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Mother Nature is in the midst of unleashing a brutal, one-two punch unlike anything I can remember. Our thoughts are with all those in Texas and Louisiana who were impacted by Hurricane/Tropical Storm Harvey and anyone in Hurricane Irma's path. When I came up with the idea for this post, I had no idea that the monstrous Hurricane Irma would be poised to make landfall. If you’re in Irma’s path, please stop reading and start making preparations for this historic storm to protect yourself and your family. If you’re in an evacuation zone, the time to get out is now.
When the winds die down and the flood waters recede, the clean-up and rebuilding will commence. It is undoubtedly already under way in places like Houston and Galveston. At NFPA we’ve already been fielding questions from our stakeholders about how NFPA 101, Life Safety Code applies to rebuilding efforts following disasters like Harvey and Irma. Up until a few editions ago, the Code was very specific if not always “reasonable” or practical: if you “touched” something, it had to comply with the requirements for new construction. It didn’t matter if you were replacing flood-damaged flooring and drywall or rebuilding a structurally compromised building; whatever work was performed had to meet the Code’s new-construction criteria. In the 2006 edition, the Life Safety Code introduced the concept of building rehabilitation in its then-new chapter 43, which was based on guidance published by the U.S. Department of Housing and Urban Development (HUD) in its Nationally Applicable Recommended Rehabilitation Provisions (NARRP). The idea behind NARRP, and subsequently Chapter 43 of NFPA 101, was to promote the adaptive reuse of existing buildings by tempering model building code requirements when applied to building rehabilitation projects while still maintaining a reasonable, minimum level of safety. Using Chapter 43 when replacing flood-damaged drywall, instead of applying the requirements for new construction, perhaps the project can comply with the less-restrictive requirements for existing buildings. The level of required code compliance depends on what the Code calls the "rehabilitation work" category. The categories are explicitly defined, and correctly categorizing the rehabilitation work project is, perhaps, the most important aspect of Chapter 43. The categories that will most likely apply to disaster recovery efforts are repair, renovation, modification, and reconstruction.
Repair. The work to be performed in buildings damaged by Harvey and Irma will probably exceed the category of repair for all but the most minor damage. Repair work, for example, involves not much more than patching a hole in the drywall membrane of a fire barrier. In most cases, the provisions for repair will not apply.
Renovation. Renovation amounts to replacing-in-kind without reconfiguring the space. Provided the rehabilitation work relates only to replacement and not to reconfiguration of the space, the project must only meet the requirements applicable to existing buildings. For example, a corridor wall that was compliant with the requirements for existing buildings is permitted to be replaced, in the same location, by a newly constructed corridor wall that meets the requirements for existing buildings (see 220.127.116.11). An exception to the rule, however, applies. If renovation work involves the replacement of interior finish materials (e.g., wall, ceiling and floor coverings), the interior finish must meet the classification applicable to new construction. If the project involves reconfiguration of the space, the applicable rehabilitation work category changes from renovation to modification or reconstruction.
Modification. With the rehabilitation work category of modification, there must be a reconfiguration of space, an addition or elimination of an element or system, or the installation of new equipment. Building owners need to be aware that if their rehabilitation work falls into the category of modification, all work performed must be in accordance with the requirements for new construction. Further, where the work is extensive (see 43.5.2), as it will likely be in many cases where the entire ground level of a building was flooded, the rehabilitation work category gets bumped up from modification to reconstruction.
Reconstruction. As explained above, reconstruction involves a reconfiguration of space. If a building’s space is not reconfigured, the rehabilitation work can be classified as renovation no matter how extensive the renovation work area is. With the rehabilitation work category of reconstruction, all elements and systems touched by the rehabilitation must meet the requirements applicable to new construction. Additionally, where the reconstruction involves more than half of a floor or more than half of the building area, automatic fire sprinklers must be installed in some or all of the building per the requirements for new construction applicable to the building’s occupancy classification.
For example, a nonsprinklered hotel is flood damaged throughout its ground floor. To repair the damage, the guest room and corridor walls are gutted to the building’s structural frame. The building owner decides to take this opportunity to reconfigure the floor with larger guest rooms. Because of the reconfiguration and the extensive work area, the rehabilitation is categorized as reconstruction. Because the reconstruction work area involves more than 50 percent of the ground floor area, automatic sprinklers must be installed throughout the ground floor because Chapter 28 of the Code requires the installation of sprinklers in all new hotels. If the reconstruction work area involves more than 50 percent of the building area, automatic sprinklers must be installed throughout the highest floor level containing reconstruction work and all floors below.
If you haven’t had much experience using Chapter 43, it can seem a bit daunting at first glance. NFPA is here to help. If you have questions and you’re an NFPA member or code enforcer, you can submit your questions online (click on the "technical questions" tab). Our staff engineers will get back to you as soon as possible. While I hope you’re spared Irma’s wrath, I’m also realistic and I suspect some of you are in for some rough days and weeks ahead. We stand with you and will provide whatever support we can.
Thanks for reading as always, and particularly in the coming days, please stay safe.
Ron Coté, P.E., life safety technical lead at NFPA, contributed to this post.
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