RCW 19.27.710 and Ceiling Radiation Dampers
Are ceiling radiation dampers required to be tested by law?
A friend asked for my opinion on a question he got from one of his customers. They’re designing a senior living apartment building. Having regular, disruptive inspections might steer them away from using Ceiling Radiation dampers. Under Washington State Law RCW 19.27.710, dampers are required to be inspected, or else penalties can be issued by the AHJ. But the wording of the law, which says nothing about Ceiling Radiation Dampers, seemed a little unclear. It only says, “fire dampers, smoke dampers, and combination fire and smoke dampers”. (You can check out the law here.) The customer’s question: Because it doesn’t say anything about Ceiling Radiation dampers, would inspections still be required for this type of damper?
The answer is yes.
The 2024 International Fire Code chapter 909.18.3 and Seattle Fire Code chapter 706.1 say very similar things.
2024 IFC 909.18.3: “Dampers shall be tested for function in their installed condition in accordance with NFPA 80 and 105.”
2021 SFC 706.1: “Dampers protecting ducts and air transfer openings shall be inspected and maintained in accordance with NFPA 80 and NFPA 105.”
How does NFPA 80 treat these types of dampers? It categorizes them in the exact same category as those types mentioned in RCW 19.27.710.
3.3.37 Damper.
3.3.37.1 Ceiling Radiation Damper.
A listed device installed in a ceiling membrane of a fire-resistance-rated floor–ceiling or roof–ceiling assembly to automatically limit the radiative heat transfer through an air inlet/outlet opening. [90A, 2024]
3.3.37.2 Combination Fire-Smoke Damper.
A listed device installed in the ducts or air transfer openings of fire-resistance-rated walls, barriers, partitions, or floors that meets both fire damper and smoke damper requirements. [90A, 2024]
3.3.37.3 Corridor Damper.
A listed device intended for use where air ducts penetrate or terminate at horizontal openings in the ceilings of fire-resistance-rated corridors and where the corridor ceiling is constructed as required for the corridor walls. [90A, 2024]
3.3.37.4* Fire Damper.
A listed device installed in an airdistribution system and designed to close automatically upon detection of heat, to interrupt migratory airflow, and to restrict the passage of flame. [90A, 2024]
3.3.37.5 Smoke Damper.
A listed device within an airdistribution system to control the movement of smoke. [90A, 2024]
In NFPA 80 chapter 20 (the section that talks about testing dampers) it explicitly states.
This chapter covers the installation, testing, and maintenance requirements of fire dampers, ceiling radiation dampers, combination fire-smoke dampers, and corridor dampers.
And, NFPA 80 chapter 20 says that defines how dampers should be inspected.
20.3.4* Periodic Inspection and Testing.
20.3.4.1 Testing Frequency.
20.3.4.1.1
Each damper shall be tested and inspected 1 year after acceptance testing.
20.3.4.1.2
After the inspection and test required by 20.3.4.1.1, the test and inspection frequency for dampers shall comply with one of the following:
(1)
Every 4 years
(2)
Every 6 years, in buildings containing a hospital
This verbiage is exactly the same verbiage as the law and is a requirement of both the International Fire Code and Seattle Fire code. This means, to answer my friend’s question: yes. Ceiling Radiation dampers, under Fire Code, are required to be tested in the exact same way as the dampers mentioned in RCW 19.27.710.