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Change of occupancy related question

Question asked by chrisk on Apr 17, 2019
Latest reply on Apr 19, 2019 by chrisk

I have an existing fully-sprinkled high rise hospital building.  Several years ago, all floors were designated as health care occupancies except for uppermost stories (mechanical spaces designated as industrial occupancies).  Our services changed over the years, and the basement was reclassified as an existing business occupancy.  The consultant that did our life safety (statement of conditions) drawings kept the smoke resistive hazardous area designations for the basement, as well as 1-hour fire barriers that were constructed during renovations that were designed to health care occupancy standards.


Our maintenance team is asking if they still need to do their barrier (fire, smoke, and smoke partition) inspections, and questioning if we still need to maintain certain barriers, particularly the smoke partitions.


My agency currently uses NFPA 101, 2018 edition.


Looking at Chapter 43 Building Rehabilitation: Where a change of occupancy classification creates other than an assembly occupancy [we went from health care to business], and the change occurs within the same hazard classification category or to an occupancy classification of a lesser hazard classification category (i.e., a higher hazard category number), as addressed by Table 43.7.3 [we went from 2 down to 3], the building shall meet both of the following:

(1) Requirements of the applicable existing occupancy chapters for the occupancy created by the change [so we’d use Chapter 39 Existing Business].

(2) Requirements for automatic sprinkler and detection, alarm, and communications systems and requirements for hazardous areas applicable to new construction for the occupancy created by the change [we were already fully-sprinklered].


So, going to Chapter 39 Existing Business:

39.3.2 Protection from Hazards. General. Hazardous areas including, but not limited to, areas used for general storage, boiler or furnace rooms, and maintenance shops that include woodworking and painting areas shall be protected in accordance with Section 8.7.


Referring to Section 8.7 Special Hazard Protection: Protection from any area having a degree of hazard greater than that normal to the general occupancy of the building or structure shall be provided by one of the following means:

(1) Enclosing the area with a fire barrier without windows that has a 1-hour fire resistance rating in accordance with Section 8.3

(2) Protecting the area with automatic extinguishing systems in accordance with Section 9.7

(3) Applying both and where the hazard is severe or otherwise specified by Chapters 11 through 43


We don’t have any severe hazards, so it appears that our automatic sprinkler system would suffice as special hazard protection.  This would apply to existing mechanical rooms (though ours do not contain fuel-fired equipment), elevator machine rooms (ASME A17 series defaults to building codes for fire resistance), and storage rooms. In new construction, where protection is provided with automatic extinguishing systems without fire-resistive separation, the space protected shall be enclosed with smoke partitions in accordance with Section 8.4, unless otherwise permitted by one of the following conditions:

(1) Where mercantile occupancy general storage areas and stockrooms are protected by automatic sprinklers in accordance with Section 9.7 [not applicable to this case]

(2) Where hazardous areas in industrial occupancies are protected by automatic extinguishing systems in accordance with 40.3.2 [not applicable to this case]

(3) Where hazardous areas in detention and correctional occupancies are protected by automatic sprinklers in accordance with 22.3.2 [not applicable to this case]


So, for anything new hazardous area we construct in the existing business occupancy will require smoke partitions (at a minimum) since we have sprinklers.


Referring to Chapter 4 General:

4.6.12 Maintenance, Inspection, and Testing. No existing life safety feature shall be removed or reduced where such feature is a requirement for new construction.


So, finally, I think I have the answer that we do indeed need to maintain the existing smoke partitions and 1-hr fire barriers we already have if the room uses are still considered hazardous areas.


Is my logic sound?  If not please steer me in the correct direction.


Thank you,