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FAQ about Compliance to UBC-7-2-97/UL-10C

Understanding the revised Uniform Building Code (UBC) and International Building Code (IBC) changes can be a complex challenge. Below are answers to some of the most commonly-asked questions regarding compliance with the requirements for positive pressure-tested, fire-rated assemblies, as well as smoke and draft control assemblies.

Question: I am a licensed distributor (or machiner) of fire doors. How can I comply with these new requirements for positive pressure and assemblies?

Answer: Any licensed distributor/machiner authorized to label doors and/or frames by suppliers listed in this directory is eligible to label those doors and/or frames for "Positive Pressure".

First, you will need to obtain updated specifications that include procedures for products complying with UBC-7-2-97/UL-10C. These are available through your listing agency, with authorization by your supplier(s).

Second, you will need to obtain labels that indicate UBC-7-2-97/UL-10C compliance. These can be "half-tab" supplemental labels or full labels custom printed for this purpose.

Third, you will need to obtain an updated "Authorization to Mark" form signed by your listing agency representative.

Question: What about smoke and draft control requirements - what do I need to know?

Answer: Virtually all door assemblies are eligible to bear the smoke mark ("S" in a box) if the assembly contains a Category H, "Fire-Rated Smoke and Draft Control Gasket" system. The Smoke and Draft Control gasket system must be listed and labeled to show compliance with UBC-7-2-97, Parts I and II.

Smoke and draft control door assemblies are required on all exit-access doorways, and doorways from an unoccupied areas to a corridor.

Question: What is the difference between Category H, "Smoke and Draft Control Gasket" systems and Category G, "Edge-Sealing" systems?

Answer: Smoke and draft control systems are designed to minimize the passage of smoke. Edge-sealing systems are designed to minimize the passage of flame.

Question: Are frames required to bear the "S" marking on the label if they are being installed into Smoke and Draft Control openings?

Answer: No. The UBC states that, "The door and frame assembly shall bear an approved label or other identification showing the rating, thereof followed by the letter 'S'." ITS has designed a system that allows the door and frame assembly to be covered by the "S" marking on the door label. This is consistent with the long-standing practice where (3-sided) steel frames have not been required to indicate an hourly rating since they effectively assume the rating of the lowest rated component in the opening (refer also to NFPA-80).

Question: How do we (as licensed manufacturers and machiners) assure that they installed assembly complies with the requirements for positive pressure?

Answer: Unfortunately, you probably will not be able to absolutely ensure that the assemblies are installed properly. However, through the use of complete, detailed instructions (to the installer), you will have provided the information necessary for the installer to install the assembly properly. Responsibility for following the instructions rests with the installer, the contractor, and the local AHJ.

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