Regulations, Codes & Standards Q&A: Parking garage underneath healthcare occupancy

Q: Can you have a parking garage under a health care occupancy/patient sleeping areas, that does not have smoke separations but does have a 2-hour fire rated barrier between the floors? This is a project in the planning stages. Currently the floor serves administrative offices and will be converted to a patient floor.

A: I am not aware of any reason in the Life Safety Code that would prevent you from having a parking garage underneath a healthcare occupancy, provided you have the proper 2-hour fire rated separation barrier. A parking garage is required to be a Storage occupancy according to 3.3.188.15 of the 2012 LSC, so there must be a 2-hour fire-rated barrier separating the parking garage and the healthcare occupancy.

Section 18.3.7.2 (5) is clear that open-air parking structures protected throughout by a sprinkler system does not have to be subdivided into two or more smoke compartments. Since it is new construction, the entire hospital, including the parking garage, would have to be fully sprinklered.

As always, check with your state and local authorities to see if they have more restrictive regulations.

Brad Keyes, CHSP, is the owner of KEYES Life Safety Compliance, and his expertise is in the management of the Life Safety Program, including the Environment of Care and Emergency Management programs.