Q: Does section 184.108.40.206 of the 2012 Life Safety Code allow hazardous rooms to not be constructed with one-hour fire rated barriers if it is fully fire sprinklered? If healthcare oocupancies were considered new occupancies prior to the adoption of the 2012 Life Safety Code, are they now considered existing?
A: Section 220.127.116.11 of the 2012 LSC for existing healthcare occupancies says hazardous areas must be safeguarded by a fire barrier having a 1-hour fire rating, or it must be provided with an automatic sprinkler system. This is an ‘either/or’ issue. The hazardous room is either protected with 1-hour barriers, or it is protected with sprinklers. Section 18.104.22.168 says if the sprinkler option is used, then the hazardous area must be separated by smoke partitions. It is important to point out that this is for existing healthcare occupancies, and not for new healthcare occupancies.
Yes… If your facility was classified as a new healthcare occupancy last year under the 2000 LSC (i.e. prior to CMS adopting the new 2012 LSC on July 5, 2016), then it is classified as existing healthcare occupancy today under the 2012 LSC. However, this does not mean you can down-grade any feature of fire protection that was required under new occupancy requirements that is not required under existing occupancy requirements. Section 4.5.8 of the 2012 LSC says whenever any device, equipment, system, condition, arrangement, level of protection, is required for compliance with the LSC, such device, equipment, system, condition, arrangement, level of protection shall thereafter be maintained, unless the LSC exempts such maintenance. In other words: Once you are required to build something, you must maintain that for the life of the building, unless the new occupancy chapter no longer requires it.
So… If you built a new hazardous area last year and you constructed it to have 1-hour fire rated barriers, and it was protected with sprinklers because it was constructed under the new occupancy chapter requirements, you cannot down-grade the hazardous area to no longer have 1-hour fire rated barriers just because it is now classified as existing conditions. You must maintain that hazardous area under the new occupancy chapter requirements for the life of the building, or until the LSC no longer requires it for new conditions.
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.
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