly or building element under the temperature that causes lost structural strength – and the resultant sagging, expansion, and possible breaking of connections between columns and beams, that support a building.
The inference is that by keeping the structural member from reaching temperatures that cause structural loading loss, the building will stay standing under fire conditions. Fire testing provides proof the temperatures remain below the softening point of the structural element or assembly.
The picture below shows a ASTM E119/UL 263 Fire Test evaluating a horizontal assembly. The size of the furnace is critical. A small scale furnace will not deflect under loading. The full scale, (approx. 10’ x 18’) furnace, with a load applied via the ‘rams’ shown in the picture, represents real world conditions, and is a required part of ASTM E119. Without a load, fireproofing could pass an hourly test, but fail under real world conditions.
Why do we bring this up? Some testing laboratories will perform fire testing without a load, and small scale, just to pass the test. It’s up to the marketplace to ask the question to see if the materials have been tested in assemblies that comply with code and standards requirements.
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.
The manufacturers of these products invest in product development, and the fire-testing to prove the products will perform when exposed to fire or smoke or both.
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,
220.127.116.11 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 18.104.22.168]
And, 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 are very broad statements. Improperly installed means improperly installed, all the way back to the original construction. And, just because the building received a certificate of occupancy, doesn’t mean the building owner and manager is off the hook should there be loss of life, property, or continuity of tenant operations. NFPA 1 states the building owner is responsible for required fire-resistive construction at new, and existing buildings, and nobody else.
Fire-Resistance has been stated, ‘easy’ by many manufacturer’s literature pieces. Certain materials are easier to install than others, but the listings for fire resistance are all complex, with strict tolerance rules, not normal in the construction industry culture. The listings and manufacturers’ installation instructions are complex – especially to those who don’t know fire resistance. That’s why in another sentence in NFPA 1, there is language about the person that reviews the fire resistance-rated assemblies.
22.214.171.124.1 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, 126.96.36.199.1]
NFPA 1 also states the frequency of visual inspection for fire-resistance in High Rise Buildings is required once every 3 years.
What Does NFPA 101 Say?
188.8.131.52 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, 184.108.40.206]
NFPA 101 states no frequency, but just requires that the building owner continuously maintain protection of the fire-resistance-rated assemblies. Wow, 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 that records of inspections and repairs need to be built or inventoried and maintained. This means the Authority Having Jurisdiction (AHJ) can, at anytime, ask for the fire resistance-rated and smoke-resistant inventory and annual visual inspection records. 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 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 fire-resistance-rated walls and horizontal assemblies – Penetrations, Joints and Voids, Door and Window Openings, Duct and Air Transfer Openings, Concealed Spaces – protection has to be maintained. There even is a separate section that addresses structural fire-resistance through 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]
The United Arab Emirates Fire and Life Safety Code of Practice, has similar language to the current version of 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 specialist firestop contractor or 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]
NOTE: that this Saudi Arabian Fire Code language looks amazingly like NFPA 101.
In the National Fire Code of Canada – a performance based code – it expects fire separations – fire-resistance rated walls, floors, roofs tested in accordance with CAN/ ULC-S101, Fire Endurance Tests of Building Construction and Materials – to perform, period.
220.127.116.11 –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 Owners And Manager To Do?
To our FCIA AHJ and Building Owner and Manager friends, how can your firm comply?
It’s clear, fire-resistance-rated and construction that resists the passage of smoke clearly needs 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 have taken place. In other words, the protection needs to be maintained.
One might think, ‘because 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, who cares?’
Building owners (and managers) should think of these codes and standards as a big stick. They are references that can be used in legal proceedings, should there be loss of life or property due to not following fire code requirements for fire-resistance-rated and smoke-resistant building elements assemblies. These documents might be stated as precedents, published standards, adopted by jurisdictions, which should guide the building owner and managers’ policies for maintaining existing buildings. Why didn’t fire-resistance protection get maintained? These codes and standards have existed for decades.
This begs the question, “where do you want to be should a loss of life occur? On the witness stand or in row 2 of the courtroom watching all this unfold in court or somewhere else?” That’s how a university facility director attendee at a FCIA Education Program on Barrier Management Systems put it to me personally. And, wow, does this make sense.
Building Owner & Manager Action Items
There are some key steps the building owner and manager needs consider to comply with the various fire codes and standards to maintain protection of fireresistance-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, showing which walls and floors are rated – fire, smoke, sound, etc.
• Tested and Listed Systems (Listings), if not incorporated in the …. Manufacturers’ 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’, survey
Assign a Champion – A fire-resistance/smoke resistant champion – to manage, and be responsible that inspections, repairs and recordkeeping take place on a timely basis.
– Educate the inspection and repair staff.
• FREE FCIA Barrier Management Symposium online is a start. Check it out at www.FCIA.org
• Education webinars at FCIA, NFCA, Door groups, Gypsum Association, AMCA, DASMA, AWCI, Damper Manufacturers, UL and 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 also for Fire Marshal / AHJ Inspection.
These records could be a benefit to use in other buildings that don’t have a process such as this for fire and life safety, property protection and continuity of building operations through maintaining protection provided by reducing fire spread with effective compartmentation. – 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. They are not meant to be the ASTM E2174 and ASTM E2393 Firestop Inspections, but instead, a ‘Survey’ for visual inspection. The assembly seems to comply or seems not to comply.
This visual inspection sounds simple, but isn’t 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. And, the tested and listed systems are complicated for the untrained, uneducated eyes. Check out the UL Product iQ to learn more about the systems. These systems, the ‘inventory’ are the basis from which to compare visually whether or not the assembly – fire door, firestopping, fire rated glazing, fire dampers, etc., – seem to visually comply or visually not comply with the listing.
Then, what about repairs? Can’t we just invent something? No, fire-dampers have to be repaired in accordance with their listing – which is incorporated in the manufacturer’s installation instructions provided with each box that packages the fire, smoke or other fire damper.
What about fire-rated glazing? Can I just fix the frame hole with a putty of some kind? Not unless that putty was specified and listed as a frame patch in the listing. 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 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 fi re-test laboratories available for this repair. Again, the listing and manufacturers’ 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 it’s not made anymore. Then, repair is with the same type of material. More on that in previous articles from Fall, 2018 of Life Safety Digest.
Can we patch firestopping with any red firestop sealant? Nope, only the firestop sealant that is in the tested and listed system can be used to maintain firestop protection. Again, get with the 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 track the maintenance of these barriers, walls, assemblies and protective materials, systems and devices. Many of them service all aspects of the fi re-resistance-rated and smoke-resistant assembly.
Whichever method is chosen, a management system needs to be in place at the building to assure that the fire resistance-rated and smoke-resistant building elements and assemblies work when called upon by fire. People, 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. We depend on it.
McHugh is Executive Director of the Firestop Contractors international Association (FCIA). He assembles and moderates at the FCIA/UL/ASHE/TJC Barrier Management Symposium. He also is involved in fire resistance at The International Code Council’s Building and Fire Code Development Processes serving twice on the ICC Fire Safety Committee, ASTM E2174/E2393 Firestop Inspection Standards, UL’s UL 263/ULC S101 Standards Technical Panels, and NFPA Fire Protection Features Committee. He can be reached at bill@FCIA.org.
This article was originally published in Life Safety Digest, Winter 2021.