Fire Door Tags: Why is it a problem?
- Jan 31
- 6 min read
Updated: Feb 2
A common problem building owners are facing currently is defective, damaged or non-compliant fire doors in existing buildings. While basic adjustments or repairs to fire doors are possible, in some relatively simple situations the default answer from most professionals has been "replace the door," resulting in unplanned costs of thousands (sometimes hundreds of thousands) of dollars for building owners. Is this the best approach?
As this is a complex issue with different topics to consider, this is the first of 3 posts:
Are Fire doors really that important?
Fire doors are needed because they are a critical life-safety measure in buildings. Their main purpose is to contain fire and smoke, allowing people time to escape and also helping to limit damage to the building. A defective fire door has the potential to permit large quantities of smoke or even fire to enter critical escape routes.
Fire door tags: Why are they a problem?
The first point of identification of a Fire door is that it is 'tagged' or fitted with a badge/name plate, and there is a bit of history here.
Our building code dates back to 1992, but as for the tags, they were only introduced in 1988 with NZS 4232 & NZSS 1188. This requirement was later solidified in AS/NZS 1905.14:1997, which was then superseded by NZS 4520:2010.
Both Standards (NZS4 4520 & AS/NZS 1905) establish that the attachment of a tag is evidence of compliance with the Standard. That's why every inspector is so fussy when a door is missing a tag.
Note: Clause 6.2 of NZS4520:2010 states that if, for any reason, the doorset is not compliant, the reference to NZS4520 on the label shall be crossed out. For the tag to be issued, the installer must provide the manufacturer with all supporting documents regarding the reason for non-compliance when returning the installer's declaration.
Another crucial change between these two Standards is that the previous standard (AS/NZS 1905) required that all fire doors were supplied with the tag on the leaf, with the frame tag missing. After the documentation was completed, the installer would provide the information and the installer's declaration form to the manufacturer, who would then issue the remaining tags for the installer to attach to the correct fire door frame.
Under the current Standard (NZ 4520), the door frame AND leaf are not supplied with a tag. After installation is complete and the installer's declaration form is sent to the manufacturer, the manufacturer will issue BOTH tags for the installer to attach to the fire doors. While this appears to be a reasonable practice, in reality, it also brings its own problems.
For large projects with multiple doors, the installer (and often the project manager who did not install the door) receives MULTIPLE door tags from the manufacturer, in some cases, for hundreds of doors. For projects where the FRR varies between doors (30-minute, 60-minute or even no FRR), the person applying the tags may apply them without proper consideration of which specific door each tag belongs to. As a result, the project may end up with tagged non-fire-rated doors, fire doors with no tags or 30-minute fire doors with 60-minute tags and vice versa.
A common practice among fire door manufacturers is that each fire door has a serial number on the top, and that the person attaching the tag should verify that number before attaching the tag. However, it is also common for an inexperienced builder installing the door to "shave" or plane the top of the door to make height adjustments, losing this tracking number.
So, in summary, we have the following tag issues commonly found in buildings (by age):
Up to 1988: No door tags
From 1988-1997: May or may not have door tags
1997-2010 - May have a door tag on the door leaf, but not on the door frame.
From 2010, door tags may have been mismatched throughout the project, leaving fire doors with no tags or with the incorrect tag.
Under current standards, all these examples are deemed noncompliant, which does not necessarily mean the building is less safe than intended.
How to obtain a door tag for an existing fire door?
As explained above, before issuing a fire door tag, the manufacturer requires the installer's declaration form to be filled out. They usually accept this form to be completed by installers or a qualified inspector, such as a Chartered Fire Engineer, who will certify that the door was installed in accordance with the manufacturer's requirements. For this, the following steps must be followed:
Identifying the Fire doors and collecting manufacturer requirements.
A list of approved hardware and possible installation methods is provided for each door model. For this reason, the first step is usually to identify the fire door by its serial number (could be a number handwritten on the top of the door leaf) and ask the manufacturer to identify the door model based on this number.
Note that this entire process is only possible if the manufacturer is known and is still in business.
Site Inspection and destructive testing (if required)
With the door information at hand, an inspection of the door is performed to determine whether the assembly method was followed as per the manufacturer's recommendations, identify any non-compliances on the fire doors (if any) and determine the recommended remedial works.
This includes checking gap seals, mineral wool requirements, solid timber, distance between screws/nails, etc...
Note: Given a lack of photographic evidence during construction, this may involve some destructive testing (especially around architraves and, maybe, door jambs). This will then require repair by a specialist passive fire subcontractor (and also possibly a carpenter).
Fire Door Inspection report issue
An inspection report is generated with the findings, including recommendations for any required remediation (i.e. door is damaged/missing parts, etc) or door replacement.
Remedying non-conformances
The recommended list of remedial works may or may not require a Building Consent. For example, maintenance work is usually exempt, but a fire door replacement would require a building consent (or a discretionary exemption).
This remedial/installation work must be performed by a qualified builder or passive fire contractor, and properly documented to demonstrate that the manufacturer's guidelines were followed.
Requesting door tags from the Manufacturer
Once all remedial work is completed and proper documentation is provided by the contractor, the installer's declaration form is issued with a letter explaining the inspection of the doors, specification of the hardware installed and any other relevant information. The manufacturer may then issue the fire door tags.
Manufacturer's register, another Fire Door identification problem:
While the process above is recommended, it is also true that some fire door manufacturers cannot be identified, or are no longer in business and do not even provide the required support, claiming no longer having access to the register of that specific door and not being able to confirm the door was indeed supplied by them.
Finally, the lack of door tags is not the only issue in existing fire doors. In fact, while this is the most common, when a fire door that meets the design safety requirements is properly installed, the lack of a tag will not compromise the building's safety, but compromises its compliance.
One important point to consider is that passive fire installations for service penetrations through a fire separation are subject to a series of strict requirements. These typically include the installer providing full evidence of compliance, marked-up as-built drawings, and comprehensive photographic records (including the labels). All of this information is then retained on the property file after the work is completed.
By comparison, fire doors represent significantly larger penetrations through fire-rated walls. They are also subject to daily use and mechanical wear, which creates a much higher likelihood of failure over time.
Given this, it is difficult to understand why fire door register requirements are generally limited to a written declaration only, without the need for supporting evidence such as as-built documentation or photographic records to demonstrate compliance and get a tag issued.
Additional issues that are much more concerning to the building's safety will be discussed in our next post.
Nelligan Consulting Engineers has a great Fire Engineering team, including an in-house Chartered Passive fire protection consultant with expertise in Fire Doors and knowledge to assist you with your project at various stages to ensure the installation is appropriately specified, compliant, cost-effective, and with minimal delays.