Designing with NFPA 101-2015

NFPA 101: Life Safety Code dictates a great deal for all building types, including egress, features of fire protection, sprinkler systems, alarms, emergency lighting, smoke barriers, and special hazard protection.

By William E. Koffel, PE, FSFPE, Koffel Associates Inc., Columbia, Md. February 1, 2016

Learning objectives:

  • Examine some of the more significant changes between the 2015 and 2012 editions of NFPA 101.
  • Recall that revisions are ongoing, and the 2018 edition is in progress. 

The 2012 edition of NFPA 101: Life Safety Code has received considerable attention due to the fact that the Centers for Medicare & Medicaid Services (CMS) has published a notice of proposed rulemaking to adopt the 2012 edition. However, the most current edition of NFPA 101 is the 2015 edition, which has been adopted by some states. Furthermore, newer editions of the code are considered refinements of previous editions and, as such, may be used as part of the justification for an equivalency to previous editions of the code (see 1.4 and A.1.4).

Horizontal exits

Horizontal exits are not required by the code. Rather, they are a design alternative that allows one to reduce the number of exit stairs and doors to the exterior. This is often done in areas where meeting the required travel distance or exit capacity presents challenges due to the area of the floor (or building) or the occupant load to be served. By reducing the number of openings required in exterior walls due to fewer traditional exits being required, horizontal exits can assist in addressing security considerations. In addition, horizontal exits often are used in health care occupancies, especially when multiple occupancies are involved, to allow patients to be moved horizontally to an area of refuge. Likewise, horizontal exits can be used in correctional occupancies to allow occupants to be moved horizontally to a secure area of refuge. Most of the changes in the 2015 edition offer clarity to existing code requirements, some of which were often overlooked or misunderstood.

NFPA 101 does not normally regulate the fire-resistance rating of exterior walls, but certain horizontal exits represent an application in which the rating may be regulated. To reduce the likelihood that a fire can spread beyond the fire barrier constituting the horizontal exit, the exterior wall at the intersection with the fire barrier serving as the horizontal exit may be required to have a fire-resistance rating. Where the horizontal exit intersects with exterior walls at an angle of less than 180 deg, the exterior wall shall have a fire-resistance rating within 10 ft of the horizontal exit. Previous editions of the code required the exterior wall on each side of the horizontal exit to have a fire-resistance rating of at least 1 hour. New to the 2015 edition: An option has been added to permit the exterior wall on one side of the horizontal exit to have a fire-resistance rating of at least 2 hours for a distance of at least 10 ft from the intersection (Section A provision has been added by which the fire barrier serving as a horizontal exit does not need to continue beyond the lowest level to provide discharge to the exterior (Section

The fire barrier is permitted to terminate at the lowest level providing discharge to the exterior when the levels below are separated by construction with a fire-resistance rating of at least 2 hours and the levels below do not have a horizontal exit.

From an engineering perspective, items that are often overlooked regarding horizontal exits include the need for manual fire alarm boxes and standpipe hose connections on both sides of the horizontal-exit fire barrier. In addition, where two opposite swinging doors are provided at horizontal exits, exit signs shall be provided on both sides of the horizontal exit and the signs shall indicate the door that swings in the direction of egress travel. This is often accomplished by not locating the signs in the center of the corridor. Note that these provisions are not new to the 2015 edition but must be considered when evaluating if horizontal exits are part of a viable egress strategy.

Elevators for occupant-controlled evacuation

Provisions have been deleted that address status indicators displayed in the lobbies for occupant evacuation elevators. However, it should be noted that many of the requirements regarding status indicators are covered by American Society of Mechanical Engineers (ASME) A17.1. These particular provisions in ASME A17.1 are specifically referenced in paragraph of the 2015 edition of NFPA 101.

Occupancy separations and atria

In the past, where the separated-occupancy concept was used, the occupancies needed to be separated by fire barriers. The 2015 edition allows an atrium to serve as an occupancy separation on a story-by-story basis, provided the atrium is separated from other areas by construction equivalent to the requirements for smoke partitions and the use of the provision is permitted by the applicable occupancy chapter (Section The doors in the smoke partitions are required to be provided with positive-latching hardware. Lastly, the provisions require that all other requirements for new atria are met.

Video monitoring of stairs

New high-rise buildings with an occupant load of 4,000 or more are required to be provided with real-time video monitoring of the stairs (Section 11.8.8). Under this new requirement, video monitoring is to be provided at a level at which the stair doors discharge and shall be arranged to capture people discharging from, entering, or passing through the discharge level. Additional video monitoring equipment is required at intervals not exceeding five stories so that the descent, ascent, and entry landings can be monitored remotely. The video cameras also may be used for video-image smoke detection provided the requirements of NFPA 72: National Fire Alarm and Signaling Code are met. Where the video cameras are integrated with the security system, the security system shall comply with NFPA 730: Guide for Premises Security.

It is recognized that installing the video monitoring equipment in the stairs may result in additional penetrations in the exit enclosure. Although related changes were not made to the requirements addressing penetrations of exit enclosures, an existing annex note indicates that penetrations involving wiring serving electrical equipment in the stairways, such as security systems, should be permitted if properly protected (Section A. (10)(b)).

Health care occupancies

Numerous changes were made to the occupancy chapters in the 2015 edition, but several significant changes were made that specifically impact health care occupancies. Several changes were made to the suite provisions, many of which were primarily clarifications of the changes made over the past few revision cycles.

However, the maximum size of a patient-care, nonsleeping suite was increased from 10,000 sq ft to 12,500 sq ft if the suite is protected with fast-response sprinklers or complete smoke detection. Note that for new construction, fast-response sprinklers are already required. If the suite is protected by both fast-response sprinklers and complete smoke detection, the maximum suite size is increased to 15,000 sq ft. The increase is consistent with the increases permitted for patient-care sleeping suites in the 2012 edition and is based, at least in part, on the increased area required by newer editions of the Facility Guidelines Institute (Section 18/

In addition to suite size, revisions were made as to when smoke barriers are required on stories below stories containing a health care occupancy (Section The 2015 edition eliminates the requirement for smoke barriers on any story that does not contain a health care occupancy and is located beneath a health care occupancy. This is a relaxation from the 2012 edition, which required smoke barriers on the level below the health care occupancy unless the story below only contained mechanical equipment. This change is especially helpful as more health care facilities include underground parking.

With respect to long-term care facilities, additional changes have been made to permit the facility to have a more home-like appearance. Language has been added that the smoke alarms required when kitchens are open to the corridor may be located outside of the kitchen area to meet the 20-ft separation from cooking equipment requirement.

Ambulatory health care occupancies

In the past, the two chapters that addressed new and existing ambulatory health care occupancies (Chapters 20 and 21, respectively) were written in a form that used business occupancy requirements as the base requirements, which were then modified by Chapters 20 and 21. As such, the user of the code needed to consult both the business occupancy chapters and the ambulatory health care chapters to find the requirements.

In the 2015 edition, the two chapters have been written in a more standalone format and no longer require the user of the code to refer to the chapters addressing business occupancies. It should also be noted that the occupant load factor for ambulatory health care occupancies was revised from 100 sq ft/ person to 150 sq ft/person. While this was initially done in expectation of a change in the occupant load factor for business uses, subsequent research conducted by the Fire Protection Research Foundation has supported this increase.

Life safety evaluation

When a life safety evaluation is required by the code, such as for festival seating, the provisions for the evaluation have been expanded. Details have been added as to what should be in the building systems document and the life safety management document. For example, the building systems document specifically requires a discussion regarding the principal fire and life safety features and strategies including, but not limited to, the various fire protection systems, emergency power and lighting, emergency elevator operations, and public address systems. The life safety management document addresses issues including, but not limited to, emergency planning, first aid and medical plans, emergency communication plans, operating procedures for risks identified in a risk assessment, and first responder plans (Section 12/13.4.1).

Moving forward

The revision cycle resulting in the 2018 edition of NFPA 101 has already commenced, and there is a number of potential changes that may impact consulting engineers. It should be noted that these potential changes are not final and they are still subject to correlating committee action, public comments, and association action. However, the changes of interest include:

  • Adding a requirement for a risk assessment, as required by NFPA 72 for mass notification systems, be performed for new buildings that are part of a college or university system. The originally proposed language is likely to be revised during the public comment period based upon task group activity and public comments. However, the intent is to ensure that the risk assessment is performed when needed. The concern is that decisions are being made to not provide a mass-notification system prior to preparing the risk assessment. Because the requirement currently exists in the requirements for mass notification systems in NFPA 72, if a decision is made not to provide such a system, the risk assessment would not be prepared.
  • Adding language to better address incidents such as active-shooter incidents in various occupancies. Again, the language being developed during the first revision phase is likely to be revised based upon public comments and task group activity. This effort may also result in revisions to the scope of NFPA 101.
  • Increasing the maximum area of smoke compartments in hospitals containing single-bed patient rooms from 22,500 sq ft to 40,000 sq ft. Similar to the rationale for increasing suite sizes, the increase in smoke compartment size is also based upon increased area requirements in newer editions of the Facility Guidelines Institute. This change is already in the 2015 edition of the International Building Code (IBC), but the increase was not accepted during the last revision cycle for NFPA 101. Related to this, changes may be appropriate in some other NFPA standards, such as NFPA 99: Health Care Facilities Code, in which fire alarm zones and gas cylinder quantities have typically been based upon smoke compartment size.
  • Marking of fire barriers, smoke barriers, and smoke partitions may be required in the 2018 edition of NFPA 101. While such marking is currently required by the IBC, it has not been accepted for inclusion in NFPA 101. It should be noted that this change has been accepted during technical committee meetings, only to fail the committee ballot. A similar outcome could occur this revision cycle.

For additional information regarding other changes to the 2015 edition, or to monitor or submit public comments regarding proposed revisions to the 2018 edition of NFPA 101, visit

William E. Koffel is president of Koffel Associates. He is chair of the NFPA Correlating Committee on Life Safety and a member of numerous NFPA technical committees. He is a member of the Consulting-Specifying Engineer editorial advisory board.