A Guide to Life Safety Damper Testing

Building codes require installation of life safety dampers for several purposes. Most are used as part of compartmentalization to prevent the spread of fire and smoke in a life-threatening event. Smoke control systems employ dampers to prevent the spread of smoke or to remove it, while some dampers can be used for other types of fire and smoke control. Periodic testing of all life safety dampers is required.

Codes and Referenced Standards

While the International Building Code (IBC) defines the requirements for installation of life safety dampers, it is the International Fire Code (IFC) that defines the requirements for their periodic testing. Section 706.1 Maintaining Protection of the IFC references NFPA 803 (fire) and NFPA 105 (smoke) for those requirements. Some clarification or additional requirements and exceptions are contained in the IBC and IFC. Dampers installed per Chapter 7 of the IBC are part of fire-resistance-rated construction, and the dampers are referred to as “containment dampers.” In contrast, dampers installed per Chapter 9 are referred to as “smoke control system dampers.”

Owner’s Responsibility

The building owner is responsible for maintaining fire-resistance-rated construction. This is clearly stated in IFC Section 701.6 Owner’s Responsibility and includes “construction installed to resist the passage of smoke.” The owner shall maintain records of inspections and repairs.

Section 907 of the IFC deals with fire alarm and detection systems and includes “life safety systems”, which are more inclusive. Section 907.8.5 Inspection, Testing and Maintenance also states that the building owner is responsible. A record of inspection, testing, and maintenance must be kept. This is also stated in NFPA 80 and NFPA 105, which are more specific to dampers. An up-to-date log book is normally enough for examination by the building official or fire marshal during inspections. This, however, is the provenance of the authority having jurisdiction.

In both the IFC and IBC Section 909.3 Special Inspection and Test Requirements, commissioning of a smoke control system is required to be subject to special inspections and tests in addition to ordinary inspections and tests. IBC Section 1704 references the professional qualifications and record-keeping requirements.

Section 909.18.8.2 Qualifications of the IFC and the IBC Section 1705.18.2 establish that qualifications require that smoke control testing (commissioning) agents “shall have expertise in fire protection, engineering, mechanical engineering and certification as air balancers.” However, no qualifications are explicitly stated for periodic testing. Some of the larger owners and hospitals have qualified people on staff to perform the testing.

Others ignore the requirements or are not aware they exist. Service contracts should include periodic testing either by the ventilation or mechanical contractor themselves or by a sub with whom they contract. Local code officials may have expectations and owner prudence would indicate that a test, adjust, and balance (TAB) contractor or otherwise qualified agent perform or oversee the work. In any event, TAB contractors should make their building owners aware of the code requirement and, when attending local ICC or ASHRAE meetings, inform mechanical contractors and engineers of their capabilities.

Testing Requirements

The IBC does not mention any periodic damper testing requirements within Chapter 7. IFC Section 706 covers duct and air-transfer openings. Section 706.1, Maintaining Protection, states that dampers protecting openings shall be maintained in accordance with NFPA 80 and NFPA 105. IFC Section 717.4 Access and Identification requires proper access to dampers. It also requires a minimum of half-inch high labels with capital letters identifying the damper type: fire/smoke, smoke, or fire damper. While this is not a testing requirement, it makes locating the dampers, and thus facilitating testing, possible. There is no further mention of testing requirements in Chapter 7 of either code.

Chapter 9 of both the IBC and IFC have the most detail regarding testing requirements. Both have the same Section 909.12 Detection and Control Systems requiring fire alarms and controls, as well as associated equipment be listed to UL 864 and UUKL listing if used for smoke control. UL 864 requires all equipment listed to be capable of a weekly self-test. Actuated dampers are not investigated to UL 864 standards and are excluded from the weekly self-test as long as the fire code official approves.

Infrequently, there is confusion about the above requirement between UL 864 and the UL 555 family of standards. UL will not investigate dampers to UL 864, and listing to one of the UL 555 family of standards is correct. The exception to 909.12.1 allows components that could interfere with building operation to be bypassed, and Section 909.20.6 of the IFC should be followed. The most common situation where dampers should not be tested is at the intakes or outlets of fans.

If the fan is running and a damper closes, negative duct pressure (suction) or positive pressure (discharge) can collapse ducts or split the seams, and the fans may shut down on static pressure limits, which are usually manually reset. As the smoke control fans and dampers are typically part of the fire alarm equipment and non-dedicated equipment part of the building management system, care must be taken to avoid not just interference but actual damage.

IFC Section 909.20 is maintenance. Sections 909.20.1. through 909.20.6 detail requirements. Operational testing of each control sequence and device must be tested semi-annually for dedicated systems, while non-dedicated systems must be tested annually. Dampers are specifically included in Section 909.20.3. Section 909.20.6 Components Bypassing Weekly Test requires semiannual testing. Dedicated system dampers must be tested semi-annually per NFPA 105, and non-dedicated dampers must be tested annually. Since they are not UL 864 listed, the NFPA standard regulates their testing frequency.

Other dampers that need testing may be installed per IBC 909.20 Smokeproof Enclosures. They should be tested per smoke control system damper requirements. Fire extinguishing equipment other than sprinklers is covered in IFC Section 904 Alternative Automatic Fire-Extinguishing Systems.

In Section 904.8.5 Auxiliary Equipment, the requirement exists for components, including dampers, to be operated at “12-month intervals.” Section 904.12.3 covers carbon dioxide systems. It recognizes that dampers may be installed in a duct as part of the system. Section 904.8.1 System Test requires yearly inspection and testing. NFPA 127 is referenced in Table 901.6.1 Fire Protection System Maintenance Standards, and as with all systems, records must be maintained.

The IFC Section 910 Smoke and Heat Removal states that smoke and heat vents are required to be inspected annually and operationally tested not less than every five years. Section 910.5.2 states that mechanical smoke removal equipment should be tested and maintained according to NFPA 2048 and the manufacturer’s instructions. These systems should be inspected and tested annually, and all ancillary equipment should be included. This would include any associated fan discharge dampers. Again, a record must be kept. These dampers are not typically considered to be smoke control related per se, but in specific cases, may be interpreted to be so.

Dampers

There are four essential types of life safety dampers:

1. Ceiling radiation
2. Fire
3. Smoke
4. Combination fire and smoke

Depending on the application, they have varying requirements for periodic testing. Further details will be covered in Part II of this series in early 2019.*

In summary, building owners are responsible for maintaining and periodic testing of life safety dampers. The IFC references NFPA 80 and NFPA 105 for some details but states the requirements in Chapter 7 and Chapter 9.