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40 Posts authored by: gharrington Employee

Health care facilities contain countless doors serving numerous purposes. Some doors require routine inspections, and the items to be inspected vary depending on the application of the door. In this NFPA® Live I guided viewers in determining which doors require routine inspections and where to find the required inspection frequencies and criteria in NFPA codes and standards.

In my recent NFPA Live I provided an overview of the code requirements and compared those with the expectations of surveyors when they are in a facility. I received this follow-up question from a member. 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!

Development of the 2021 edition of the Life Safety Code is well underway. The NFPA 101 First Draft Report, which contains the NFPA 101 First Draft with all approved first revisions (FRs), committee inputs (CIs), and resolved public inputs (PIs), is available for review online. Any topic addressed by an FR, CI, or PI, can be commented on by anyone. The public comment closing date is May 8, 2019, so if you would like to participate in the process, now is the time to submit public comments. If you’re new to the NFPA standards development process or could just use a refresher, head over to the codes and standards page on the NFPA website.

The NFPA 101 First Draft contains a total of 316 FRs (334 including first correlating revisions). A comprehensive understanding of the proposed revisions requires reviewing the entire First Draft Report. I realize relatively few people have time for such an undertaking, so I’ve identified what I think are some of the highlights (noted paragraph numbers are consistent with the First Draft numbering):

  • Revised definition of ‘personal care’ to include limited skilled nursing services (3.3.216, A.3.3.216)
  • New provision clarifying that non-required fire doors do not require compliance with NFPA 80 (4.6.12.14, A.4.6.12.3)
  • New term ‘clear floor area’ used in Ch. 7, Means of Egress (numerous locations, draft definition in CI 3.3.22.2)
  • Revised interior exit discharge provisions (7.7.2)
  • Revised communicating space provisions to permit smoke detection in lieu of openness (8.6.6)
  • New requirements for low-frequency alarm signals (9.6.2.10.3, 9.6.3.3)
  • New requirement for fire department two-way radio communication enhancement systems in new and existing buildings in accordance with the fire code (9.15)
  • New requirements for outdoor furnishings adjacent to buildings (10.4)
  • New requirement for automatic sprinklers in all new assembly occupancy bars and restaurants (12.3.5.1)
  • Revised classroom door locking requirements for existing educational and day care occupancies (15.2.2.2.4, 17.2.2.2.6)
  • Revised construction limits for existing nursing homes (19.1.6)
  • New requirement for automatic sprinklers in existing high-rise buildings containing ambulatory health care occupancies (21.4.3.1)
  • New requirement for carbon monoxide detection in existing hotels and dormitories (29.3.4.6)
  • New provisions for valet trash services in apartment buildings (30.7.5, 31.7.5)
  • Removal of engineered life safety system option for existing, high-rise apartment buildings; new 12-year phase-in for mandatory automatic sprinkler systems (31.3.5.12)

Several CIs were also developed for the purpose of soliciting public comments:

  • Proposed Annex A language on dynamic exit signage (7.10.2, CI-6568)
  • Proposed mezzanine area limits with automatic sprinklers (8.6.10.2, CI-6598)
  • Proposed revised school fire drill provisions (14.7.2.4, CI-6914)
  • Proposed mandatory requirement for automatic sprinklers in all new day care occupancies (16.3.5.1, CI-6910)

While this list is not intended to be all-inclusive, it touches on what I think are the “big proposed changes” for the next edition of the Code. Your comments are vital to ensuring that a broad range of stakeholder interests are considered by the NFPA 101 technical committees. For a video overview of these proposed revisions, NFPA members can check out my NFPA Live ARCHIVE: A Preview of the NFPA 101, Life Safety Code, 2021 Edition FIRST DRAFT from this past January.

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!

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

Follow me on Twitter: @NFPAGregH

 

I still refer to the building rehabilitation chapter of NFPA 101, Life Safety Code, as the “new Chapter 43.” It’s been in the Code since the 2006 edition; that’s something like 13 years. I guess it’s not so new anymore. Nonetheless, when I teach NFPA’s three-day 2018 Life Safety Code Essentials seminar, I sometimes encounter some confusion in the class with the concepts of change of use and change of occupancy. Here’s how it works:

 

Chapter 4, General, mandates any rehabilitation work on an existing building must comply with Chapter 43 (see 4.6.7). One of the rehabilitation work categories is change of use or occupancy classification. It should be noted that change of use or occupancy classification does not necessarily have to involve a physical change to the building; Chapter 43 applies whether a physical change occurs or not. To understand the difference between change of use and change of occupancy classification, refer to the special definitions in Section 43.2:

 

43.2.2.1.5 Change of Use. A change in the purpose or level of activity within a structure that involves a change in application of the requirements of the Code.

 

43.2.2.1.6 Change of Occupancy Classification. The change in the occupancy classification of a structure or portion of a structure.

 

The key words in the ‘change of use’ definition are, “that involves a change in application of the requirements of the Code.” An example I give is converting an office in a business occupancy into a storage room. The occupancy classification has not changed; it’s still a business occupancy because storage is permitted by 6.1.14.1.3 to be considered incidental. However, general storage areas are considered to be hazardous in business occupancies per 38.3.2.1 and 39.3.2.1. This results in a change in the application of the requirements of the Code and is a change of use. Chapter 43 describes the requirements for change of use in 43.7.1. For this example, the creation of a hazardous area is covered by 43.7.1.2, which requires a new hazardous area to comply with the requirements applicable to the new use as though it were new construction. This means we would have to apply the requirements for new business occupancies in 38.3.2.1, which sends us back to Section 8.7. This requires either: 1) separation of the hazardous area from the remainder of the building by one-hour fire barriers and 45-minute doors, or 2) the installation of automatic sprinklers with a smoke partition separation and self-closing doors. Either way, some modification to the room and/or door is likely going to be required. Changes of use to other than hazardous areas might require compliance with the existing occupancy chapter requirements.

 

Change of occupancy is pretty straightforward: changing a building’s occupancy classification from one classification to a different classification. An example I give is when I worked in the fire marshal’s office in San Antonio (home of the 2019 NFPA Conference & Expo!) in the 1990s, we had several old office buildings on the Riverwalk that were bought by developers and converted into hotels. The former occupancy classification was business and the new classification was hotel and dormitory (this was back before Chapter 43 existed, so it’s a hypothetical application). To determine the requirements, the former and new occupancy classifications are assigned a relative hazard category classification in Table 43.7.3; these categories relate to the relative occupant risks for the various occupancies. In my example, both business occupancies and hotels and dormitories are assigned hazard category 3 (hotel and dormitory is a residential occupancy by definition). Where a change of occupancy creates other than an assembly occupancy, and the change occurs within the same hazard classification category or to a lesser hazard category, the building must meet the requirements of the applicable existing occupancy chapter for the occupancy created by the change, except that the requirements for automatic sprinklers, fire alarm systems, and hazardous areas must comply with the new occupancy chapter. For my office building-hotel example, the hotel would be required to comply with the requirements of Chapter 29 applicable to existing hotels and dormitories, except that automatic sprinklers, fire alarm systems, and hazardous areas would have to be provided/protected as required by Chapter 28 applicable to new hotels and dormitories. For other changes of occupancy, the requirements vary depending on the relative hazard categories.

 

Hopefully this will help you to better understand how the Life Safety Code applies to changes of use and occupancy classification and make your job a little easier. Join us at the NFPA C&E in San Antonio in June and check out some of those changes of occupancy for yourself!

 

Thanks, as always, 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!

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

 

Follow me on Twitter: @NFPAGregH

The revision process for the 2021 edition of NFPA 101 is currently underway. In my recent NFPA live, I offered viewers a preview of some of the key subjects for which revisions are being considered in advance of the posting of the First Draft, on which the public will have the opportunity to submit public comments.
I provided a brief overview of the revision process for NFPA 101, a synopsis of some of the key first revisions to be included in the First Draft, how to get more involved in the NFPA 101 revision process, and an overview of how to stay on top of potential revisions. I received a follow-up question from a member and included it in the video below. 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 Questionservice. 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!

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 telegraph.co.uk

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 www.nfpa.org/101 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 8.3.3.2.2 (what I’ll refer to as “the table”). In the 2015 and earlier editions, the required ratings were located in Table 8.3.4.2. 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 (32.3.3.6.2). 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 www.nfpa.org/101 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., www.nfpa.org/101), 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 www.nfpa.org/101 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 www.nfpa.org/101 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:

6.1.14.2.1 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 6.1.14.3 or the requirements for separated occupancies in 6.1.14.4, as prescribed by 6.1.14.1.1. 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 6.1.14.3.2.

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 6.1.14.4, the occupancies are mixed by default. Also, where multiple occupancies share common exit access travel paths (e.g., corridors) as described in 6.1.14.1.2, 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 6.1.14.1.2:

6.1.14.1.2 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”:

6.1.14.2.2 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 6.1.14.4.

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 (12.3.5.1). 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 www.nfpa.org/101 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 7.3.1.2.

 

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 www.nfpa.org/101 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:

8.2.1.3 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 8.2.1.3(1) or 8.2.1.3(2) 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 8.2.1.3 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.14.3.5.1 It is the intent to permit use of the criteria of 8.2.1.3(1) 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 www.nfpa.org/101 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 www.nfpa.org/101 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 12.2.4.4 and 13.2.4.4:
A fenced outdoor assembly occupancy shall have not less than two remote means of egress from the enclosure in accordance with 7.5.1.3, 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 www.nfpa.org/101 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 (6.1.14.3) or separated multiple occupancies (6.1.14.4). In each case, the requirements applicable to all involved occupancies must be evaluated. However, 6.1.14.1.3 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 6.1.14.1.3: 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 www.nfpa.org/101 and click on “Free access to the 2015 edition of NFPA 101.”

 

Image above courtesy of timeout.com



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