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NFPA101(2012) Section Contradictory language creating ambiguity or not?

Question asked by atalwar on May 3, 2017
Latest reply on May 4, 2017 by atalwar

NFPA 101 Life Safety Code (2012 edition) Section 19.6.1:


I am new to this organization and website so I might be duplicating a question I thought I was sending to the technical team at NFPA yesterday. I am hoping that I now reach a wider audience to this question (the technical team and peers)


Table Construction type limitation:


I am analyzing the compliance needs of a healthcare facility. It is built on grade with a lower level and two upper floors. Both the lower level (basement) and the  next level up meet the definition of level of exit discharge each having at least two exits to grade. The lowest level also meets the technical definition of basement. 


I have consulted three professionals and there is conflict in their interpretation of the footnote section of this table and the method to be utilized to count the number of stories. Because the initial language in the footnote directs that the total number of stories to be counted starts with the level of exit discharge (also further defined as the lowest level of exit discharge), one view is that this overrides the other footnote to the effect that "Basements are not to be counted as stories". Read in this manner, the result is that I have a three story structure with my highest story therefore becoming a non-permitted use. 


The last footnote in this table has the language "Basements are not counted as stories" which if interpreted as over-riding the earlier footnote, results in my having a three floor structure, a basement with two floors above. 


This is my interpretation but one of the professionals believes that the Code is unclear with conflicting provisions.


When I further pointed out to the fact that Annex A level of exit discharge contains language to the effect: "Low occupancy ancillary spaces with exit doors discharging directly to the outside...that are located on levels other than the main occupiable floors should not be considered in the determination of level of exit discharge" further supported my position that my lowest level (basement) should not be counted as a story for purposes of this Table, this argument was further rebuffed. My lower level has mechanical equipment spaces, laundry rooms, offices and storage rooms. The only healthcare occupancy in this building is on the upper two floors. 


One interpretation of the footnotes to this table give me a basement with two floors, a structure that complies with the life safety code. The other interpretation gives me a three story building which does not comply with the FSC.


A good answer is critical in that I am trying to determine what the longevity of the structure is going to be, i.e. do I continue to make capital investments in this structure or do I consider a new structure somewhere else. 


Since this is a technical provision in the NFPA that is being interpreted differently by professionals from good firms and credentials, if there any way for me to get some clarity. I am not a fire safety professional.