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36 Posts authored by: gharrington Employee

Spire London – Image via Greenland Group

When I look at my new copy of the 2018 edition of the Life Safety Code, there's a sense of accomplishment for the fire protection and life safety community in advancing the safety of building occupants from the effects of fire. Indeed, fire deaths are unusual in buildings in which the code’s requirements are met, and when they do occur, NFPA’s technical committees are quick to revisit those requirements and modify them as necessary. We’ve come a long way from the days of the fires that precipitated the development of what was then known as the Building Exits Code. For example, a fire at the Iroquois Theatre in Chicago killed more than 600 people in 1903, and another at the Triangle Waist Company in New York City killed 146 workers in 1911. We’ve learned from these fires and applied those lessons to our ever-evolving codes so those deaths were not in vain. 

The provision of multiple exit stairs has been a fundamental requirement for apartment buildings since the 1956 edition of NFPA 101. How is it, then, that in 2018 I’m reading in the Times of London about the development of not one but seven high-rise, residential towers that will each contain only a single-exit stair serving the highest floors? It’s mind-boggling to me with what we know about life safety from fire that anyone would consider designing—and any building code would allow—a high-rise building with a single exit.

The proposed Spire London will have a single stair serving the apartments on floors 55 through 67 (presumably equivalent to floors 56 through 68 in the U.S., since the first level above the ground floor is typically designated as the first floor in Europe). This was likely a design decision to allow for larger luxury apartments on the upper floors, since increased living space equals increased price. This is about money.

While the building will be equipped with automatic sprinklers and smoke extraction systems, these are active systems. Any active system (or passive life safety feature for that matter) has the potential to fail. It is this potential that makes redundancy critically important when it comes to means of egress. Anyone with any fire service experience knows that if something can go wrong, there’s a good chance it will. The risk of system failures can be minimized by performing the needed routine testing and maintenance, but it can never be eliminated entirely. Putting residents 770 feet above ground level with only a single-exit stair for the sole purpose of profit creates a completely unnecessary risk.

Compounding the Spire London exiting issue, travel distance from the furthest apartment entrance to the single stair will reportedly be about 70 feet, while the usual “government guidelines” call for a distance of no more than about 25 feet. This increased distance is based on “fire engineering solutions,” which is fine as long as all the systems on which the engineering solutions are based function as intended and the real fire does just what the design fire did. How can all this be assured? There’s not much of a safety factor when there’s only one way out, especially when there’s 70 feet of corridor between you and one exit. By comparison, the Life Safety Code would require at least two exits, and the maximum permitted common path of travel (the distance between an apartment door and the point at which an occupant would have a choice of going in two directions to reach separate exits) would be 50 feet.

What makes this story all the more unbelievable is it comes just seven months after the horrific Grenfell Tower fire in London, in which 71 people died. While the combustible exterior cladding and lack of automatic sprinklers and functioning fire alarms significantly contributed to the large loss of life in that fire, so too did the building’s single-exit stair. The proposed construction of these single-exit residential towers, nearly three times the height of Grenfell, is a slap in the face to those victims.

Grenfell Tower – Image via

Let me put it in terms that the developers of these buildings can understand. You don’t put all your investments in only stocks, bonds, or real estate. You diversify your holdings. Why? Because each market has vulnerabilities, and you protect your assets by spreading your investment portfolio across multiple markets. To put it simply, you don’t put all your eggs in one basket because if you drop the basket, you can say goodbye to all your eggs.

In this case we’re not talking about investments. We’re talking about diversifying life safety features and providing redundancy so that when the bubble bursts (a system doesn’t work the way it was supposed to or the fire does something unanticipated), you don’t lose all your assets (the lives of the residents who have no idea what risk they’re being exposed to because they will assume the building is safe). Maybe residents of Spire London and the other single-exit high rises will be safe if everything works the way it’s supposed to. But what about if and when it doesn’t? How many lives might be placed at risk for the sake of an additional few hundred square feet of living area?

Thanks for reading, and as always, stay safe.

Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!

Did you know NFPA 101 is available to review online for free? Head over to and click on “FREE ACCESS.”

Follow me on Twitter: @NFPAGregH


When I’m asked, “What is the required rating for a door in a particular wall?” nine times out of 10 my answer is, “It depends.” (This is the standard answer for nearly everything code-related.) In the Life Safety Code, required ratings for doors and other opening protectives (e.g., windows) depend on the required hourly, fire-resistance rating of the barrier in which the opening is located and the function the barrier is serving.

Not all fire barriers are created equal. A door in an exit enclosure fire barrier will probably require a different rating than a door in a similarly rated corridor or hazardous area enclosure. Or a smoke barrier. Or a smoke partition. Or a shaft enclosure. (You get the idea.) At first glance it may seem convoluted, but the code does a good job of consolidating the opening protective rating requirements in one location. In the 2018 edition, you’ll find the required door rating in Table (what I’ll refer to as “the table”). In the 2015 and earlier editions, the required ratings were located in Table Prior to the 2003 edition, there was no handy consolidated table. If you’re using the 2000 or earlier edition, you’ll have to sort through a series of requirements and exceptions to determine the required door rating. (If you’re using the 2000 or earlier edition, you’re using a code that’s some 20 years out of date, and it might be time to join the rest of us in the 21st century. But I digress.)

To use the table, you’ll first need to establish the fire barrier’s purpose as required by the code. The table lists the purpose under the heading “Component.” Components include:

  • Elevator hoistways
  • Elevator lobbies
  • Vertical shafts
  • Horizontal exits
  • Exit access corridors
  • Other fire barriers
  • Smoke barriers
  • Smoke partitions

This is where the table has, at times, caused some confusion. Some have misinterpreted it as prescribing minimum fire-resistance ratings for various fire barriers. For example, the bottom row addresses smoke partitions. The second column specifies fire-resistance ratings for smoke partitions (half hour and one hour). Some have been led to believe that based on the table, all smoke partitions must have a minimum fire resistance rating of a half hour. This is not the case for smoke partitions or any of the other components listed in the table.

The requirements for smoke partitions are located in Section 8.4; you’ll find no fire-resistance rating requirement there. Smoke partitions require a rating only where required by another section of the code. An example would be corridor walls in new, large, residential board-and-care occupancies, which require a half-hour rating ( Once it’s determined that the smoke partition requires a fire-resistance rating, then refer to the table to determine the required fire-protection rating of any doors. In the case of a half-hour rated smoke partition, doors must have a one-third hour, or 20 minute, fire-protection rating. In short, use the table to determine the required opening protective rating when a barrier is required by another section of the code to have a fire-resistance rating.

Fire barriers having a one-hour rating might require one-hour doors, three-quarter-hour doors, or one-third-hour doors. Again, it depends on the barrier’s application. Fire barriers having a two-hour rating generally require one-and-a-half hour doors. Fire barriers with a rating exceeding two hours are rarely required by the code, except for a few occupancy separation fire barriers involving relatively hazardous occupancies.

I sometimes get the question, “Why does the code allow a 20-minute door in a one-hour barrier? Why not just require a one-hour door?” This would certainly make life easier when applying the code, but it also might require a more expensive door than is actually needed for life safety. Where the code requires 20-minute doors, it’s usually in a barrier that the committees primarily wanted to be smoke resistant. Before the days of smoke partitions, which first appeared in the 2000 edition, when a committee wanted a smoke resistant barrier (e.g., a corridor wall), it was simpler to mandate a one-hour barrier than to come up with criteria to evaluate smoke resistance. Since they really wanted a nominal degree of fire resistance, rather than mandating a substantial one-hour door, they were comfortable with a 20-minute door, which would inherently resist the passage of smoke.

Other reasons for the difference in fire barrier ratings and door ratings are the tests used to establish the ratings. You might have noticed I refer to the fire-resistance rating of a fire barrier, whereas a door has a fire-protection rating. Fire barrier assemblies are tested at a lab using a standard like ASTM E119, Standard Test Methods for Fire Tests of Building Construction and Materials, which yields a fire-resistance rating. Fire doors are tested using a standard like NFPA 252, Standard Methods of Fire Tests of Door Assemblies, which yields a fire-protection rating. Comparing the ratings from the different tests is not an apples-to-apples comparison. An hour’s worth of fire resistance (fire barrier) is not necessarily equivalent to an hour’s worth of fire protection (fire door).

And although it’s not a very scientific reason, this is the way the code has done it for many years and it seems to work. To this point, there has been no compelling reason to change the approach. If it’s not broken, there’s no need to fix it.

For more details on fire door installation, inspection, testing, and maintenance, check out NFPA 80, Standard for Fire Doors and Other Opening Protectives. NFPA also offers online training for NFPA 80 ITM requirements and classroom training on NFPA 101 and NFPA 80 fire door inspection for health care facilities.

Thanks for reading, and as always, stay safe.

Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!

Did you know NFPA 101 is available to review online for free? Head over to and click on “Free Access.”

Follow me on Twitter: @NFPAGregH

(The mock revision shown in the photo wouldn’t be accepted because it isn’t in mandatory language, although it has merit.) 

We recently released the 2018 edition of the Life Safety Code and its companion Life Safety Code Handbook. (I’m still catching my breath.) The cycle of code revisions never stops, so here we are, ready to start working on the next, the 2021 edition. NFPA 101 is now open for public input, along with a number of other standards in the Annual 2020 revision cycle, which includes NFPA 1, Fire Code, and NFPA 5000, Building Construction and Safety Code.


I often tell attendees of NFPA’s Life Safety Code Essentials Seminar that you don’t get to complain about what’s in the code if you don’t participate in the process, similar to not complaining about politicians if you don’t vote. You don’t have to be an NFPA technical committee member to participate. Anyone can participate by submitting public input (PIs) and public comments (PCs) on proposed revisions. NFPA has made the process incredibly easy. Login to the NFPA website, navigate to the appropriate document information page (e.g.,, click on ‘Next Edition’, and click the link to submit a PI or PC. The current code text will come up. All you have to do is type your revisions and a substantiation and you’re done.


The applicable technical committee will review and consider your submittal. Granted, the 2018 edition of NFPA 101 just hit the streets, so chances are you’re not familiar with all the new requirements. If you’re an NFPA member, you can view my one hour 2015 to 2018 NFPA 101 Changes webinar at no charge. The Origin and Development section of the code also provides a summary of the key changes. If I had to narrow it down, I would say the top five changes to the 2018 edition are:


• New requirements for hazardous materials protection that goes beyond fire-related hazards

• Added criteria for door locking to prevent unwanted entry in educational, daycare, and business occupancies to accommodate active-shooter/lockdown emergencies

• New provisions that permit health care and ambulatory health care smoke compartments up to 40,000 ft2 (3720 m2) in area

• New requirements for risk analyses for mass notification systems

• New testing requirements for integrated fire protection and life safety systems in accordance with NFPA 4, Standard for Integrated Fire Protection and Life Safety System Testing


If any of these or any other life safety topics are of interest to you, you’re encouraged to look at the requirements and provide recommended revisions. Our technical committees can’t operate effectively in a vacuum; input from the people directly affected by the code’s requirements is vital.


The clock is ticking; the public input closing date for NFPA 101 is June 27, 2018. If you miss that deadline, any new proposed revisions won’t be able to be considered until the 2024 edition cycle. (That’s a long wait.) Visit our website for more details on the NFPA code development process or to submit public input on NFPA 101.


Thanks for reading, and as always, stay safe.


Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!


Did you know NFPA 101 is available to review online for free? Head over to and click on “FREE ACCESS.”


Follow me on Twitter: @NFPAGregH


Building security and life safety from fire have polar opposite objectives. The former is to make it as difficult as possible to get in or out of a building, and the latter is to make it as easy as possible. While NFPA 101 recognizes the need to provide security for occupants’ safety (especially now given the “new normal”), life safety from fire must also be maintained. This is a tricky balancing act. Many lives have been lost in fires due to locked or otherwise compromised egress doors.


During my recent NFPA Live presentation I provided an overview of the Code’s egress door requirements and the provisions that allow for special locking arrangements, including requirements that are new to the 2018 edition addressing classroom door locking to prevent unwanted entry.


During the live event we received this follow-up questions from a member. I'm now sharing it with you. I hope you find some value in it.

NFPA Live is an interactive video series in which members of NFPA staff address some of the most frequent topics they receive through the Member's Only Technical Question service. If you are currently an NFPA Member you can view the entire video by following this link. If you're not currently a member, join today!

Marriott Marquis New York designed by John Portman. Image via Wikimedia Commons
During NFPA’s winter shutdown between Christmas and New Year’s, I stumbled upon a New York Times obituary for architect John Portman, a pioneer of the modern atrium building design and a true visionary. Mr. Portman was famous for designing Hyatt hotels with soaring atriums, including the Hyatt Regency in Atlanta’s Peachtree Center, the first of its kind. When it was built, this Hyatt defied accepted building design practices.
 A fundamental tenet of building codes at the time and today, including what’s in the Life Safety Code, is to compartmentalize buildings to prevent the effects of fire from spreading beyond the floor of origin, allowing occupants remote from the fire adequate time to evacuate. Atrium design scuttles that notion by opening up the building interior, allowing multiple floors to communicate amongst each other. This radical departure from conventional building design necessitated cooperation between the designers, code officials, and fire protection engineers to develop alternative means of compliance. As noted by Kathleen Almand, NFPA's vice president of Research, Data, and Analytics, in a recent blog she wrote to NFPA staff, “These alternative means included fire sprinklers, smoke management systems, and other features which are now common in fire safety design and code requirements in high-rise structures … (Portman’s) determination opened the door for a more scientific approach toward the development of fire safety design and building codes, which has been applied to other innovations in building design.” 
The proliferation of atrium buildings in the 1970s and 1980s meant codes like the Life Safety Code needed to adapt so as to not hinder innovation, but still maintain the required level of safety for occupants. Requirements for atriums first appeared in the 1981 edition of the code as an exception to the requirement for the enclosure of floor openings. At the time, the requirements included: 
  • a minimum opening dimension of not less than 20 feet and an area of not less than 1000 square feet
  • automatic sprinklers throughout the building
  • an engineered smoke control system acceptable to the authority having jurisdiction (AHJ), with factors such as means of egress and smoke control of adjacent spaces considered
  • separation from the remainder of the building by one-hour fire barriers or glass walls with closely spaced sprinklers, with an allowance for up to three stories open to the atrium 
The 1981 edition included in Annex A prescriptive criteria for smoke removal systems, which were permitted in lieu of engineered smoke control systems. These criteria did not, however, take into consideration the anticipated fire size based on the actual fuel load, the time to egress based on the anticipated occupant load, or the physical building configuration. Fire and egress modeling was in its infancy in 1981, and the computing power needed to perform complex calculations was available only to a select few. It was a start, and it was based on the best information available at the time. 
Times have changed. Today most of us carry around more computing power in our pockets than was carried into space on the first space shuttle. Fire protection engineers today have access to powerful computational fluid dynamics fire models that can predict fire and smoke spread in buildings based on the actual building configuration and fuel load. Egress models also continue to evolve and can be used to predict where building occupants will be when the effects of fire might potentially impact a specific area.  
Because no two atrium building designs are the same, the 1988 edition of the Life Safety Code deleted the prescriptive smoke removal system criteria in favor of an engineered approach specific to the building design. In the 1997 edition, the minimum size requirements were removed, and an allowance for an unlimited number of stories to be open to the atrium was added based on a required engineering analysis. The engineering analysis was required to demonstrate that the building was designed to keep the smoke layer interface above the highest unprotected opening to adjoining spaces, or six feet (1.85 meters) above the highest floor level of exit access open to the atrium for a time period equal to 1.5 times the calculated egress time or 20 minutes, whichever was greater.
The Life Safety Code requirements for atriums haven’t changed much since the 1997 edition. Over the last 20 years, however, the tools to perform the required engineering analysis have matured, and the fire protection engineers who utilize them have gained invaluable experience. John Portman’s legacy will live on in every new atrium building. More importantly, perhaps, his legacy will also live on in the partnership between building designers, AHJs, and standards development organizations as codes like NFPA 101 continue to undergo revisions to promote, and not hinder, advancements in innovative building design. 
Thanks for reading, and as always, stay safe. 
Got an idea for a topic for a future #101Wednesdays? Post it in the comments below. I’d love to hear your suggestions! Did you know NFPA 101 is available to review online for free? Head over to and click on “FREE ACCESS.” Follow me on Twitter: @NFPAGregH

Image: Wikimedia Commons

Over the 20+ years I’ve been working with  NFPA 101, Life Safety Code, the concept of multiple-occupancy buildings hasn’t been all that controversial. In fact, I’d go so far as to say it’s been relatively straightforward—until recently.

Over the past couple weeks, I’ve seen a spate of questions relating to buildings with multiple tenants having the potential for different occupancy classifications. I’ve also seen some interpretations from authorities having jurisdiction (AHJs) that don’t align with the code’s intent. While I recognize that the AHJ has the final say with regard to code interpretation, it doesn’t make an incorrect interpretation right. I don’t like disagreeing with the AHJ; I was one for several years, and I know how difficult the job is given the volume of work and limited resources. AHJs take their responsibilities very seriously; after all, the safety of the public and emergency responders is in their hands. But my job is to educate and inform about the intent of the Life Safety Code, and when I know it is being misapplied, I have a duty to share that information.

NFPA is transforming from a codes-and-standards organization into a knowledge-and-information organization. Here is some knowledge and information to help everyone get on the same page with regard to multiple-occupancy buildings.

Occupancy classification is addressed in Section 6.1 (all references are to the current 2018 edition). The term “multiple occupancy” has the following definition: Multiple Occupancy. A building or structure in which two or more classes of occupancy exist.

NFPA’s headquarters in Quincy, Massachusetts is an example of a multiple-occupancy building. Our building contains offices (business occupancy) and a cafeteria with an occupancy load of more than 49 persons (assembly occupancy).

Where a building contains multiple occupancies, it must comply with the requirements for mixed occupancies in or the requirements for separated occupancies in, as prescribed by Here is the key takeaway: use of the separated-occupancy criteria is not mandatory unless specified by another section of the code. This occurs only in a few instances. For example, a health care occupancy (e.g., a hospital or nursing home) is permitted to be in a building containing other occupancies only when it is separated from the other occupancies by a two-hour fire barrier (see Chapters 18 and 19 for details). Even if a building looks like it contains multiple-separated occupancies, nothing prohibits it from being classified as a multiple-mixed occupancy as long as all of the occupancies comply with the most restrictive requirements of the occupancies involved, unless separate safeguards are approved, as stated in

Conversely, situations exist where the code mandates the use of the multiple-mixed occupancy provisions. Where multiple occupancies lack separation by fire barriers (occupancy separations) as required by, the occupancies are mixed by default. Also, where multiple occupancies share common exit access travel paths (e.g., corridors) as described in, the occupancies are mixed. Note that multiple-separated occupancies are permitted to share common exits (e.g., stair enclosures). Let’s take a closer look at Where exit access from an occupancy traverses another occupancy, the multiple occupancy shall be treated as a mixed occupancy.

I’m aware of a jurisdiction extrapolating this to mean where exit access from an occupancy does not traverse another occupancy, the multiple occupancy must be treated as a separated occupancy. This is not the case; the code doesn’t work like that. If that was the code’s intent, it would specifically say so, and it does not. Part of the confusion arises from the definition of “mixed occupancy” and the use of the undefined term “intermingled”: Mixed Occupancy. A multiple occupancy where the occupancies are intermingled.

What constitutes intermingling of occupancies? Based on the mandatory requirements in the code, intermingling occurs where multiple occupancies share exit access paths or lack occupancy separation fire barriers, or both. The definition describes a condition resulting from the mandatory code provisions.

As an example, consider the generic “strip mall” depicted in the accompanying figure. This is a classic example of a multiple-separated occupancy building provided that the partitions separating the different tenants are fire barriers meeting the requirements of

Also, each tenant space is provided with independent exit access. As a result, the code’s requirements for each occupancy are applied independently. If the space identified as an assembly occupancy is a new nightclub, it requires automatic sprinkler protection ( If the occupancies are separated, the code requires the installation of an automatic sprinkler system only in the assembly occupancy; the other occupancies would be permitted to remain nonsprinklered.

But does anything require these occupancies to be separated by fire barriers? The answer is no as long as each occupancy meets the more restrictive requirements of the occupancies involved. It’s less expensive to build non-rated partitions to separate the tenant spaces. If the owner can show that the entire building meets the most restrictive requirements, they have the right to use the mixed occupancy provisions even though the occupancies are separated by non-rated tenant separations and have independent exit access.

I suspect this is really an enforcement issue. Once the building is constructed with non-rated tenant separations, it might be challenging for the AHJ to enforce the separation requirements when a tenant comes along that impacts the other tenants or needs to be separated so as to not adversely impact the other tenants (e.g., the previously described nightclub). In my experience, this needs to be addressed at the permitting stage. Building permits for “speculative-use” buildings (i.e., the occupancy classification is unknown) should be for the “shell building” only. Certificates of occupancy should only be issued once the occupancy classification is known and inspected. Subsequent certificates of occupancy should be issued only after being reviewed by the AHJ whenever a change of occupancy classification occurs as required by NFPA 1, Fire Code. If the shell building tenant separations are to be non-rated, make it clear in the permit process that additional protection in the form of occupancy separation fire barriers might be required depending on the occupancies ultimately present.

If the building owner chooses to go this route, it’s their problem down the road if upgrades are needed. An example: I once had the pleasure of telling a tire storage facility that their occupancy wasn’t permitted in a spec-use warehouse protected by an ESFR sprinkler system that wasn’t designed to protect the hazard – after they had moved in. Good times. The job of the AHJ isn’t always sunshine and lollipops. I’m sure there were some animated meetings between the owner and the tenant after I broke the bad news. Buyer beware.

It’s important for developers and AHJs to work together to achieve a safe building design. The mixed- and separated-occupancy protection strategies are both safe, and the owner has the right to choose which one works best for their building unless the code explicitly mandates the use of one or the other based on the arrangement or occupancies involved. I know this will put me in the doghouse with at least some jurisdictions, but I didn’t take this job to be popular. You can relate to that, right AHJs? Hopefully we’re all on the same page now. #InfoKnowledge

Thanks for reading, and as always, stay safe.

Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!

Did you know NFPA 101 is available to review online for free? Head over to and click on “FREE ACCESS.”

Follow me on Twitter: @NFPAGregH

I was introduced to model codes as a graduate intern fire protection engineer at Schirmer Engineering (now Jensen Hughes) outside of Washington DC in 1991. Since that time, for almost 27 years (I know many of you have been doing this longer than me), I have calculated the occupant load of business use areas using a factor of 100 sq-ft/person (gross). That’s how it always was and how I figured it would always be. And it was simple. 3000 sq-ft of office area? Occupant load is 30. 10,000 sq-ft? Occupant load is 100. Simple, but perhaps overly conservative.


The 100 sq-ft/person factor first appeared in the 1934 edition of NFPA 101, which was then known as the Building Exits Code. Subsequent studies by the National Bureau of Standards (now the National Institute of Standards and Technology) and other entities found that this factor is generally conservative because it is a gross factor and does not permit any reduction for corridors, closets, restrooms, or other non-occupied spaces. Later studies performed between 1966 and 1992 found the actual occupant density in business occupancies ranged from 150 to 248 sq-ft/person. The 248 sq-ft/person factor was reaffirmed by a 1993 study of 23 federal government and private sector office buildings.


nfpa 101 concentrated office


Based on these studies and a 2012 Fire Protection Research Foundation report, the Technical Committee on Mercantile and Business Occupancies floated a revision to the business factor by creating a committee input (CI) at the first draft stage for the 2018 edition of NFPA 101 to change it from 100 to 150 sq-ft/person for the purpose of soliciting public comments. A total of five public comments were received, some in favor of the revision, and some against (see the NFPA 101-2018 Second Draft Report for details). At this point, the technical committee was not convinced the revision was appropriate and did not move the CI forward as a second revision, meaning the 100 sq-ft/person factor would remain.


Representatives of the U.S. General Services Administration (GSA), however, disagreed, and took advantage of the entire NFPA process to revise the Code by submitting a notice of intent to make a motion (NITMAM) and debate the issue with the NFPA membership at the NFPA Annual Technical Meeting (sometimes called the “tech session”) this past June in Boston. The NITMAM was certified, making it a certified amending motion (CAM), and was openly debated on the floor of the tech session. The membership present agreed with the GSA reps and voted to revise the business factor from 100 to 150 sq-ft/person. In order to make the change in the Code, the technical committee got one more chance to have its say via a ballot of the amendment. At this point, the committee ballot passed, meaning they now agree with the revision, and it has been incorporated into Table


huddle room, NFPA 101


Recognizing that the new factor will reduce the occupant loads of business occupancies, new factors have been added to address collaboration rooms, which are small meeting spaces sometimes referred to as “huddle rooms.” Traditional private offices are going by the wayside in many cases. Designers are opting for more open workspaces. Sometimes, however, there is a need for private, quiet space, and these collaboration rooms can have an occupant density greater than 150 sq-ft/person. If the collaboration room is relatively small (not more than 450 sq-ft), the occupant load factor is 30 sq-ft/person. If it is larger than 450 sq-ft, it is treated like a conference room and the factor is 15 sq-ft/person. Although the Code doesn’t specify these are “net” factors, I would apply them in that way. For example, if I have a 10,000 sq-ft floor of office space that includes five collaboration rooms, each 200 sq-ft in area, I would calculate the occupant load of the floor as follows:


  • Collaboration rooms: [(5) X (200 sq-ft)] / (30 sq-ft/person) = 33.3 people (33 using standard rounding)
  • Remainder (office area): (10,000 sq-ft – 1000 sq-ft) / (150 sq-ft/person) = 60 people
  • TOTAL: 33 + 60 = 93 people


Using the former business factor, the occupant load would have been 100, so there is not much of a difference in this case because of the collaboration rooms, but the difference will be greater as the floor area increases. The net effect is the reduced occupant load might impact the required number and capacity of means of egress, and might also impact the need for fire alarm systems and emergency lighting, the requirements for which are driven by occupant load in business occupancies.


Note that the owner can always increase the occupant load as long as all Code requirements are met for the greater number of occupants. The factor for concentrated business use, 50 sq-ft/person, which was introduced in the 2015 edition of the Code, also remains.


This was a good example of a proponent for a code revision successfully utilizing the complete NFPA open-consensus process to make NFPA 101 more accurately reflect real world conditions. Although I’ll miss being able to divide the floor area by 100. My calculator will now be getting more of a workout.


Thanks for reading, and as always, stay safe!


Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!

Did you know NFPA 101 is available to review online for free? Head over to and click on “FREE ACCESS.”

Follow me on Twitter: @NFPAGregH

I’ve had a couple questions come across my desk asking what the Life Safety Code would require for wall construction to subdivide a building into separate smaller “buildings.” This subdivision is for the purposes of avoiding a requirement for automatic sprinkler protection by reducing the height or area of the smaller buildings to below the prescribed threshold values at which sprinkler protection is required. 

The short answer is that the Life Safety Code contains no such provision. It is not a building code, therefore it does not contain requirements for barriers to create “separate buildings.” If the code requires automatic sprinkler protection throughout the building, it is then up to the authority having jurisdiction to determine what constitutes the boundaries of the building, usually with the help of the applicable building code.  Having said that, there are some provisions in the code that flirt with the concept of building separation walls, so the questions I received were not without merit. 

One of those provisions deals with separating portions of buildings with different types of construction for the purpose of classifying the construction type: Where the building or facility includes additions or connected structures of different construction types, the rating and classification of the structure shall be based on one of the following: 

(1) Separate buildings, if a two-hour or greater vertically aligned fire barrier wall in accordance with NFPA 221 exists between the portions of the building

(2) Separate buildings, if provided with previously approved separations

(3) Least fire-resistive construction type of the connected portions, if separation as specified in or is not provided   

For example, if I have an existing building of Type II(222) construction (noncombustible, two-hour rated structure), and I add on to it using Type II(000) construction (noncombustible, nonrated structure), the building’s overall construction classification will be downgraded to Type II(000). This is the least fire resistive type present, unless the addition is separated from the existing building by a two-hour or greater vertically aligned fire barrier wall in accordance with NFPA 221, Standard for High Challenge Fire Walls, Fire Walls, and Fire Barrier Walls, in which case the existing building continues to be classified as Type II(222) and the addition is classified as Type II(000). From the Life Safety Code’s perspective, however, it is still one building, and if the building requires automatic sprinkler protection throughout, then both the existing building and the addition must be protected. The provision of relates only to separating different types of construction for the purpose of construction classification. 

Another question I received asked whether an existing building with two, side-by-side dwelling units could add a new third dwelling unit separated by a two-hour fire barrier and classify the addition as a new one-family dwelling (sprinklered) and the existing portion as an existing two-family dwelling (nonsprinklered). Or would the entire building be classified as an apartment building (three or more dwelling units) and require sprinklers throughout? The Life Safety Code says if there are three or more dwelling units, it’s an apartment building, and Chapter 43, Building Rehabilitation, says automatic sprinklers would be required throughout the building. However, NFPA’s building code, NFPA 5000, Building Construction and Safety Code, says you can separate townhouses with not more than two dwelling units from each other by two-hour fire barriers and classify them as a series of attached, one- and two-family dwellings (see Section 22.5 of NFPA 5000 for details). The International Building Code, which is widely used here in the U.S., might have similar criteria. 

Another (paraphrased) question asked whether a new school could be subdivided into fire compartments formed by two-hour fire barriers, each not more than 12,000 square feet in area, to avoid requiring automatic sprinklers under the 2015 edition of NFPA 101. (Note that the 2018 edition was revised to require sprinklers in all new educational occupancies other than those not more than 1,000 square feet in area or consisting of a single classroom. See 14.3.5.) The answer to this one was “maybe,” because Annex A contained the following provision:

A. It is the intent to permit use of the criteria of to create separate buildings for purposes of limiting educational occupancy building area to not more than 12,000 square feet (1120 square meters). 

So this suggestion left it up to the AHJ to determine if subdivision by two-hour barriers was permitted in lieu of sprinklers. I’ll be honest, I wasn’t a fan of this language. Either permit something via code language or don’t. It doesn’t help anyone to have wishy-washy “suggestions” in Annex A and then force me to tell people “it’s up to the AHJ.” Frankly, I’m glad this provision in Annex A is gone (thank you, Technical Committee on Educational and Day Care Occupancies). It’s not uncommon to hear me say in technical committee meetings, “I’m going to have to answer questions on this…” The code isn’t perfect, but we try really hard to make it as perfect as we can. You can help; participate in the process by submitting public input for revisions. The 2021 edition revision cycle is right around the corner. Your opportunity to make your voice heard is now!


Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions! Did you know NFPA 101 is available to review online for free? Head over to and click on “FREE ACCESS.” Follow me on Twitter: @NFPAGregH

In what seems like a continuous string of tragedies (earthquakes in Mexico; hurricanes in Texas, Florida, and the Caribbean; and the deadly Las Vegas mass shooting), Northern California is now in the grip of devastating wildfires, which have left at least 17 people dead and another 180 missing – a sad, ironic twist to 2017’s Fire Prevention Week. I’ve been able to connect some of the earlier events to my #101Wednesdays posts, but wildfires are a bit of an enigma to me, and there’s no direct correlation to the Life Safety Code. My experience with wildfires was limited to strapping on an Indian can in my late-teens and early twenties as an on-call firefighter in Central Massachusetts and wetting down the edges of relatively small brush fires. We never had fires where I grew up like they have out West. Fortunately, NFPA has a group of experts dedicated to the wildland fire problem. I invite you to check out their Fire Break blog posts for the latest information.

On a happier note, the 2018 edition of NFPA 101 has officially hit the street. If you were unable to view my one-hour webinar on changes from the 2015 edition, it was recorded and can be viewed here free of charge. One of the changes I touched on was the addition of new occupant life safety requirements for animal housing facilities, which are now categorized as special structures in Chapter 11 of the code. Animal housing facilities are defined as areas of a building or structure, including interior and adjacent exterior spaces, where animals are fed, rested, worked, exercised, treated, exhibited, or used for production (3.3.19). Note that an animal housing facility is not an occupancy classification; an animal housing facility could be a storage occupancy (e.g., barns and stables), a business occupancy (e.g., a veterinary hospital), or a mercantile occupancy (e.g., a pet store), among others. As with other special structures, the usual occupancy-specific requirements apply in addition to any modifications by the special structure provisions of Chapter 11. In the case of a horse stable, for example, the storage occupancy requirements of Chapter 42 would apply as modified by the new animal housing facility provisions of Section 11.1.

Section 11.1 provides a reference to NFPA 150, Standard on Fire and Life Safety in Animal Housing Facilities, 2016 edition. While the scope of NFPA 150 includes the safety of both human and animal occupants, the scope of NFPA 101 is limited to the safety of human occupants. Section 11.1 indicates that where human occupants are expected to delay their egress to care for animals or assist with their evacuation in the event of a fire, the means of egress requirements of NFPA 150 are to be applied where they are more restrictive than those of NFPA 101.

Chapter 8 of NFPA 150 specifies requirements for means of egress in animal housing facilities where handlers will assist with animal evacuation:

  • At least two means of egress must be provided
  • Doors must have a clear width of not less than 32 in., 1.5-times the average width of the largest animal expected to be accommodated, or 1.5-times the width of any equipment needed to facilitate evacuation, whichever is greater
  • Door height must also be sufficient to accommodate any animals or evacuation equipment
  • In nonsprinklered facilities, the travel distance to an exit meeting the aforementioned requirements is limited to 75 feet
  • With automatic sprinklers, the permitted travel distance increases to 100 feet


It is expected these travel distance limits will be more restrictive than the typical NFPA 101 travel distance limits. For example, in ordinary-hazard storage occupancies, exit travel distance is limited to 200 feet (nonsprinklered) or 400 feet (sprinklered) (42.2.6); so the reduced exit travel distance limits of NFPA 150 are probably the most significant implications of the new animal housing facility requirements in the Life Safety Code. As noted in Annex A of NFPA 150, these reduced travel distances recognize the difficulty associated with evacuating panicking animals from a facility during an emergency.

It should be noted that NFPA 150 contains additional requirements which help to protect animals and their handlers from the effects of fire. For example, facilities that house what it refers to as Category A animals (animals that pose a potential risk to the health or safety of rescuers or the general public; animals that cannot be removed without potential risk to the health and welfare of the animal or other animals; animals that are impossible or impractical to move; animals that are not mobile or not in a mobile enclosure) or horses must be protected by an approved automatic sprinkler system. Although NFPA 101 requires compliance only with the means of egress provisions of NFPA 150, application of its numerous other requirements should be considered where humans might need to remain in the facility to assist with the evacuation of animals during a fire.

I hope this glimpse at one of the new requirements of the 2018 edition of NFPA 101 has been useful. I’ll look at highlighting additional revisions in the coming weeks. Until then, thanks again for reading and stay safe.

Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!

Did you know NFPA 101 is available to review online for free? Head over to and click on “FREE ACCESS.”

Follow me on Twitter: @NFPAGregH

concert crowd
As we all try to wrap our heads around this past Sunday’s horrific mass shooting in Las Vegas, my heart goes out to all those who were affected by this senseless act. I also struggle with what I, as a life safety professional, can meaningfully contribute to the conversation going forward. I realize that about the best I can do is discuss what I know, and that’s the Life Safety Code. While the Code has been focused historically on occupant life safety from fire, its scope has expanded over the past couple decades to include protection from other similar emergencies. One area on which the Code has focused is the protection of occupants in assembly venues from myriad emergencies via planning. Here is a brief overview of the resources provided by the Code for planners of large assembly events.
Crowd Managers
The Life Safety Code requires all assembly venues to be provided with trained crowd managers who can assist with evacuation in an emergency by directing attendees to safe egress points. Of course, in a situation like the Las Vegas mass shooting, it’s difficult or impossible to know where the safe egress points are located. Nonetheless, crowd managers can have a positive impact on the outcome of an assembly occupancy emergency. More details on crowd managers can be found in my #101Wednesdays post from this past May.
Means of Egress
The Life Safety Code is primarily concerned with life safety in buildings and structures. It recognizes, however, the need for adequate means of egress from fenced outdoor assembly venues as well. The assembly occupancy chapters require the following in and
A fenced outdoor assembly occupancy shall have not less than two remote means of egress from the enclosure in accordance with, unless otherwise required by one of the following:
(1) If more than 6000 persons are to be served by such means of egress, there shall be not less than three means of egress.
(2) If more than 9000 persons are to be served by such means of egress, there shall be not less than four means of egress.
The capacity of the means of egress from an outdoor assembly venue would be based on the modified capacity factors for smoke-protected assembly seating, which permit reduced egress widths because of the expectation that smoke will not accumulate in the outdoor venue. This reduced egress capacity makes sense from a life safety from fire standpoint; however, when planning for an incident in which occupants might need to flee for their lives under a hail of gunfire, perhaps the reduced egress capacities should be given further consideration. See 12.4.2 and 13.4.2 for details on smoke-protected assembly seating.
Life Safety Evaluation
Perhaps the most significant requirement in Life Safety Code as it relates to an incident such as that which occurred in Las Vegas is that for a written life safety evaluation (LSE) in assembly venues having an occupant load of more than 6,000, and those with festival seating (e.g., standing room with no seats) for more than 250. The LSE is required to consider a broad range of potential emergencies; as we now know, that broad range of emergencies needs to include the unthinkable. Details on the LSE are provided in 12.4.1, 13.4.1, and associated Annex A provisions. A recent NFPA Journal article provides a good overview of what an LSE is intended to achieve. Coincidentally, it describes an LSE as it would apply to a music festival, not unlike the one attacked this week. While no one could have imagined how an outdoor concert venue could be vulnerable to automatic weapon fire from a nearby high-rise hotel, it is this type of unthinkable scenario that needs to be considered in the LSE. A response plan must be developed, practiced, and then, should the unthinkable occur, put into action.
Risk Analysis for Mass Notification
New to the 2018 edition, the Code now requires some new occupancies to have a risk analysis performed to determine the need for mass notification systems. The results of the risk analysis determine whether a mass notification system to alert people of any number of emergencies, which could include fire, an impending weather event (e.g., a tornado), or an active shooter incident, is needed. The 2018 edition of the Code requires new assembly occupancies with an occupant load of 500 or more to have such a risk analysis performed. If deemed to be required, the mass notification system is required to comply with NFPA 72, National Fire Alarm and Signaling Code. In 2013, NFPA Journal published this cover story about the use of a mass notification system at a large assembly venue.
I don’t know if we’ll ever be able to completely eliminate the heinous acts of violence we witnessed this week. I do believe, however, it’s important for us to keep doing what we do and educate event planners of the need to plan for the worst-case scenario. We’re in the business of saving lives. If a bit of additional forethought might help to save a life in the future, I believe it is a worthy effort. It’s also important for us to continue to go to music festivals, do the things we enjoy, and live our lives. I plan to attend the NFPA Conference and Expo next June in Las Vegas at the Mandalay Bay. I’m sure when I’m there I’ll pause to remember those whose lives were lost this week. Then I will try to make whatever small contribution I can towards making the world a safer place. Our work is too important to be scared away by the memory of a madman bent on snuffing out innocent lives while they were enjoying a country music festival on the Las Vegas Strip.
Thank you for taking a few moments to read, and please be safe.
Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!
Did you know NFPA 101 is available to review online for free? Head over to and click on “Free access to the 2015 edition of NFPA 101.”
Follow me on Twitter: @NFPAGregH

When should a portion of a building should be treated as an incidental use or as its own occupancy?


A topic that sometimes prompts a bit of animated discussion when I teach NFPA’s three-day Life Safety Code Essentials seminar is incidental uses. It is not always clear when a portion of a building should be treated as an incidental use or as its own occupancy. In today’s #101Wednesdays post, I will attempt to provide some guidance.

Before getting into the NFPA 101 requirements, it’s important to recognize we live in a world in which the Life Safety Code co-exists with building codes. In most cases, the building code is the International Building Code (IBC), which is promulgated by the International Code Council. Both the IBC and NFPA 101 use the term incidental; however, the term has different meanings in each code. In NFPA 101, incidental refers to “minor” uses that are accessory to and/or support the predominant occupancy and do not warrant their own occupancy classification. This concept in the IBC is known as accessory occupancies. In the IBC, the term incidental uses refers to what NFPA 101 calls hazardous areas. The concepts are very similar, but the terminology is different. Be sure to understand how each term is used in each code so you’re not comparing apples to oranges.

Classification of occupancy is addressed by Chapter 6 of NFPA 101, and it is based on how a building is used. The Code’s requirements are predicated on occupancy classification, which directly relates to occupant characteristics and their associated risks. It is common for buildings to be comprised of more than occupancy; these are known as multiple-occupancy buildings (see 6.1.14 of NFPA 101, 2015 edition). Multiple occupancies are then treated as either mixed multiple occupancies ( or separated multiple occupancies ( In each case, the requirements applicable to all involved occupancies must be evaluated. However, permits some, but not all uses to be considered incidental. For example, where an office building (business use) has an office supply closet (storage use), the AHJ is permitted to judge the storage use to be incidental to the predominant business use and classify the building as a business occupancy, not a multiple occupancy (business and storage). The requirements of Chapter 38 (new business) or 39 (existing business) apply, as applicable, and the AHJ ignores the storage occupancy requirements of Chapter 42. If that same office building has a cafeteria with an occupant load of 50 or more, however, that is an assembly occupancy, and the building must be treated as a multiple-occupancy building (business and assembly). Here is how it works:

Certain uses that are permitted to be considered incidental subject to the determination of the AHJ are specified by mercantile, business, industrial, and storage uses. Examples of each might include:


  • Incidental mercantile: newsstand in an office building lobby (business occupancy)
  • Incidental business: supervisor’s office in a distribution warehouse (storage occupancy)
  • Incidental industrial: repair shop in a bicycle store (mercantile occupancy)
  • Incidental storage: raw materials storage in a manufacturing plant (industrial occupancy)


For these uses, no measurable threshold in terms of area or occupant load applies. Whether one of these uses is incidental or its own occupancy is strictly up to the AHJ. This requires sound, reasonable judgment.


Other nonresidential uses having an occupant load fewer than that established by each occupancy classification’s definition are also considered incidental. Determining whether these areas are incidental requires no judgment. The occupant load based on how the area is used is determined, and if the occupant load is less than that established by the occupancy’s definition, it’s incidental. Examples of these might include:


  • Incidental assembly: café with an occupant load of fewer than 50 in a book store (mercantile occupancy)
  • Incidental educational: tutoring for fewer than four students through the twelfth grade in an office building (business occupancy)
  • Incidental day care: child care service for fewer than four kids at a health club (assembly occupancy)
  • Incidental health care: limited skilled nursing care for fewer than four patients in an assisted living facility (residential board and care occupancy)
  • Incidental ambulatory health care: oral surgery and recovery provided to fewer than four patients in a dentist’s office (business occupancy)


Note that residential uses (one- and two-family dwellings, lodging or rooming houses, hotels and dormitories, apartment buildings, and residential board and care) can never be considered incidental. This is to ensure that the requisite protection for sleeping occupants, namely smoke alarms, is always provided. An on-call physicians’ sleeping room in a hospital is NOT incidental; rather, it’s usually a lodging or rooming house occupancy, and the requirements of Chapter 26 apply in addition to the requirements of Chapter 18 or 19 for health care occupancies. Also be aware that even though an area is incidental, it might still need to be protected as a hazardous area by automatic sprinklers, 1-hour separation, or both (e.g., a soiled linen storage room in a hospital).

It’s interesting to note that the IBC takes a different approach to accessory occupancies. The IBC states that occupancies can be considered accessory if they are ancillary to the main occupancy of the building and do not exceed 10 percent of the floor area of the story in which they are located and do not exceed the allowable area for nonsprinklered buildings for each accessory occupancy. For example, in a 500,000 ft2 building used predominantly as a warehouse, up to 10 percent of the area (50,000 ft2) could be used for offices (assuming Type I construction), and the office area could be considered an accessory occupancy subject only to the requirements applicable to the storage use. To me and to the Safety to Life Technical Committees, 50,000 ft2 of offices is a lot of business use area to treat as accessory (IBC) or incidental (NFPA 101). This is not to disparage the IBC; it’s only to point out the different protection philosophies provided by each code.

I hope this overview of incidental uses in the Life Safety Code has been useful. Thanks for reading, and until next time, stay safe!

Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions! Follow me on Twitter: @NFPAGregH

Did you know NFPA 101 is available to review online for free? Head over to and click on “Free access to the 2015 edition of NFPA 101.”


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I'm excited to be presenting a free webinar on Thursday, September 28 at 1 p.m. ET, which will provide an overview of the key changes in the 2018 edition of NFPA 101, Life Safety Code. This will be a great opportunity to learn about new provisions as jurisdictions update their adoptions to this latest edition. Some of the new provisions I'll be reviewing include:

  • New requirements for hazardous materials protection that goes beyond fire-related hazards 
  • New occupant load factors for business uses
  • New requirements for risk analyses for mass notification systems
  • A new reference to NFPA 4, Integrated Fire Protection and Life Safety System Testing  
  • Animal housing facilities added as special structures
  • Added requirements for carbon monoxide detection in new assembly occupancies and new residential board and care occupancies
  • Added criteria for door locking to prevent unwanted entry in educational, day care, and business occupancies
  • A new mandatory sprinkler requirement for all but very small new educational occupancies
  • New provisions that permit health care and ambulatory health care smoke compartments up to 40,000 ft2 (3720 m2) in area
  • Added requirements for bathtub and shower grab bars
  • Added requirements for attic protection requirements that impact certain new hotels, dormitories, and apartment buildings
  • A new reference to NFPA 99,  Health Care Facilities Code, for medical gases in business occupancies
  • A new annex that offers guidance on several NFPA hazardous materials standards

These are changes that you'll need to be aware of once the code hits the streets in the coming weeks. Register for the free webinar. By taking an hour out of your day on Sept. 28th, you'll save yourself hours of reviewing the new code on your own to determine what changed from the previous edition. I'll also be able to answer some of your questions, time permitting. 

I look forward to seeing you virtually on September 28th! Until then, as always, stay safe.

Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!

Did you know NFPA 101 is available to review online for free? Head over to and click on “Free access to the 2015 edition of NFPA 101.”

Follow me on Twitter: @NFPAGregH

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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 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.
Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!
Did you know NFPA 101 is available to review online for free? Visit the NFPA site and  click on “Free access to the 2015 edition of NFPA 101.”
Follow me on Twitter: @NFPAGregH
In a #101Wednesdays post this past January, I discussed the Life Safety Code requirements for inspection of egress doors for life safety, and I touched on a bit of confusion created by the language in the 2012 edition and its adoption by the Centers for Medicare & Medicaid Services (CMS) for health care occupancies with regard to inspection of fire and smoke doors. In short, the language was formatted in such a way as to be easily misconstrued. While the language was clarified for the 2015 edition of NFPA 101, that didn’t do much to help the thousands of health care facilities (e.g., hospitals and nursing homes) mandated to comply with the 2012 edition via the CMS adoption. Staff from NFPA’s technical services division reached out to CMS and, through a series of meetings and conversations, was able relay the Code’s intent, resulting in a July 28, 2017 memorandum from CMS to the state survey agency directors clarifying the requirements for fire and smoke door annual testing. The memorandum (17-38-LSC) is summarized by CMS as follows:
· In health care occupancies, fire door assemblies are required to be annually inspected and tested in accordance with the 2010 edition of NFPA 80, Fire Doors and Other Opening Protectives.
· In health care occupancies, non-rated doors assemblies including corridor doors to patient care rooms and smoke barrier doors are not subject to the annual inspection and testing requirements of either NFPA 80 or NFPA 105, Smoke Door Assemblies and Other Opening Protectives.
· Non-rated doors should be routinely inspected as part of the facility maintenance program.
· Full compliance with the annual fire door assembly inspection and testing in accordance with 2010 NFPA 80 is required by January 1, 2018.
· Life Safety Code deficiencies associated with the annual inspection and testing of fire doors should be cited under K211–Means of Egress-General.
It was great to see this cooperative effort between NFPA and CMS lead to the relatively speedy issuance of this memorandum. Many facilities subject to CMS regulation and the public will benefit from this consistent, well-defined door inspection requirements. Kudos to all who worked hard to get this done! Thanks for reading, and as always, stay safe.
Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!
Did you know NFPA 101 is available to review online for free? Head over to and click on “Free access to the 2015 edition of NFPA 101.”
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Three people died and six were injured in a fire at a senior housing complex in Chesapeake, Virginia on Saturday, July 15th. The cause of the fire is reported to be a lightning strike somewhere in the vicinity of the roof of the three-story building. According to media reports, the building, which was constructed in the early 1990s, was protected by automatic sprinklers in the living areas but lacked sprinklers in the attic. This sounds like a residential sprinkler system, probably based on NFPA 13R, Standard for the Installation of Sprinkler Systems in Low-Rise Residential Occupancies, although I haven’t confirmed this. Residential sprinkler systems are intended to provide for occupant life safety by controlling or extinguishing the majority of residential fires where they start, which is within living areas. Unoccupied spaces, such as attics and garages, are generally not required to be sprinklered so as to not require freeze-protection and minimize cost. Since the Chesapeake fire apparently started in the area of the roof, there was no way for the sprinkler system to control it. Compounding the problem, the Chesapeake apartment building reportedly lacked a fire alarm system. Media reports indicate the building had alarms “connected to the sprinklers” – that sounds like an outside sprinkler waterflow alarm, which is not intended to notify building occupants of a fire.


The 1991 edition of the Life Safety Code was the first edition to mandate automatic sprinklers in new apartment buildings, with a handful of exceptions based on the means of egress arrangement. In that respect, the Chesapeake apartment building’s residential sprinkler system was state-of-the-art. That edition of the Code, however, also required a fire alarm system. Again, media reports indicate the code under which the Chesapeake apartment building was constructed did not require a fire alarm system. We’ll never know if a fire alarm system would have made a difference to the three individuals who did not survive Saturday’s fire.


The protection of senior housing apartments is an issue the NFPA 101 technical committees have been wrestling with for many years. Special requirements for apartments for the elderly were included in one edition of the Code: the 1981 edition. These requirements were deleted for the subsequent 1985 edition as the requirements were deemed to be discriminatory. The Code assumes occupants of residential occupancies are able to evacuate using the provided means of escape and means of egress. In reality, there is the potential that not all residents will have that ability in any apartment building, and especially in housing designed for seniors.


So where do we go from here? It will be up to the NFPA 101 technical committee responsible for the apartment building requirements to determine what, if any, changes need to be made to the Code. Is it a case where the Code adequately protects all apartment buildings, including senior housing, and the Chesapeake fire was a one-off event that we just have to accept from time to time? Or, are the current requirements inadequate? It’s interesting to note that for the 2018 edition, the Code recognizes that in apartment buildings of combustible construction, where the roof is more than 55 ft (17 m) above the lowest level of fire department vehicle access, some form of attic protection is needed. The protection options include sprinklers in the attic, the use of noncombustible materials or fire-retardant treated wood for attic construction, or filling the attic with noncombustible insulation. It doesn’t appear the Chesapeake apartment building met the 55-ft (17-m) roof height threshold, so this new requirement likely would not have made a difference there. If it’s determined that the Code requirements need to be enhanced, there’s no reason why this concept couldn’t be applied to any new apartment building. Yes, additional protection features have costs associated with them. Last Saturday’s fire in Chesapeake had a significantly greater, tragic cost.


What can you do? If fire protection and life safety are important to you, it’s incumbent on you to participate in the code development process. You don’t necessarily need to travel to committee meetings (although we’d be happy to see you there); you can participate by submitting public input and public comments for code revisions. NFPA is about to issue the 2018 edition of NFPA 101 on August 15th. Soon thereafter, NFPA will begin accepting public input for the 2021 edition. (Details on the public input process can be found here.) I’ll be blunt when I say I see very little fire service participation in the public input process. This is a challenge to all fire service organizations out there to step up your participation and submit public input. It’s not only the public’s safety, but also your safety that is directly impacted by the requirements of model codes and standards such as NFPA 101. I speak from personal experience when I say if you make your voice heard, you can make a difference.


Between the recent fire in Chesapeake, the horrific June 14 Grenfell Tower inferno in London that claimed 80 lives, the May 15 high-rise apartment building fire in Pittsburgh that left one person dead, and the July 14 high-rise apartment building fire in Honolulu that killed three people, it’s been a difficult couple months with respect to residential fire deaths. Our hearts go out to the victims and their families.


I’ve asked the question before: we can do nothing and go on, status-quo, or we can take action (by “we” I mean “you” because I can’t change the codes; only you can). In response to these recent fires, NFPA President Jim Pauley has called on legislators to enact the requirement of NFPA 1, Fire Code, to install automatic sprinklers in all high-rise buildings, regardless of occupancy, both new and existing. I can’t help but notice the disconnect between NFPA 1 and NFPA 101, which also requires existing high-rise apartment buildings to be sprinklered unless they’re provided with something called an engineered life safety system. The stated reason for the disconnect? They’re different codes with different scopes. While that’s true, if NFPA’s president is calling for all existing high-rise buildings to be sprinklered, NFPA 101 should perhaps take a hard look at that exemption. Once again, your voice could make a difference.


The fire protection community can be proud of the strides it has made in reducing fire deaths in recent decades, but I’m feeling anything but proud after the last couple months. I know we can do better. I can raise awareness because NFPA gives me a platform to do so, but if you think change is needed, it’s up to you to make it happen. Get after it.


Thanks for reading, and as always, stay safe.


Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!


Did you know NFPA 101 is available to review online for free? Head over to and click on “Free access to the 2015 edition of NFPA 101.”


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