By Chad Beebe, AIA, FASHE, ASHE Deputy Executive Director
Nearly 100 ASHE members attended important NFPA meetings last week to speak about and vote on important proposals being considered for the next editions of NFPA 101 and NFPA 99. Because of these members and others from the health care field who are NFPA voting members, nearly all proposed changes to improve the codes passed.
ASHE thanks all members who voted at the meeting—and their health care organizations who support their attendance—for taking the time to help positively influence code changes.
One important victory was the expansion of smoke compartment maximum space limits to 40,000 square feet from the current 22,500 square feet. This move provides hospitals with greater flexibility in creating single patient rooms, which improve patient satisfaction and reduce health care-associated infections. Details about this change and others that will take effect in the 2018 editions are outlined in this article.
Importance of code improvements
The changes voted on during the NFPA Technical Meeting in Boston last week relate to the 2018 editions of NFPA 101 and NFPA 99.
Although these changes will not be enforced until adopted by the Centers for Medicare & Medicaid Services (CMS), they still serve two valuable purposes. First, the code development process is an ongoing process. Even though this edition may not be adopted by CMS as a Condition of Participation, a future edition that includes these changes will. Second, there have been many instances in which later editions of the codes adopted provide clarification on the intent of the code. Authorities often will give deference to those changes when making a decision on a situation; this deference is allowed by each code because NFPA gives the authorities having jurisdiction the ability to deviate from the code requirements when necessary and to interpret the code accordingly.
Changes to NFPA 99: Health Care Facilities Codes
- Minor changes were proposed to provide testing criteria for furnishing and mattresses, which is consistent with industry standards. ASHE supported these proposals, and NFPA membership voted to approve.
- Several ASHE members testified in support of the continuation of provisions that allow either water mist, clean agent, or CO2 fire extinguishers. Currently, many facilities are cited by surveyors when they only have a water mist or clean agent extinguisher within an operating room because reports have recommended that CO2 extinguishers be available in operating rooms (although those reports do not recommend their use as a first line attack on a fire intimately involved with the patient). Members testified that it should be up to the facility to decide which type of extinguisher they need based on their policies on responding to surgical fires. For example, if a facility chooses to have a clean agent extinguisher, they should no longer be cited for not having a CO2 extinguisher. Annex language does not recommend the use of a dry chemical extinguisher in the surgical department. ASHE supported the provision to allow facilities this flexibility, and the NFPA membership agreed. This effort allows facilities to continue to direct resources to patient care and avoid an added impact of an estimated $7.8 million nationwide to provide additional extinguishers.
- Another proposal would have eliminated a provision that allows facilities to use risk assessments to exempt health care from the requirement to provide audible and/or visual alarm notification appliances. The risk assessment option in NFPA 99 may not be consistent with current editions of NFPA 101 but is a circumstance in which one code document needs to move forward with the provision before the other can follow. ASHE opposed the proposal, and NFPA membership agreed. This may help in conversations with authorities having jurisdiction who may want to require strobe devices in sensitive areas such as NICUs, where audible or visible alarms can have negative effects on patients. This effort has a direct patient care impact and potentially saves a number of effects on vulnerable patient populations.
Changes to NFPA 101: Life Safety Code®
- One proposed change to NFPA 101 would have eliminated requirements for integrated fire protection system testing for new health care occupancies and existing high rise health care facilities as well as new ambulatory health care occupancies (ACHOs) and existing high rise AHCOs. Although ASHE supports integrated testing, and it is likely occurring on a routine basis in health care facilities today, there were several ambiguous requirements found in the referenced standard NFPA 4. Periodic testing was undefined and a requirement to test when any modification of the system is moved could be interpreted as extreme in instances in which a single device is simply moved. ASHE supported the change to eliminate testing because of the concerns about referenced standard NFPA 4. Unfortunately the submitter withdrew the motion on this issue and ASHE members were unable to testify about this change. ASHE was made aware that the submitter and a technical committee will be working on a Tentative Interim Amendment that may address several of their concerns, although ASHE is unsure how these changes could effect health care facilities. Removing this requirement potentially saves each facility affected about $150,000 annually, based on 1 FTE to manage and coordinate testing or contracting this service and the cost to perform the work periodically.
- Two proposed changes to NFPA 101 would have stopped efforts to expand the maximum compartment size to 40,000 square feet from the current 22,500 square feet for new hospitals using a single bed room concept. These proposals would have created conflict with other codes, including NFPA 5000 and the International Building Code, both of which allow 40,000 square feet smoke compartments. ASHE opposed these proposals, noting that as health care organizations aim to provide more single bed rooms, it becomes nearly impossible to comply with room size requirements; outside window requirements; and infection prevention considerations while keeping a compartment size to 22,500. NFPA members voted against the proposals, so the maximum smoke compartment size that will be allowed under the 2018 edition of the Life Safety Code will be 40,000 square feet. This supports single patient rooms, which promotes patient satisfaction and reduces health care associated infections.
- ASHE supported a motion that would continue to allow rooms with boiler, mechanical, and electrical equipment to be used for some storage when the room is protected per NFPA 101 requirements for storage rooms. However, NFPA members voted against the motion. The 2018 edition will limit health care facilities in the storage of items not directly related to the equipment within that room. Filters, belts, and materials used to maintained the equipment will still be allowed; however if not specific to the exact equipment in the room, the facility will risk being cited. For example, extra filters or belts that are used on other equipment—not equipment within the room—would not be allowed. Storage is typically at a premium in health care facilities and may require displacement of other space to accommodate the materials. At a U.S. average of $400 per square foot of health care space, a typical hospital may have to relocate 500 square feet of storage, costing up to $200,000.
Preparing for the next code development cycle
Three years from now, another NFPA Technical Meeting will be held to vote on proposals to NFPA 101 and NFPA 99. ASHE will be encouraging members to attend that meeting so that health care is represented when votes on code proposals are held.