ASHE News

Comments on TIAs affecting adoption of the 2012 editions of NFPA 101 and NFPA 99

Published:

Subject Matter: Article | Topics: Codes and standards

By Jonathan Flannery, CHFM, FASHE, MHSA, FACHE, Senior Associate Director of Advocacy

Tentative Interim Amendments (TIAs) are amendments to National Fire Protection Association (NFPA) standards made in between published editions of the standard. For example, after the 2012 edition of NFPA was published, NFPA adopted several TIAs. When the Centers for Medicare & Medicaid Services (CMS) recently adopted the 2012 editions of NFPA 101: Life Safety Code® and NFPA 99: Health Care Facilities Code, CMS also adopted several of the TIAs that NFPA had previously made. This article outlines those TIAs included in the new CMS Conditions of Participation for health care occupancies.

TIAs made to the 2012 edition of NFPA 101 and included in the CMS Conditions of Participation effective July 5, 2016

TIA 12-1:

Adds opening protectives requirements for half-hour elevator hoist ways within Table 8.3.4.2 Minimum Fire Protection Ratings for Opening Protectives in Fire Resistance-Rated Assemblies and Fire-Rated Glazing Markings.

Issued: August 11, 2011
Effective Date: August 21, 2011

ASHE comments: This TIA was corrected prior to the original publishing of the 2012 edition and therefore is included in NFPA 101-2012. The following note is provided before Table 8.3.4.2 in the Life Safety Code:

Table 8.3.4.2 was revised by a Tentative Interim Amendment (TIA). See page 1.


TIA 12-2:

This TIA clarifies requirements for two AC-powered photoelectric smoke alarms for residential or commercial cooking equipment used to prepare meals for less than 30 persons open to the corridor. Smoke alarms must be equipped with a silence feature, located between 20 and 25 feet from the cooking appliance, and are permitted to be located out of the cooking area. This also provides an option for a single system smoke detector to be installed. The TIA restricts the usage of a system smoke detector required by other sections of the code to be used to meet these requirements.

Issued: October 30, 2012
Effective Date: November 19, 2012

ASHE comments: The purpose of this TIA is to provide the option to allow a single system smoke detector and to provide appropriate coverage for a two smoke alarm option, to reduce the opportunity for nuisance alarm activation where cooking appliances are used. It also aims to provide increased reliability of the smoke alarms to detect a potentially dangerous situation and alert local staff.


TIA 12-3:

Revises allowable construction types for existing day care occupancies.

Issued: October 22, 2013
Effective Date: November 11, 2013

ASHE comments: Prohibits Type II (000) and Type III (200) construction in a two-story existing day care occupancy. These construction types were not permitted in the 2000 edition. This affects existing day care occupancies only. No major effect on health care organizations is anticipated.


TIA 12-4:

Revises requirements for door-locking arrangements to reference the correct section for sprinkler protection.

Issued: October 22, 2013
Effective Date: November 11, 2013

ASHE comments: This TIA corrects a mistake in the reference listed in Section 19.2.2.2.5.2 (3). The corrected reference to 19.3.5.7 provides the requirements for a sprinkler system to qualify in order to implement code-permitted exceptions based on a fully sprinklered building.

TIAs to the 2012 edition of NFPA 99 that were adopted by CMS

TIA 12-2:

Adds Chapter 9 HVAC. This chapter applies only to new facilities and altered, renovated, and modernized portions of existing systems.

Issued: August 11, 2011
Effective Date: August 21, 2011

ASHE Comment: This TIA was corrected prior to the original publishing of the 2012 edition and therefore is included in NFPA 99-2012. The following note is provided following Chapter 9 of the Life Safety Code:

Chapter 9 was added by a Tentative Interim Amendment (TIA). See page 1.


TIA 12-3:

Removes alternate source requirements from critical branches within a Type 3 EES.

Issued: August 9, 2012
Effective Date: August 29, 2012

ASHE Comments:Without this TIA, the critical branch of a Type 3 essential electrical system would be required to have an alternate source of power.


TIA 12-4:

Clarifies which portions of Chapter 5 apply to existing facilities.

Issued: March 7, 2013
Effective Date: March 27, 2013

ASHE Comments: As NFPA 99-2012 was originally published (without this TIA), not all of the requirements for Category 1 support gas systems would be retroactive to existing systems. Many important requirements for Category 1 systems would not apply to existing systems. For example, there would be no requirement for labeling of cylinders and cryogenic containers. There would be no requirements for existing systems in Category 2 and Category 3 systems. This TIA corrects that and ensures all requirements apply.


TIA 12-5:

Removes the requirement that means are employed to ensure that additional devices or nonmedical equipment cannot be connected to the multiple outlet extension cord after leakage currents have been verified as safe when using flexible connections to receptacles for portable equipment.

Issued: August 1, 2013
Effective Date: August 20, 2013

ASHE Comments: As published, NFPA 99-2012 10.2.3.6 (5) makes it virtually impossible to use a multiple outlet connection, For example, if 10.2.3.6.(5) had remained in NFPA 99-2012 without a TIA, if a multiple outlet connection is used for infusion pumps, the total leakage would need to be measured at the plug of the multiple outlet each time an IV pump is plugged in, making it virtually impossible to manage. This TIA makes it possible to use multiple outlet connections based on the requirements of 10.2.3.6 (1) – (4).


TIA 12-6:

Clarifies limitations to ignition sources in respiratory care areas.

Issued: March 3, 2014
Effective Date: March 23, 2014

ASHE Comments: This TIA adds clarity to limitations of ignition sources in respiratory care areas. These limitations are necessary to reduce the risk of fires in oxygenated environments.