The Vermont State Archives and Records Administration has received inquiries from towns building vaults for their town clerk's records on how to comply with NFPA 232, and I'm wondering if other records management professionals on this list have run into similar issues, and how they were resolved. The Vermont Division of Fire Safety has adopted NFPA 232 into their codes, and they are ultimately responsible for enforcing the codes, but they are seeking input from the State Archives on appropriate requirements for vaults.
The first question is relatively straightforward: NFPA 232, 6.10.2, requires that a 6-hour vault be constructed with a 6-hour vault door. However, towns which have attempted to procure a 6-hour door have been unable to find a manufacturer who still makes one. Is anyone aware of a manufacturer that does make 6-hour doors? A Google search shows that SentrySafe once made 6-hour doors, but a call to the SentrySafe confirms that the doors have been discontinued.
The second question is a bit more complicated, and is in regards to dampers in vault ventilation systems; NFPA 232 seems to set out conflicting requirements for how wall penetrations for ventilation must be protected. We have a town constructing a new 4-hour vault with a ventilation system, but when they looked to procure fire dampers for the ventilation, the highest rating they could find was for 3-hour fire dampers. Parts of NFPA 232, 5.1.9 and 5.4.2, state that NFPA 90A requirements shall be used for ventilation systems, and 90A states that a 3-hour damper shall be used in openings in walls "having a fire resistance rating of 3 hours or more". This would seem to indicate that it is acceptable to put a 3-hour damper in a 4-hour wall opening.
However, in the chapter of NFPA 232 specific to vaults, in section 6.7.6.4, it states that "Wall penetrations shall be sealed with a listed fire-rated through penetration assembly with a minimum rating that meets or exceeds the rating of the vault". This would seem to indicate that a 4-hour wall must have at least a 4-hour damper, which the town was unable to find a manufacturer for. Is anyone aware of what the correct interpretation of NFPA 232 is, and if a 3-hour damper would be acceptable in a wall penetration of a 4-hour vault?
Sincerely,
Steven
Steven Dibelius, CRM CIP
Chief Records Officer
Vermont State Archives & Records Administration
1078 U.S. Route 2, Middlesex
Montpelier, VT 05633-7701
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802-828-5026
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