NFPA 101 Changes
An examination of changes to NFPA 101 and how they apply to health care facilities.
The tricky part of this is that one must look not only at the changes occurring with the 2012 edition of NFPA 101; one must also look at the series of changes that occurred in the three editions between the 2000 edition and the 2012 edition. The good news is that the 2012 edition of NFPA 101 is, in most cases, more helpful to heath care facilities in terms of increased design flexibility and greater opportunity for existing facilities to come into compliance.
Let’s start off with an important format change. Since the 2003 edition, all items previously identified as “exceptions” have been changed to numbered paragraphs. So format-wise, they look like any other code provision. This did not really change any of the technical criteria. These “exceptions” will follow the basic requirement and one must carefully read all the paragraphs following the basic requirement to avoid problems. (Question, which NFPA code or standard still uses exceptions?)
With regard to buildings containing more than one occupancy, the 2000 edition “sort of” required occupancies to be separated unless they were mixed, in which case the most stringent occupancy requirements would apply. Though the chapters for health care, ambulatory health care, detention, and correctional identify separation requirements, other occupancy chapters do not identify separation requirements in the 2000 edition.
This gap was corrected starting with the 2003 edition of NFPA 101. The concept of Multiple Occupancy Buildings was introduced. A multiple occupancy building could contain mixed occupancies or separated occupancies. New tables in Chapter 6 were added to identify the fire resistance separation required between separated occupancies. You may recall that in early 2000 NFPA was battling with the ICC for world building code dominance (who won?). The separation requirements created for the first edition (2002) of NFPA 5000 were brought into NFPA 101.
Means of egress
New to the 2012 edition, is 18.104.22.168.10.6, two releasing operations shall be permitted for existing hardware on a door leaf serving an area having an occupant load not exceeding three, provided that releasing does not require simultaneous operations. Many existing Health Care Occupancies (HCO’s) have a large number of small offices and exam rooms that have both a door latch and a separate deadbolt or thumb latch. These are no longer considered code violations for existing buildings.
Starting with the 2009 edition, 22.214.171.124.2 For other than existing means of egress, where more than one means of egress is required, the means of egress shall be of such width and capacity that the loss of any one means of egress leaves available not less than 50 percent of the required capacity. This will primarily affect those new HCO’s which have assembly occupancies, such as auditoriums and large classrooms.
New to the 2012 edition, 126.96.36.199 Stairs and ramps that continue more than one-half story beyond the level of discharge shall be provided with an approved means to prevent or dissuade occupants from traveling past the level of discharge during emergency building evacuation. I was surprised to see that the feature was only recently added to 101.
Fire rated glazing
Extensive material on fire-rated glazing was added to the 2003 edition. Starting with the 2006 edition, 188.8.131.52.2 New fire resistance-rated glazing shall bear the identifier “W-XXX”, where “XXX” is the fire resistance rating in minutes. Such identification shall be permanently affixed. Again, this requirement calls for new fire-rated glass to be etched in a manner to indicate this information.
New to the 2012 edition, wired glass is permitted only for existing installations per 184.108.40.206. Also new to the 2003 edition, Table 220.127.116.11 Minimum Fire Protection Ratings for Opening Protectives in Fire Resistance–Rated Assemblies and Fire-Rated Glazing Markings. The table was extensively expanded and revised in the 2012 edition.
There have been several revisions related to firestopping. The 2003 edition in 18.104.22.168 identifies where firestop systems are required. Also, material on membrane penetrations (22.214.171.124) was added. In 2006, requirements for joints (8.3.6), where fire barriers meet, was added. In 2009, requirements for Exterior Curtain Walls and Perimeter Joints (126.96.36.199) were introduced.
For many years, doors in smoke barriers in HCO’s have been exempt from the general 101 requirement that these doors must latch. To help stop the confusion, the 2012 edition added a section to point to this exemption for HCO’s, 188.8.131.52 Latching hardware shall be required on doors in smoke barriers, unless specifically exempted by Chapters 11 through 43.
Sprinkler system impairments
In the 2012 edition, the details of sprinkler system impairment procedures have been removed and are taken care of with a reference to NFPA 25, Standard for the Inspection, Testing and Maintenance of Water-Based Fire Protection Systems.
Rehabilitation of existing non-sprinklered smoke compartments
The 2000 edition requires major rehabilitation projects involving a nonsprinklered smoke compartments to be provided with automatic sprinkler protection. The 2003 edition provided thresholds to define the difference between a major and minor rehabilitation. The 2003 edition also added provisions in 18.4.3 that identifies minimum requirements to which a smoke compartment, undergoing rehab and exempt from adding sprinklers, must comply with.
Alcohol-based hand-rub dispensers
To address the industry concern with infection control, there was a desire to allow the use of sanitizing hand-rubs. The flammable nature of the hand-rubs was naturally a concern to fire safety professionals, particularly when dispensers were located in patient rooms and corridors and other means of egress in patient care areas. Starting in 2006, provisions were developed to permit the installation of dispensers while minimizing the fire hazard.
NFPA 101 editions since 2000 have extensively expanded the provisions related to suites in health care occupancies. Suites are a great way to avoid costly requirements for corridors, including the 8-feet corridor width. There are now three major types of suites: sleeping suites, patient care non-sleeping suites and non-patient care Suites. In the 2003 edition, the maximum size of a sleeping suite was 5,000 square feet. With the 2006 edition, this was allowed to be increased to 7,500 square feet, if additional requirements were met. The 2012 edition then increased the base maximum size to 7,500 square feet, and allows an increase to 10,000 sf if additional requirements are met.
There are many other changes to suites that have been incorporated since 2000, too numerous to list here. The changes are generally favorable to the suite concept and tend to promote its use.
Patient friendly trend impact
The expansion of suite provisions and of suites themselves is, in part, a reaction to changes in the way society wants to care for patients. The industry is looking to make buildings housing these patients less institutional and more comfortable, more patient friendly.
These patient friendly provisions include allowing fixed furniture in corridors, allowance of cooking facilities within smoke compartments containing patient sleeping and allowance of direct-vent gas fireplaces in smoke compartments containing patient sleeping rooms. You can imagine how hard it was for AHJ’s on the committee to get comfortable with the idea of open flames in smoke compartments containing patients. For facilities designed to these requirements families can visit with patients and prepare a “home cooked meal” at the same time.
Existing nursing homes
Members of NFPA 101 technical committees are frequently reminded to be careful about imposing retroactive requirements in existing occupancy chapters. In the aftermath of a spate of life-loss fires in non-sprinklered nursing homes, the American Health Care Association (an advocate for nursing home operators), came to the NFPA 101 technical committee on Health Care Occupancies and proposed a change to the 2006 edition to require sprinklers for all existing nursing home. This unprecedented act, coming from those that were to bear the cost of this retroactive requirement, was gladly approved by the technical committee.
Existing high-rise hospitals
In a more controversial move, the technical committee agreed to retroactively require sprinklers for existing high-rise health care occupancies in 2009 edition of NFPA 101. Existing high-rise HCO’s had to be sprinklered within 12 years of adoption of the 2009 code. The 2012 NFPA 101 also includes the 12-year grace period from adoption of the code, unless the 2009 was previously adopted, in which case the grace period is only 9 years. FYI, the 2015 NFPA 101 also includes the 12-year grace period from adoption of the code, unless the 2009 was previously adopted, in which case the grace period is only 12 years
Chapter 43 building rehabilitation
This new chapter was added in 2006, and provides excellence guidance as to what levels of compliance are required based on what type of building rehabilitation is performed. Two key provisions I take from this chapter are that: 1) compliance with the requirements for existing occupancies is the minimum level of compliance, and 2) that for existing facilities that exceed requirements for existing occupancies, they may only eliminate fire safety features that exceed the requirement for new occupancies.
As noted last month, it really is about time that, after 16 years, CMS has been able to update to a more current set of documents. Particularly since many of the changes contained in the 2012 NFPA 101 will save hospitals money. An industry that is expected to meet the rapidly changing health care environment deserves regulation that keeps pace with the times. The patients deserve better as well.
Samuel S. Dannaway, P.E., FSFPE, is a licensed fire protection engineer and mechanical engineer with bachelor’s and master’s degrees from the University of Maryland Department of Fire Protection Engineering. He is a past president and fellow of the Society of Fire Protection Engineers. He is vice president of Fire Protection Technology at Coffman Engineers Inc., a multidiscipline engineering firm with over 360 employees across eight offices. Email him at firstname.lastname@example.org.