Protecting a vulnerable population

Under the International Building Code (IBC), senior assisted-living facilities usually fall under the requirements for institutional or residential occupancies based on their number of residents and level of care provided. But what happens when a jurisdiction requires conformance with the NFPA Life Safety Code (NFPA 101), either for licensing or as an ongoing maintenance code?

By James Kaspar, Associate, Rolf Jensen & Assocs., Phoenix February 1, 2008

Under the International Building Code (IBC), senior assisted-living facilities usually fall under the requirements for institutional or residential occupancies based on their number of residents and level of care provided.

But what happens when a jurisdiction requires conformance with the NFPA Life Safety Code (NFPA 101), either for licensing or as an ongoing maintenance code?

Local jurisdictions can apply even more restrictive requirements than those found in NFPA 101, but as a starting point, let’s examine some major fire protection and safety requirements for senior assisted-living facilities in the current Life Safety Code.

We must begin by looking at how the NFPA defines such occupancies in terms of size and classification. Senior assisted-living facilities cover a wide range of occupancies and associated levels of care. However, there are two primary categories as defined by the NFPA. Per section of the 2006 edition of the Life Safety Code, a nursing home is defined as “a building or portion of a building used on a 24-hour basis for the housing and nursing care of four or more persons who, because of mental or physical incapacity, might be unable to provide for their own needs and safety without the assistance of another person.”

Nursing homes often fall under the same strict codes and standards as hospitals and other ambulatory care facilities due to the level of services they provide, and typically are seen as separate occupancies from assisted-living facilities.

By contrast, a residential board-and-care occupancy receives the following definition from chapter 3 of the Life Safety Code: “A building or portion thereof that is used for lodging and boarding of four or more residents, not related by blood or marriage to the owners or operators, for the purpose of providing personal care services.” Appendix A. expands this definition through example to include “assisted-living facilities” and “group housing for the elderly that provides personal care, but not nursing care.” By definition, most senior assisted-living facilities fall under the classification of residential board-and-care occupancies with respect to the Life Safety Code and are referred to as such throughout this article.

A history of assisted living

From 1990 to 2003, the NFPA documented 23 multiple-death fires (three or more fatalities) in board-and-care occupancies for a total of 122 deaths. NFPA’s analysis of these fires reveals that the major contributing factors included a lack of automatic sprinklers, unprotected vertical openings, doors that open to the room of fire origin, and ineffective staff or resident training or response. Based on the survey results, NFPA re-evaluated the methodology of the existing Life Safety Code as part of the development of NFPA 5000 Building Code.

Prior to the 2003 Life Safety Code, requirements for board-and-care facilities were based primarily on the occupant’s evacuation capability—the amount of time required to evacuate the building during a fire drill. When first classified, a building would receive a capability rating on a three-tiered scale:

  • Prompt for evacuation times up to 3 min

  • Slow for evacuation times above 3 min but less than 13 min

  • Impractical for facilities with evacuation times of 13 min or more.

The problem with this approach is that as residents increase in age, their capabilities change. Decreased mobility and a higher concentration of residents using assisted devices, such as walkers and wheelchairs, can lead to a resident population moving from a “prompt” rating to a rating of “slow” or even “impractical.” The onset of mental disorders and diseases, such as Alzheimer’s, also creates logistical strains on the staff during an evacuation. Even the time of day that a fire occurs has a larger impact on board-and-care facilities due to the increased use of nightly medications and drug therapy.

Common path of egress travel is the portion of exit access the occupants must travel before a choice of two separate paths of egress are available.
Source: NFPA

Even though this evacuation classification is no longer the primary method of determining applicable standards, egress capability is still used as a sub-classification for assessing code requirements.

Typical egress for a floor without “defend-in-place” compartments available for evacuation of occupants.
Source: NFPA

The 2006 update

Moving on to the updated 2006 Life Safety Code, chapters 32 and 33 are based on two main concepts:

  1. Larger buildings are more difficult to evacuate than smaller buildings and require more built-in fire protection.

  2. Occupants who are more difficult to evacuate require more built-in fire protection than occupants who are more easily evacuated.

As intrinsically simple as these statements sound, the impact on fire protection and life safety strategies is profound. On the topic of egress, the current 2006 code uses more of a “defend-in-place” approach than the pre-2003 codes. The defend-in-place concept uses smoke and fire barriers in combination with automatic sprinkler systems to divide a facility into isolated compartments. This allows the building’s occupants to be moved to a safe location within the structure while the fire department responds to the fire in a different area. Traditional egress designs centered on evacuation. But similar to hospitals, board-and-care facilities benefit from the “defend-in-place” approach, which accommodates the limited or restricted mobility of residents.

Rated fire and smoke barriers to create multiple compartments allows partial evacuation or relocation of occupants.
Source: NFPA

To further define the fire protection for a building, the code requires classifying the occupancy based on the total number of residents being housed in each building. Small facilities provide accommodations for as many as 16 residents and are covered under NFPA 101 sections 32.2 and 33.2 for new and existing facilities. The large facility designation, which covers all residential board-and-care occupancies designed to accommodate more than 16 residents, is covered in sections 32.3 and 33.3 of the Life Safety Code. A principle distinction between small and large board-and-care facilities is that large facilities have specific height and area limitations based on construction type—similar to chapters 5 and 6 of the IBC.

As an example, a new, large residential board-and-care facility of 1-hour fire resistance rated construction (Type II -111) is allowed to be built as high as 3 stories with a maximum area per floor of 19,000 sq. ft. By contrast, an existing facility of similar construction can be 6 stories high, provided that the building egress capability is rated as either “prompt” or “slow.” A caveat is that a change to the egress capability rating of a building to one of a lesser rating requires the building to adhere to the requirements and standards of the new rating for a newly constructed building. This is especially true if the rating drops to “impractical” for a large board-and-care facility. Code would then require the facility to adhere to chapter 19 for healthcare occupancies. The impact of this change in egress capability has the potential for distinct repercussions over the course of a facility’s lifecycle.

Other considerations

Beyond construction type, height, and area limitations, both small and large board-and-care facilities have other similarities and differences within the current code. Fire protection is fairly similar in application regardless of the size classification a facility falls under. Fire sprinklers in new construction forboard-and-care occupancies (regardless of size) are required by code to be either quick response or residential-type sprinklers, while existing small facilities are not required to have an automatic sprinkler system installed if each individual sleeping area has two fully separate means of escape.

It is generally accepted under current life-safety codes that fires typically occuring in board-and-care occupancies are similar in nature to those in other residential occupancies. As such, NFPA 13R and NFPA 13D for sprinkler systems are considered acceptable for use in small facilities of both new and existing construction. NFPA 13R-based systems remain limited to use in facilities with 4 or fewer stories, and the Life Safety Code does not mandate any major provisions for their use in this type of occupancy.

Maximum travel distance, measured from the most remote point in a building, along the natural unobstructed path of travel to exit. Source: NFPA

Designing an NFPA 13D sprinkler system, on the other hand, requires two major provisions for use in board-and-care facilities with respect to the Life Safety Code. The first requires that valve supervision be provided in the form of either electrical supervision, audible valve closure alarms, or a separately listed shutoff for both domestic and sprinkler systems, in addition to a domestic-only shutoff. The second requirement is to increase the water supply from the 10 min standard to 30 min of water to ensure sprinkler operation throughout the anticipated evacuation timeframe.

Though these standards are applicable for large residential board-and-care facilities, the inherent story height limitations of NFPA 13R and 13D sprinkler systems make them less likely to be used instead of a NFPA 13 sprinkler system.

To engineer a safe environment for senior citizens, form follows function. Hallways, ramps, stairs, doorways, and floor surfaces must be designed with the expectation of increasingly reduced mobility. Oxygen tanks and other medical equipment, essential to sustaining life, can make navigating corners and turns that much more difficult. Furniture and other decorative accents provide an ambiance of comfort, yet 60 in. of clearance must be maintained throughout all corridors in new construction. Designers also should be aware that board-and-care occupancies have specific means of egress requirements from NFPA 101, particularly those facilities that fall under the “large” classification.

Another critical concept in the design of residential board-and-care facilities is time—it is the key to survival. Residents must have the time to recognize an emergency and time to respond within their capabilities.

Adequate time to recognize and identify the emergency most often arises from working smoke and fire alarms. Smoke detection systems are required for all types of new construction and are required to be installed in the sleeping rooms of existing structures. One notable exception is that existing small board-and-care facilities with an approved fire protection system can omit the requirements for smoke alarms in accordance with NFPA 101-, provided that smoke alarms are installed in each individual sleeping area.

Protection systems must allow enough time to respond to an emergency in order to control a fire before it spreads. This also re quires a means of egress that is tailored to meet the needs of the residents. In new construction of large facilities, corridors used as part of the means of egress system are required to have a 30-min fire rating. Travel distances are limited to 250 ft as a maximum and common paths of travel can be no more than 75 ft. Interior stairs, as are used for means of egress, fall under the general requirements of chapter 7.2. For large, existing construction, travel distances from a corridor door to the nearest exit cannot exceed 100 ft and the overall maximum travel distance cannot exceed 200 ft.

Small facilities, on the other hand, have no travel distance limitations specific to the occupancy within the current code as long as they meet the minimum requirements for number and arrangement of exits.

While the requirements of the Life Safety Code are often similar to those of the IBC, as a designer and engineer, you may one day thank the stars that you learned both standards.

Year Location Fatalities
Source: NFPA, Fire Incident Data Organization (FIDO)
Analysis of these fires reveals that the major contributing factors included a lack of automatic sprinklers, unprotected vertical openings, doors that open to the room of fire origin, ineffective staff or resident training, and ineffective response. Accordingly, NFPA re-evaluated the methodology of the existing Life Safety Code.
1990 Georgia 4
1990 Texas 4
1990 Bessemer, Ala. 4
1990 Wisconsin 3
1991 Colorado Springs, Colo. 10
1992 Detroit 10
1993 Texas 3
1994 Alabama 6
1994 Broward County, Fla. 6
1995 Mississauga, Ontario 8
1995 Oregon 4
1995 California 3
1995 Michigan 3
1996 Connecticut 3
1996 California 3
1996 Laurinberg,N.C. 8
1996 Shelby County, Tenn. 4
1996 Ste. Genevieve, Quebec 7
1996 Pennsylvania 4
1997 Harveys Lake, Pa. 10
1998 Arlington, Wash. 8
2000 Pennsylvania 3
2003 California 4
Author Information
James Kaspar is an associate in the Phoenix office of Chicago-based Rolf Jensen & Assocs. Inc.