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CMS Interpretation of 20.3.7.1

Question asked by mikeg@hochassoc.com on Dec 4, 2017
Latest reply on Dec 4, 2017 by milt.werner

I have been told that when it comes to an occupancy separation between a ambulatory health care and business occupancy that CMS requires that the one hour fire rated wall serving this purpose "must" extend to the underside of the roof deck slab/deck per 20.3.7.1.  Is seems apparent to me that NFPA 101-2012, provides a clear alternative to the extension of the the wall to the roof deck per 6.1.14.4.4 and Chapter 8 which permits “fire barriers” as a means of providing a one hour fire rated occupancy separation, including both "vertical" and "horizontal" fire barrier separation per 8.3.1.2(2), between an Ambulatory Health Care and Business occupancy rather than by extension of the one-hour wall to the underside of the roof deck per 20.3.7.1? 

 

I have been told that CMS doesn't recognize this alternative of 8.3.1.2(2) since 20.3.7.1 does not refer to the wall as a “fire barrier” nor does it reference Chapter 8.  This would in effect create a more restrictive requirement (more restrictive than the requirements of a fire barrier requirements of Chapter 8) for a wall type separating an Ambulatory Health Care occupancy from an adjacent business or other occupancy with no alternative other then to extend the wall vertically to the underside of the roof.

 

Does anyone have first hand experience with CMS's interpretation or application of 20.3.7.1 or any instances where such a wall was indeed recognized as a fire barrier and permitted to comply with 8.3.1.2(2) as an acceptable alternative?

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