K223 – Doors Held Open? Only If It's Done Right
Understanding When Doors Can Stay Open and What Triggers Them to Close
CMS Survey for Life Safety K223 is all about protecting people by controlling the spread of fire and smoke. But here’s the problem: many staff members don’t realize that some doors in your facility aren’t just doors—they're fire and smoke barriers. These doors must close during a fire emergency, and if they’re not working properly, it could lead to survey citations or worse.
This newsletter is designed to make sure everyone understands which doors are affected, how they should function, and what options you have when it comes to setting up your system the right way.
What Does K223 Actually Say?
K223 requires that certain doors be self-closing and kept closed—unless they are held open by a release device that meets strict safety standards. These doors are located in important areas like:
Exit passageways
Stairway enclosures
Horizontal exits
Smoke barriers
Hazardous area enclosures
If these doors are held open, they must be connected to an automatic release device that will close them during an emergency, such as:
Activation of the fire alarm system
Smoke detected by a local smoke detector or a required smoke detection system
Activation of the sprinkler system (if your building has one)
Loss of power to the hold-open device
Code Option: Smoke Compartment or Entire Facility?
Here’s a very important detail that’s often overlooked:
According to Section 19.2.2.2.7 of the Life Safety Code, you have a choice when it comes to how many doors will close during a fire event. You can set the system to close:
All such doors throughout the smoke compartment, or
All such doors throughout the entire facility
Most facilities choose the entire facility, and many surveyors are used to seeing it that way. But remember, that is not required. If your system is designed to close only the doors in the affected smoke compartment, that’s still code compliant. Just be ready to explain this to a surveyor, especially when it’s not what they typically see.
What About Automatic-Closing Doors?
Not all doors need to stay closed all the time. If your doors are designed to stay open during normal use, they must meet Section 7.2.1.8.2 to be code compliant. That section allows automatic-closing doors in most buildings, if they follow these five rules:
Once the hold-open device is released, the door must self-close.
The device must release instantly if pulled manually, and the door must close on its own.
The device must respond to approved smoke detectors, installed following NFPA 72.
If there is a power failure, the door must still close on its own.
If one stairwell door closes due to smoke, then all doors serving that stairwell must also close.
Common Mistakes That Lead to Citations
Facilities often get cited for:
Doors propped open with wedges or furniture
Hold-open devices not tied to smoke detectors
Doors that don’t close when the fire alarm is activated
Door systems that don’t work after a power loss
Staff not knowing how or why these doors’ function
If your door is designed to close automatically, you must test it regularly, and staff should understand how it works and why it matters.
The Bottom Line
Doors that are part of your fire and smoke protection plan must self-close during emergencies. Whether you choose to close doors across your entire facility or just the affected smoke compartment, both options are compliant. Just make sure your systems are working, your staff is trained, and you’re prepared to explain your setup during a survey.
This isn’t just about passing an inspection—it’s about saving lives and stopping fire and smoke from spreading.
How I Can Help
Staying ahead of Life Safety Compliance doesn’t have to be overwhelming. At Dustin Phillips Consulting, I make it easier for your team to understand what’s required, prepare for surveys, and improve safety across your facility.
Whether it’s mock surveys, staff training, or reviewing your documentation and fire plans, I bring real-world experience with practical solutions. My job isn’t just to point out issues—it’s to help you fix them before they become citations.
If you're looking for clear guidance and a partner who makes life safety surveys easier, let’s connect. A quick conversation today could save you a major headache tomorrow.
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