NFPA 101 Life Safety Code - 2005 Edition Comment Period Closes October 1, 2004
The National Fire Protection Association is in the process of updating the 2003 edition of the Life Safety Code (NFPA 101). The new edition will be released in 2005 in order to bring the document in line with NFPA 5000. Although there is no certainty, there is a good possibility of this new edition being referenced by both the Centers for Medicare and Medicaid Services and the Joint Commission on Accreditation of Healthcare Organizations subsequent to its publication. The rationale behind this statement is the pending retroactive requirement for nursing homes to be fully sprinklered. ASHE/AHA is a strong participant in the NFPA process and has been a member of the Technical Committee on Health Care Occupancies of NFPA 101 since 1975. With the LSC being one of the most referenced documents in the design and continued maintenance of healthcare facilities, it is very important for the ASHE member to understand the proposed changes and to voice their opinion on the newly proposed code language. This article is a summary of the major changes being proposed in the 2005 edition of the Life Safety Code. For more detailed information go to the Codes and Standards section of the NFPA website to access the Report on Proposals for NFPA 101 at: www.nfpa.org
As of the publishing of this article, the timeframe for responding back to the NFPA on the public proposals for the 2005 edition of the LSC is very tight. Below is a synopsis of the major issues and the reference number to the Proposal in which the new language was proposed. Underlined text is proposed for the 2006 edition and text that has a strikethrough is recommended for deletion. To submit comments on these proposals (10/1/04 deadline) go to www.nfpa.org/PDF/commentform.pdf?src=nfpa
Alcohol-Based Hand-Rubs (Hospitals, Nursing Homes and Ambulatory Care Facilities)
(Proposal 101-410 (Log #CP1206) page 101-148 of ROP on NFPA 5000 & NFPA 101, (Log #CP1207), (Log #CP1208), and (Log #CP1209)
Note: This proposal is similar for existing health care facilities and new and existing ambulatory health care facilities (19.3.2.6, 20.3.2.6, 21.3.2.6). Some of the language will be modified for these other facilities to be in line with the corridor requirements of these facilities.
18.3.2.6,* Alcohol-based Hand-rub Solutions. Alcohol-based hand-rub dispensers shall be protected in accordance with 8.7.3 unless all of the following conditions are met:
(1) Where dispensers are installed in a corridor, the corridor shall have a minimum width of 1830 mm (72 in.).
(2) The maximum individual dispenser fluid capacity shall be:
(a) 1.2 liters (0.32 gals) for dispensers in rooms, corridors, and areas open to corridors
(b) 2.0 liters (0.53 gals) for dispensers in suites of rooms
(3) The dispensers shall have a minimum horizontal spacing of 1220 mm (48 in.) from each other.
(4) Not more then an aggregate 37.8 liters (10 gallons) of alcohol-based hand rub solution shall be in use in a single smoke compartment outside of a storage cabinet.
(5) Storage of quantities greater then 18.9 liters (5 gallons) in a single smoke compartment shall meet the requirements of NFPA 30, Flammable and Combustible Liquids Code.
(6) The dispensers shall not be installed over or directly adjacent to an ignition source.
(7) In locations with carpeted floor coverings, dispensers installed directly over carpeted surfaces shall be permitted only in sprinklered smoke compartments.
18.2.3.4* Aisles, corridors, and ramps required for exit access in a hospital or nursing home shall be not less than 2440 mm (96 in.) in clear and unobstructed width, unless otherwise permitted by the following:
(1)* Aisles, corridors, and ramps in adjunct areas not intended for the housing, treatment, or use of inpatients shall be not less than 1120 mm (44 in.) in clear and unobstructed width.
(2) Where minimum corridor width is 1830 mm (72 in.), projections of maximum 152 mm (6 in.) from the corridor wall, above the handrail height, shall be permitted for the installation of hand-rub dispensing units in accordance with 18.3.2.6.
(3)* (2)* Exit access within a room or suite of rooms complying with the requirements of 18.2.5 shall be permitted.
18.2.3.5 Aisles, corridors, and ramps required for exit access in a limited care facility or hospital for psychiatric care shall be not less than 1830 mm (72 in.) in clear and unobstructed width, unless otherwise permitted by the following:
(1)* Aisles, corridors, and ramps in adjunct areas not intended for the housing, treatment, or use of inpatients shall be not less than 1120 mm (44 in.) in clear and unobstructed width.
(2) Where minimum corridor width is 1830 mm (72 in.), projections of maximum 152 mm (6 in.) from the corridor wall, above the handrail height, shall be permitted for the installation of hand-rub dispensing units in accordance with 18.3.2.6.
(3)* (2)* Exit access within a room or suite of rooms complying with the requirements of 18.2.5 shall be permitted.
Proposal 101-96 Log #CP1216 SAF-HEA page 101-39 of ROP on NFPA 5000 & NFPA 101
7.2.1.4.1* Any door in a means of egress shall be of the side-hinged or pivoted-swinging type, and shall be installed to be capable of swinging from any position to the full required width of the opening in which it is installed, unless otherwise specified in 7.2.1.4.1.1 through 7.2.1.4.1.9 7.2.1.4.1.8.
7.2.1.4.1.5 Horizontal-sliding doors complying with 7.2.1.14 shall be permitted.
7.2.1.4.1.6 Horizontal-sliding doors serving a room or area with an occupant load of fewer than 10 in health care occupancies shall be exempt from the requirements of 7.2.1.4.1 as provided in Chapter 18 or Chapter 19.
For Reference:
7.2.1.4.1* Any door in a means of egress shall be of the sidehinged or pivoted-swinging type, and shall be installed to be capable of swinging from any position to the full required width of the opening in which it is installed, unless otherwise specified in 7.2.1.4.1.1 through 7.2.1.4.1.8.
(Proposal 101-400 Log #CP1215 SAF-HEA) page 101-143 of ROP on NFPA 5000 & NFPA 101
18/19.2.2.2.9.2 Eliminates the Breakaway Feature of the Door
18.2.2.2.9 Horizontal sliding doors shall be permitted in accordance with 18.2.2.2.9.1 or 18.2.2.2.9.2.
18.2.2.2.9.1 Horizontal sliding doors, as permitted by 7.2.1.14, that are not automatic-closing shall be limited to a single leaf and shall have a latch or other mechanism that ensures that the doors will not rebound into a partially open position if forcefully closed in an emergency.
18.2.2.2.9.2 Horizontal sliding doors serving an occupant load of fewer than 10 shall be permitted provided all of the following are met:
(a) The area served by the door has no high hazard contents.
(b) The door is readily operable from either side without special knowledge or effort.
(c) The force required to operate the door in the direction of door travel is not more than 133 N (30 lbf) to set the door in motion and is not more than 67 N (15 lbf) to close the door or open it to the minimum required width.
(d) The door assembly complies with the fire protection rating, if required, and, where rated, is self-closing or automatic-closing by means of smoke detection in accordance with 7.2.1.8 and is installed in accordance with NFPA 80, Standard for Fire Doors and Fire Windows.
(e) Corridor doors shall have a latch or other mechanism that ensures that the doors will not rebound into a partially open position if forcefully closed.
For Reference:
7.2.1.14 Horizontal-Sliding Doors. Horizontal-sliding doors shall be permitted in means of egress, provided that the following criteria are met:
(1) The door is readily operable from either side without special knowledge or effort.
(2) The force that, when applied to the operating device in the direction of egress, is required to operate the door is not more than 67 N (15 lbf).
(3) The force required to operate the door in the direction of door travel is not more than 133 N (30 lbf) to set the door in motion and is not more than 67 N (15 lbf) to close the door or open it to the minimum required width.
(4) The door is operable using a force of not more than 222 N (50 lbf) when a force of 1100 N (250 lbf) is applied perpendicularly to the door adjacent to the operating device, unless the door is an existing horizontal-sliding exit access door serving an area with an occupant load of fewer than 50.
(5) The door assembly complies with the fire protection rating, if required, and, where rated, is self-closing or automatic-closing by means of smoke detection in accordance with 7.2.1.8 and is installed in accordance with
(Proposal 101-134 Log #CP1210 SAF-HEA) page 101-60 of ROP on NFPA 5000 & NFPA 101
7.3.2 Measurement of Means of Egress.
7.3.2.1 The width of means of egress shall be measured in the clear at the narrowest point of the exit component under consideration, unless otherwise provided in 7.3.2.2 or 7.3.2.3.
7.3.2.2 Projections within the means of egress of not more than 114 mm (4 1/2 in.) on each side shall be permitted at a height of 965 mm (38 in.) and below.
7.3.2.3 In health care and ambulatory health care occupancies, projections shall be permitted in corridors as allowed by Chapter18 through Chapter 21.
(Proposal 101-405 Log #388 SAF-HEA) page 101-144 of ROP on NFPA 5000 & NFPA 101
18.2.3.4* and 19.2.3.4 Aisles, corridors, and ramps required for exit access in a hospital or nursing home shall be not less than 2440 mm (96 in.) in clear and unobstructed width, unless otherwise permitted by the following:
(1)* Aisles, corridors, and ramps in adjunct areas not intended for the housing, treatment, or use of inpatients shall be not less than 1120 mm (44 in.) in clear and unobstructed width.
[(2) New text will be inserted here by Committee Proposal 101- (Log #CP1206) on alcohol-based hand-rub dispensers]
(3) Where minimum corridor width is 1830 mm (72 in.), projections shall be permitted in corridors, at both sides of the corridor, as follows:
(a) Each projection shall not exceed a depth of 152 mm (6 in.).
(b) Each projection shall not exceed a length of 915 mm (36 in.).
(c) Each projection shall be positioned a minimum of 1015 mm (40 in.) above the floor.
(4)* (2)*Exit access within a room or suite of rooms complying with the requirements of 18.2.5 shall be permitted.
18.2.3.5 and 19.2.3.5 Aisles, corridors, and ramps required for exit access in a limited care facility or hospital for psychiatric care shall be not less than1830 mm (72 in.) in clear and unobstructed width, unless otherwise permitted by the following:
(1)* Aisles, corridors, and ramps in adjunct areas not intended for the housing, treatment, or use of inpatients shall be not less than 1120 mm (44 in.) in clear and unobstructed width.
[(2) New text will be inserted here by Committee Proposal 101- (Log #CP1206) on alcohol-based hand-rub dispensers]
(3) Where minimum corridor width is 1830 mm (72 in.), projections shall be permitted in corridors, at both sides of the corridor, as follows:
(a) Each projection shall not exceed a depth of 152 mm (6 in.).
(b) Each projection shall not exceed a length of 915 mm (36 in.).
(c) Each projection shall be positioned a minimum of 1015 mm (40 in.) above the floor.
(4)* (2)*Exit access within a room or suite of rooms complying with the requirements of 18.2.5 shall be permitted.
Cross Corridor Doors and Smoke Leakage
(Proposal 101-186 Log #CP1217 SAF-HEA) page 101-76 of ROP on NFPA 5000 & NFPA 101
8.5.4.2 [current 8.5.3.2] New doors in smoke barriers in other than health care occupancies shall comply with the requirements of 8.2.2.4.
For Reference:
8.2.2.4 Where required elsewhere in this Code to comply with 8.2.2.4, door assemblies also shall comply with the following:
(1) They shall be tested in accordance with UL1784, Standard
for Air Leakage Tests for Door Assemblies.
(2) The maximum air leakage rate of the door assembly shall
be 0.9 m3/min/m2 (3.0 ft3/min/ft2) of door opening at
25 N/m2 (0.10 in. water column) for both the ambient
and elevated temperature tests.
Commentary:
The health care occupancies provisions for smoke barriers have not required the doors to be smoke leakage rated as a conscious decision of the SAF-HEA committee. The health care occupancies cross-corridor smoke barrier doors are not required to have latches as a practical necessity for effective day-to-day operations. The smoke leakage-rated door testing is required to be run on specimens arranged as the doors are intended to be installed in actual use. The health care occupancies cross-corridor doors without latches will not pass the required testing.
(Proposal 101-290 Log #CP1219 SAF-HEA) page 101-107 of ROP on NFPA 5000 & NFPA 101
Further revise the text proposed as a new 11.8.6 by SAF-IND's action on Proposal 101- (Log #346) by adding an exemption to read:
Elevator hoistway separation shall not be required in health care and ambulatory health care occupancies where elevators serving the floor are located in at least two smoke compartments.
Commentary:
The health care occupancies committee requests the Technical Correlating Committee to take one of two actions:
1. Permit the health care occupancies exemption shown above in the recommendation field, or
2. Modify the text so as to allow the exemption for any occupancy as follows: Elevator hoistway separation shall not be required where elevators serving the floor are located in at least two smoke compartments.
Fire-Retardant-Treated Lumber New and Existing
(Proposal 101-397 Log #191 SAF-HEA) page 101-142 of ROP on NFPA 5000 & NFPA 101
18.1.6.6 All interior walls and partitions in buildings of Type I or Type II construction shall be of noncombustible or limited-combustible materials.
18.1.6.6 Interior nonbearing walls in buildings of Type I or Type II construction shall be constructed of noncombustible or limited-combustible materials unless otherwise permitted by 18.1.6.7.
18.1.6.7 Interior nonbearing walls required to have a fire resistance rating of 2 hours or less shall be permitted to be fire retardant–treated wood enclosed within noncombustible or limited-combustible materials, provided such walls are not used as shaft enclosures.
18.1.6.818.1.6.7 Fire-retardant-treated wood that serves as supports for the installation of fixtures and equipment shall be permitted to be installed behind noncombustible or limited-combustible sheathing.
18.1.6.918.1.6.8 All buildings with more than one level below the level of exit discharge shall have all such lower levels separated from the level of exit discharge by not less than Type II(111) construction.
Revise as follows:
19.1.6.6 All interior walls and partitions in buildings of Type I or Type II construction shall be of noncombustible or limited-combustible materials, unless otherwise permitted by 19.1.6.7.
19.1.6.7* Listed, fire-retardant-treated wood studs shall be permitted within non–load-bearing 1-hour fire-rated partitions.
19.1.6.6 Interior nonbearing walls in buildings of Type I or Type II construction shall be constructed of noncombustible or limited-combustible materials unless otherwise permitted by 19.1.6.7.
19.1.6.7 Interior nonbearing walls required to have a fire resistance rating of 2 hours or less shall be permitted to be fire retardant–treated wood enclosed within noncombustible or limited-combustible materials, provided such walls are not used as shaft enclosures.
19.1.6.8 Fire-retardant-treated wood that serves as supports for the installation of fixtures and equipment shall be permitted to be installed behind noncombustible or limited-combustible sheathing.
19.1.6.919.1.6.8 Each exterior wall of frame construction and all interior stud partitions shall be firestopped to cut off all concealed draft openings, both horizontal and vertical, between any cellar or basement and the first floor, and such firestopping shall consist of wood not less than 51 mm (2 in.) (nominal) thick or shall be of noncombustible material.
(Proposal 101-408 Log #192 SAF-HEA) page 101-147 of ROP on NFPA 5000 & NFPA 101
18.2.5.4 Any suite of rooms that complies with the requirements of 18.2.5 shall be permitted to be subdivided with non-fire-rated, noncombustible, or limited-combustible partitions or partitions constructed with fire-retardant-treated wood enclosed with noncombustible or limited-combustible materials.
Suites of Rooms – Partition Separation
(Proposal 101-406 Log #CP1222 SAF-HEA) page 101-145 of ROP on NFPA 5000 & NFPA 101
18.2.5.6.2.1.2 Sleeping suites shall be arranged in accordance with one of the following:
(a)* Sleeping suites shall allow for direct visual supervision of the suite by staff from a normally attended location within the suite; and cubicle curtains shall be permitted.
(b)* Interior walls and partitions within sleeping suites shall not exceed three-quarters of the floor-to-ceiling height or shall not exceed 8 ft (2440 mm) in height, whichever is less; and staff shall provide supervision from a normally attended location within the suite.
(c) Sleeping suites shall be provided with a total coverage (complete) automatic smoke detection system in accordance with 9.6.2.8 and 18.3.4.
Suites of Rooms - Size Limitations
18.2.5.6.2.3 Sleeping Suite Maximum Size.
18.2.5.6.2.3.1 Sleeping suites shall not exceed 5000 ft2 (460 m2) unless otherwise provided in 18.2.5.6.2.3.2.
18.2.5.6.2.3.2 Sleeping suites shall not exceed 7500 ft2 (700 m2) where both of the following are provided in the suite:
(a) Direct visual supervision in accordance with 18.2.5.6.2.1.2(a)
(b) Total coverage (complete) automatic smoke detection in accordance with 9.6.2.8 and 18.3.4
(Proposal 101-423 Log #497 SAF-HEA (18.3.6.3.10 and 19.3.6.3.10)) page 101-152 of ROP on NFPA 5000 & NFPA 101
18.3.6.3.10* Nonrated, factory- or field-applied protective plates, unlimited in height, extending not more than 1220 mm (48 in.) above the bottom of the door shall be permitted.
19.3.6.3.10* Nonrated, factory- or field-applied protective plates, unlimited in height, extending not more than 1220 mm (48 in.) above the bottom of the door shall be permitted.
(Proposal 101-435 Log #CP1220 SAF-HEA (18.7.5.1 and 19.7.5.1)) page 101-155 of ROP on NFPA 5000 & NFPA 101
18.7.5.1* Draperies, curtains, and other loosely hanging fabrics and films serving as furnishings or decorations in health care occupancies shall be in accordance with the provisions of 10.3.1 (see 18.3.5.6 ), and the following also shall apply:
(1) Such curtains shall include cubicle curtains.
(2) Such curtains shall not include curtains at showers.
(3) Such draperies and curtains shall not include draperies and curtains at windows in patient sleeping rooms.
For Reference:
10.3.1* Where required by the applicable provisions of this Code, draperies, curtains, and other similar loosely hanging furnishings and decorations shall be flame resistant as demonstrated by testing in accordance with NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films.
Retroactive Sprinkler Systems - Rejected
(Proposal 101-448 Log #220 SAF-HEA (19.3.5.1)) page 101-160 of ROP on NFPA 5000 & NFPA 101
Where required by 19.1.6, h Health care occupancies facilities shall be protected throughout by an approved, supervised, automatic sprinkler system in accordance with Section 9.7, unless otherwise permitted by 19.3.5.3.
Commentary:
The action on the referenced proposal requires retroactive sprinklering of nursing homes. There is inadequate substantiation to extend the
retroactive sprinkler requirement to hospitals.
Nursing Home Retroactive Sprinklers
(Proposal 101-449 Log #265 SAF-HEA (19.3.5.1)) page 101-160 of ROP on NFPA 5000 & NFPA 101
19.3.5 Extinguishment Requirements.
19.3.5.2 Buildings containing nursing homes shall be protected throughout by an approved, supervised automatic sprinkler system in
accordance with Section 9.7, unless otherwise permitted by 19.3.5.4.
19.3.5.3* The sprinkler system required by 19.3.5.1 or 19.3.5.2 shall be installed in accordance with 9.7.1.1(1).
Require Windows in Existing Smoke Barrier Doors – Rejected
(Proposal 101-459 Log #423 SAF-HEA (19.3.7.6)) page 101-164 of ROP on NFPA 5000 & NFPA 101
A vision panel of fire rated glazing or wire glass panel shall be required in each cross-corridor swinging door and at each cross-corridor horizontal sliding door in a smoke barrier.
Commentary:
The submitter has not substantiated a need for a retroactive/retrospective requirement for vision panels.