Adopting NFPA 101 in health care buildings

Explore the top 10 things to know about the 2012 edition of NFPA 101 for hospitals and health care facilities.


Learning objectives:

  • Identify the impact of the adoption of the 2012 edition of NFPA 101: Life Safety Code by Centers for Medicare & Medicaid Services on health care design.
  • Know the differences in the various editions of NFPA 101.

In May 2016, the Centers for Medicare & Medicaid Services (CMS) released its final rule amending fire-safety requirements for certain Medicare and Medicaid participating health care facilities. The goal of the adoption was to reduce life safety risks for patients and caregivers who occupy these facilities while at the same time modernizing requirements to reflect current health care needs. Effective July 5,, 2016, health care facilities must comply with the provisions of the 2012 edition of the NFPA 101: Life Safety Code and the 2012 edition of the NFPA: 99 Health Care Facilities Code, with some exceptions. Certain sections have been excluded from adoption, most notably Chapter 7 of NFPA 99 on information technology equipment. Previously, the 2000 edition of NFPA 101 and the 1999 edition of NFPA 99 were the adopted codes used for fire protection and life safety purposes in health care occupancies.

Since multiple code-revision cycles occurred between adopted versions, facilities may face some challenges in attempting to meet CMS requirements. Ten of the most salient differences are explored that should be considered between these code editions for health care occupancies. This is not an exhaustive list, and further differences exist and must be considered when attempting to comply with this CMS rule.

Figure 1: Power doors complying with NFPA 101-2012, Section, are not required to latch provided the doors can be kept closed if a force of 5 lb is applied in the direction to open the door (swinging or sliding). Courtesy: JENSEN HUGHES1. Risk assessment

The 2012 edition of NFPA 99 requires using a risk-based approach to categorize and design building systems. This assessment is required to be a formal and documented assessment. The code defines four categories (Category 1 to Category 4) based on the effect of system/equipment failure on the well-being of patients and caregivers: 

  • Failure of Category 1 systems is likely to cause "major injury or death."
  • Failure of Category 2 systems is likely to cause "minor injury."
  • Failure of Category 3 systems is likely to cause "discomfort."
  • Failure of Category 4 systems is likely to have "no impact."

While CMS will confirm that facilities are using this type of risk assessment, it is not required that facilities submit a formal assessment to CMS for review.

2. Sprinkler protection

Under the new requirements in NFPA 101-2012, all existing high-rise health care occupancies must be fully protected by an approved, supervised automatic sprinkler system. All new health care occupancies are required to be fully sprinkled already, but this requirement now requires existing buildings to retroactively become fully sprinklered. Retroactive provisions can be difficult and costly to comply with, which is why a phase consisting of a period of 12 years is allowed to provide the required sprinkler system. This change in sprinkler requirements has also impacted the scoring system contained in NFPA 101A for Fire Safety Evaluation Systems (FSES). This change may cause facilities currently using an FSES for justification of an equivalency to no longer achieve a passing score.

3. Building rehabilitation

Health care occupancies are often renovating areas to update for modern medical delivery. In the past, designers often struggled with which components of a renovation must comply with the "new" occupancy requirements and which could comply with the "existing" occupancy requirements. To rectify this, the 2012 edition of NFPA 101 defines explicit criteria relating to building rehabilitation in Chapter 43. In NFPA 101, rehabilitation activities are classified into the following categories: 

  • Repair
  • Renovation
  • Modification
  • Reconstruction
  • Change of use/occupancy
  • Addition.

Each type of activity requires compliance to different requirements. Repairs and renovations only require adherence to the requirements for "existing" occupancies. Modifications require that any new elements follow the "new" occupancy requirements of the code. Reconstruction and addition require that the entire work area meet the requirements of the new occupancies. Changes of use only require adherence to existing occupancy requirements except where hazardous areas are created, in which case the new occupancy requirements apply. Changes of occupancy are dependent on the level of hazard of the "new" occupancy compared to the "existing" occupancy of the building. If the hazard is lesser, then existing requirements govern the area except for life safety features, such as sprinkler, fire alarm, and hazardous areas. If the hazard is greater, then the new occupancy requirements apply.

Figure 2: Additional inspection, testing, and maintenance requirements have been imposed on many hospital features—including doors—as a result of CMS’s adoption of newer editions of NFPA 101 and NFPA 99. Courtesy: JENSEN HUGHES4. Inspection, testing, and maintenance

The adoption of the 2012 editions of NFPA 101 and NFPA 99, as well as the referenced NFPA 25 and NFPA 72 standards, dictates new criteria for inspection, testing, and maintenance (ITM) for various fire protection-related features. Some requirements have been more restrictive over the recent code-revision cycles, while some have been made less restrictive over the same period. Additional requirements have been put in place for features including receptacles, doors, and isolation modules. To ensure that ITM requirements are met, it is important to make sure to test all required systems, maintain accurate and organized records, and have qualified personnel where they are required. For example, fire-resistance-rated doors now require an annual inspection conducted and documented by qualified personnel.

5. Suite criteria

The 2012 edition of NFPA 101 provides several new criteria for suites. The updates provide many more requirements to meet, but they also provide for more flexibility in design to more effectively address the way medical care is currently delivered. The non-patient care suite, defined as "a suite within a health care occupancy that is not intended for sleeping or treating patients," has been introduced to distinguish such spaces from suites that are used for patient care. Non-patient care suites can follow the egress provisions for the primary use and occupancy of the suite.

Suite-arrangement criteria have also been introduced. Suites must be separated from the remainder of the building with the same level of protection as afforded for corridors, by using partitions and positively latching doors that limit smoke transfer. However, the criteria also provide for additional flexibility by allowing for egress from one suite to another and not regulating circulation spaces within suites as corridors. Therefore, circulation spaces are not required to meet the more stringent requirements of corridors.

Sleeping suites greater than 1,000 sq ft in area and non-sleeping suites greater than 2,500 sq ft require two exit access doors. In suites where only one exit access door is required, the door must open directly into a corridor. In suites with two exit access doors, one must open directly into a corridor while the other may open into an adjacent suite, given suite-separation requirements are met, or into an exit stairwell, exit passageway, or the exterior.

Within a suite, the maximum travel distance to an exit access door is limited to 100 ft but may pass through more than one intervening room. This provision applies to both sleeping and non-sleeping suites. This is slightly less restrictive than the 2000 edition requirements, which limited travel distance in non-sleeping suites through multiple intervening rooms to only 50 ft.

Allowable suite sizes have increased because of this rule adoption. New sleeping suites have increased in maximum size from 5,000 to 7,500 sq ft, or to 10,000 sq ft with direct visual supervision and smoke detection. Existing sleeping suites still have a maximum area of 5,000 sq ft. The addition of a sprinkler system and smoke detection or quick-response sprinklers raises the allowance to 7,500 sq ft, while the addition of direct supervision, smoke detection, and quick-response sprinklers raises the allowance to 10,000 sq ft. Both existing and new non-sleeping suites still have a maximum allowable area of 10,000 sq ft. It should be noted, however, that certain larger suites may require three or more exits to meet other applicable egress requirements.

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