New or existing? Determining scope for healthcare projects
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Flad Architects Page 1 of 5 Flad Code Forum Notes : DD Month YYYY
Flad Code Forum Notes 29 September 2015 1. Code Forums
a. Notes of past code forums are posted at : i. Flad Home Page / Resources / Codes / Forums / Year / Date of Forum.
b. This Code Forum will Discuss : New or Existing? Determining Scope for Healthcare Projects.
c. Additional information is contained in attached power point slides: PP-pages. New or Existing? Determining Scope for Healthcare Projects – PP-01 through PP-64 2. References
a. NFPA 101 Life Safety Code - 2012 edition = LSC 3. LSC = (5) Major Parts : PP-01 through PP-06
a. General Chapters : Chapters 1-4 & 6-11 b. Performance-Based Option : Chapter 5 c. Occupancy Chapters : Chapters 12-42 d. Building Rehabilitation : Chapter 43 e. Annexes (A, B, & C)
4. General Chapters : PP-07 through PP-13 a. Many of the provisions of these General Chapters are mandatory for all occupancies
i. Some provisions are mandated only when referenced by a specific occupancy ii. Others provisions are exempted for specific occupancies iii. Often "where permitted by Chapters 11 through 43" appears
(1) (80) instances of “Chapters 11 through 43” in the LSC iv. “Permitted” or “Required” or “Specified” v. “Unless prohibited” vi. “Chapter 18 & 19” References
5. LSC Application : PP-14 through PP-19 a. Apply to both new construction and existing buildings/structures b. Specific provisions for existing buildings/structures may differ from those for new
i. Example : Doors in Boiler Rooms, Heater Rooms, and Mech Equip Rooms may be held open in EXISTING HC occupancies but not in NEW HC occupancies
c. Existing Building. A building erected or officially authorized prior to the effective date of the adoption of this edition of the Code by the agency or jurisdiction. i. Date plans were approved for construction by the appropriate AHJ. ii. Per CMS’s S&C-11-05-LSC :
(1) If the facility’s building plans were approved or a building permit was issued or construction started after the effective date, (March 13, 2003), of the final regulation, the building or addition must be surveyed under 2000 NEW LSC.
(2) If the facility’s building plans were approved by a State Agency or building permit issued or construction started prior to the effective date, (March 13, 2003), of the final regulation, the building must be surveyed under 2000 EXISTING LSC.
d. Major vs. Minor Rehabilitation i. LSC 2003 : establishes when a smoke compartment (SC) needs to be sprinklered as
part of a rehabilitation (major - yes, minor - no) (1) Major = 50% or more of SC or more than 4500 SF (2) Minor = Less than 50% of SC and less than 4500 SF
6. Building Rehabilitation : PP-20 i. Ch 43 first appeared in the 2006 LSC.
Flad Architects Page 2 of 5 Flad Code Forum Notes : DD Month YYYY
(1) It was added to “promote the adaptive reuse of EXISTING buildings without sacrificing needed life safety.”
(2) Prior to that, any alteration to an EXISTING building was required to meet the requirements for NEW construction.
b. Rehabilitation Classifications are a stepped approach to mandate requirements. i. (1) Repair ii. (2) Renovation iii. (3) Modification iv. (4) Reconstruction v. (5) Change of use or occupancy classification vi. (6) Addition
7. Repair : PP-21 a. The patching, restoration, or painting of materials, elements, equipment, or fixtures for
the purpose of maintaining such materials, elements, equipment, or fixtures in good or sound condition.
b. Examples i. Ceiling tiles, damaged by a water leak, are replaced in an existing office. ii. A portion of the original plaster-on-lath wall is patched with a piece of GWB, sanded,
and painted to match the adjacent wall. 8. Renovation : PP-22 & PP-32
a. The replacement in kind, strengthening, or upgrading of building elements, materials, equipment, or fixtures, that does not result in a reconfiguration of the building spaces within.
b. Examples i. Ceiling tiles are replaced with newer ones in an existing office. ii. Existing lavatories and water closets are replaced on a one-to-one basis & in the
same locations for aesthetic reasons. c. Requirements
i. Interior Finish Requirements = NEW ii. All other renovation work = EXISTING
d. Renovation work must not reduce the level of code compliance 9. Modification : PP-23 & PP-33 through PP-34
a. The reconfiguration of any space; the addition, relocation, or elimination of any door or window; the addition or elimination of load-bearing elements; the reconfiguration or extension of any system; or the installation of any additional equipment.
b. Examples i. (2) adjacent offices are combined into a single larger office by removing the wall
between the rooms. All work occurs within the (2) offices. ii. A sprinkler system is voluntarily (not statutorily) added to a warehouse. (See 43.5.2.2
for exclusively Fire Protection work) c. Requirements
i. Newly constructed elements, components, and systems shall comply with NEW construction.
ii. Work must also comply with Renovation iii. Renovation work must not reduce the level of code compliance
d. Extensive Modifications i. Modification work that is exclusively electrical, plumbing, mechanical, fire protection
system, or structural work shall not be considered a reconstruction, regardless of its extent.
10. Reconstruction : PP-24 through PP-26 & PP-35 through PP-39 a. The reconfiguration of a space that affects an exit or a corridor shared by more than one
occupant space; or the reconfiguration of a space such that the rehabilitation work area
Flad Architects Page 3 of 5 Flad Code Forum Notes : DD Month YYYY
is not permitted to be occupied because existing means of egress and fire protection systems, or their equivalent, are not in place or continuously maintained.
b. Examples i. An entire floor of an existing hospital is gutted to the columns and exterior walls. New
patient rooms and staff support areas are added. ii. A portion of an existing hospital floor is closed to occupancy and isolated from the
remainder of the floor by temporary fire-resistance rated barrier. The remainder of the floor remains occupied during the rehabilitation and has independent Means of Egress from the work area.
c. Requirements i. Newly constructed elements, components, and systems shall comply with NEW
construction. ii. Work must also comply with Renovation & Modifications iii. Renovation work must not reduce the level of code compliance iv. Means of Egress
(1) If Recon Area > 50% of Floor, then (3) M of E Components for entire Floor = NEW (a) Illumination of the Means of Egress (M of E) (b) Emergency Lighting (c) Marking the M of E
v. Extinguishing Systems (1) If Recon Area > 50% of Building Area, then Sprinkler Systems (SS) – highest
Recon floor & all floors below per NEW (2) If Recon Area > 50% of Floor Area, then Sprinkler Systems (SS) – entire floor per
NEW vi. Fire Alarm Systems
(1) Smoke Alarms required in any Recon Area to meet the NEW occupant requirements (a) Lodging or Rooming Houses (b) Hotels & Dormitories (c) Apartment Buildings (d) Guest rooms (e) Dwelling Units (f) Residential Board and Care
vii. Elevators (1) In High-Rise Buildings where the Recon Area is 20% or more of the occupied
floor area, all floors must be accessible by at least (1) elevator. 11. Change of Use : PP-27 through PP-28 & PP-40
a. A change in the purpose or level of activity within a structure that involves a change in application of the requirements of the Code.
b. Examples i. A patient room is converted into a storage room that is greater than 100 sf and stores
combustible materials making it a hazardous location. ii. A living area in a small board and care (16 or less residents) is converted to a
resident room requiring it to meet the large board and care requirements (more than 16 residents)
c. Change of Use only = No Change of Occupancy + No change of Hazard Level d. Change of Use only = No Change of Occupancy + Change of Hazard Level
i. Comply w/(1) : (1) Compliance w/the requirements to the new Change of Use in accordance with its
NEW occupancy chapter
Flad Architects Page 4 of 5 Flad Code Forum Notes : DD Month YYYY
(2) Existing HC protected throughout by a supervised automatic sprinkler system & the Change of Use room/space is <250sf, it does not need to meet the NEW occupancy chapter
12. Change of Occupancy (COC) : PP-40 through PP-43 a. Other than a COC to an Assembly occupancy, ALL other occupancies w/in the
same/lesser hazard category & classification must meet : i. EXISTING occupancy chapters ii. NEW occupancy chapters
(1) Automatic Sprinkler & Detection (2) Alarm & Communication Systems (3) Hazardous Areas
iii. Example (1) Hospital (Hazard Category 2) is rehabilitated to an Ambulatory HC (Hazard
Category 3) (2) Must meet EXISTING & NEW
b. Other than a COC to an Assembly occupancy, ALL other occupancies w/in the higher hazard category & classification must meet : i. NEW occupancy chapters ii. Example
(1) Ambulatory HC (Hazard Category 3) is rehabilitated to a Hospital (Hazard Category 2)
(2) Must meet NEW 13. Addition : PP-29 & PP-44
a. An increase in the building area, aggregate floor area, building height, or number of stories of a structure.
b. Additions to an Existing Building must meet NEW occupancy chapter(s) i. Must NOT create or extend any nonconformity that affects fire safety or the Means of
Egress in the Existing Building ii. Examples
(1) Increased travel distance (2) Number of Stories based on Construction Type
c. Existing Building must meet its EXISTING occupancy chapter(s) i. Any rehabilitation work that affects the Existing Bldg must meet those requirements ii. Need separation from Addition or be sprinkled if the combined areas of the Addition
+ Exist Bldg require it per NEW 14. Repair vs Renovation : PP-30 through PP-32
a. Matter of Quantity i. Major Repair = Renovation ii. Minor Renovation = Repair iii. Examples
(1) Replacing a section of corridor carpet = Repair (2) Replacing all corridor carpet = Renovation
b. Matter of Quality i. Repair permits the use of “similar” materials to those existed before the repair work
was done provided the use of that material is not prohibited by other code sections. ii. Renovation requires the use of materials that are permitted by other code sections
for existing or new buildings. 15. History of Hospital Regulation : PP-45
a. 1946 : Hospital Survey and Construction Act i. Hill Burton Act ii. Code : Building Exits Code (pre-NFPA 101 LSC)
b. 1971 : CMS adopts the 1967 NFPA 101 LSC c. 1987 : CMS adopts the 1985 NFPA 101 LSC
Flad Architects Page 5 of 5 Flad Code Forum Notes : DD Month YYYY
d. 1995 : International Code Council formed i. Combined ICBO, BOCA, & SBCI into ICC
e. 2003 (3/11/03) : CMS adopts the 2000 NFPA 101 LSC f. 2011: CMS announces adoption of the 2012 NFPA 101 LSC g. 2012 : CMS issues waivers for 2012 NFPA 101 LSC h. 2016 (?) : CMS adopts the 2012 NFPA 101 LSC
16. Hospital Example : PP-46 through PP-63 a. 1950 Hospital + 1967/1970 Additions b. 2000 Addition c. March 3, 2003 : CMS adopts 2000 NFPA 101 Life Safety Code
i. Surveyors follow CMS's S&C-11-05-LSC which differentiates EXISTING and NEW healthcare occupancies per March 13, 2003. (1) 2000 Addition + 1967/1970/1990 Additions + 1950 Hospital should meet
EXISTING Health Care Occupancy (1985 LSC) (2) 2000 Addition + 1967/1970/1990 Additions + 1950 Hospital must meet
EXISTING Health Care Occupancy (2000 LSC) T:\twyatt\Code\Code Forums\2015 0929\2015 0929 Code Forum Notes.docx
F L A D C O D E F O R U M
New or Existing?
Determining Scope for Healthcare Projects
9/29/2015 Flad Code Forum 1
O U T L I N E
• NFPA 101 Life Safety Code (LSC) Overview
– Chapters 1-11 + 43 vs. Chapters 12-42
• New vs. Existing Health Care Occupancies
• Chapter 43 : Rehabilitation Work
• Example : Hospital
9/29/2015 Flad Code Forum 2
NFPA 101 Life Safety Code (2012)
• LSC is comprised of (5) major parts
– General Chapters : Chapters 1-4 & 6-11
– Performance-Based Option : Chapter 5
– Occupancy Chapters : Chapters 12-42
– Building Rehabilitation : Chapter 43
– Annexes (A, B, & C)
9/29/2015 Flad Code Forum 3
NFPA 101 Life Safety Code (2012)
• (31) Occupancy Chapters – Ch 12/13 Assembly
– Ch 14/15 Education
– Ch 16/17 Day-Care
– Ch 18/19 Health Care
– Ch 20/21 Ambulatory Health Care
– Ch 22/23 Detention and Correctional
– Ch 24 One- and Two-Family Dwellings
– Ch 25 Reserved
– Ch 26 Lodging or Rooming Houses
– Ch 27 Reserved
– Ch 28/29 Hotels and Dormitories
– Ch 30/31 New Apartment
– Ch 32/33 Residential Board and Care
– Ch 34 Reserved
– Ch 36/37 Mercantile
– Ch 34 Reserved
– Ch 38/39 Business
– Ch 40 Industrial
– Ch 41 Reserved
– Ch 42 Storage
• (11) New/Existing + (4) New + (5) Reserved
• (12) General Chapters– Ch 1 Administration
– Ch 2 Referenced Publications
– Ch 3 Definitions
– Ch 4 General
– Ch 5 Performance-Based Option
– Ch 6 Classification of Occupancy and Hazard of Contents
– Ch 7 Means of Egress
– Ch 8 Features of Fire Protection
– Ch 9 Building Service and Fire Protection Equipment
– Ch 10 Interior Finish, Contents, and Furnishings
– Ch 11 Special Structures and Hi-Rise Buildings
– Ch 43 Building Rehabilitation
• Annexes– Annex A Explanatory Material
– Annex B Supplemental Evacuation Equipment
– Annex C Informational References
07/30/2015 Flad Code Forum 4
NFPA 101 Life Safety Code (2012)
• (31) Occupancy Chapters – Ch 12/13 Assembly
– Ch 14/15 Education
– Ch 16/17 Day-Care
– Ch 18/19 Health Care
– Ch 20/21 Ambulatory Health Care
– Ch 22/23 Detention and Correctional
– Ch 24 One- and Two-Family Dwellings
– Ch 25 Reserved
– Ch 26 Lodging or Rooming Houses
– Ch 27 Reserved
– Ch 28/29 Hotels and Dormitories
– Ch 30/31 New Apartment
– Ch 32/33 Residential Board and Care
– Ch 34 Reserved
– Ch 36/37 Mercantile
– Ch 34 Reserved
– Ch 38/39 Business
– Ch 40 Industrial
– Ch 41 Reserved
– Ch 42 Storage
• (12) General Chapters– Ch 1 Administration
– Ch 2 Referenced Publications
– Ch 3 Definitions
– Ch 4 General
– Ch 5 Performance-Based Option
– Ch 6 Classification of Occupancy and Hazard of Contents
– Ch 7 Means of Egress
– Ch 8 Features of Fire Protection
– Ch 9 Building Service and Fire Protection Equipment
– Ch 10 Interior Finish, Contents, and Furnishings
– Ch 11 Special Structures and Hi-Rise Buildings
– Ch 43 Building Rehabilitation
• Annex– Annex A Explanatory Material
– Annex B Supplemental Evacuation Equipment
– Annex C Informational References
07/30/2015 Flad Code Forum 5
NFPA 101 Life Safety Code (2012)
• (4) Occupancy Chapters – Ch 18/19 Health Care
– Ch 20/21 Ambulatory Health Care
• (10) General Chapters– Ch 1 Administration
– Ch 2 Referenced Publications
– Ch 3 Definitions
– Ch 4 General
– Ch 6 Classification of Occupancy and Hazard of Contents
– Ch 7 Means of Egress
– Ch 8 Features of Fire Protection
– Ch 9 Building Service and Fire Protection Equipment
– Ch 10 Interior Finish, Contents, and Furnishings
– Ch 43 Building Rehabilitation
• Annex– Annex A Explanatory Material
07/30/2015 Flad Code Forum 6
(10) General Chapters (1-4, 6-11)
• Building blocks for occupancy chapters (12-42)
• Many of the provisions of these General Chapters are mandatory for all occupancies– Some provisions are mandated only when referenced by a specific
occupancy
– Others provisions are exempted for specific occupancies
– Often "where permitted by Chapters 11 through 43" appears
• 4.3* Assumptions.
– 4.4.2.3 Where specific requirements contained in Chapters 11 through 43 differ from general requirements contained in Chapters 1 through 4, and Chapters 6 through 10, the requirement of Chapters 11 through 43 shall govern
• (80) instances of “Chapters 11 through 43” in the LSC (2012)
9/29/2015 Flad Code Forum 7
“Where Permitted” Example
• 7.2.1.6.1 Delayed-egress locks
– Only allowed when permitted by Chapters 11 through
43. Permission to use the delayed-egress lock is
normally found in the " __ .2.2" subsection of each
occupancy chapter.
– For example, 12.2.2.2.5 specifically permits the use of
delayed-egress locks in New Assembly occupancies.
• If this permission is not found in an occupancy
chapter, the delayed-egress lock cannot be used.
9/29/2015 Flad Code Forum 8
“Permitted” or “Required” or “Specified”
• 4.7 Fire Drills– 4.7.1 Where Required
– 4.7.2 Drill Frequency
• 6.2 Hazard of Contents. – 6.2.1.3 … hazardous areas are separated …
• 7.1.3.1 Exit Access Corridors
• 7.2.1.4.1 Swinging-Type Door Assembly Requirement
• 7.2.1.5.5 Key-Operated Locks
• 7.2.1.5.7 … cannot be removed when the door leaf …
• 7.2.1.5.8 … Re-entry from the stair enclosure
• 7.2.1.6.1 Delayed-Egress Locking Systems
• 7.2.1.6.2 Access-Controlled Egress Door Assemblies
• 7.2.1.6.3 Elevator Lobby Exit Access Door Assemblies Locking
• 7.2.1.10 Revolving Door Assemblies
• 7.2.1.11 Turnstiles
• 7.2.1.15 Inspection of Door Openings
• 7.2.2.2.3 Spiral Stairs
• 7.2.2.2.4 Winders
• 7.2.2.5.5 Exit Stair Path Markings
• 7.2.8 Fire Escape Stairs
• 7.2.10 Slide Escapes
• 7.3.4 Minimum Width
• 7.4 Number of Means of Egress
• 7.5 Arrangement of Means of Egress
• 7.5.3 Exterior Ways of Exit Access
• 7.6.7 Travel distance limitations
• 7.8 Illumination of Means of Egress
• 7.9 Emergency Lighting
• 7.10 Marking of Means of Egress
• 7.13 Normally Unoccupied Building Service Equipment Support Areas
• 8.2 Construction and Compartmentation
• 8.3.4.4 20-minute fire protection-rated door
• 8.3.5 Penetrations
• 8.3.6 Joints
• 8.4.5 Joints
• 8.5.7 Joints
• 8.6.9 Convenience Openings
• 9.6.3 Occupant Notification
9/29/2015 Flad Code Forum 9
“Unless prohibited” Examples
• In other locations in the General Chapters, the
wording "unless prohibited by Chapters 11
through 43" is used.
– (5) examples in LSC (2012)
• In these cases, the provision is permitted in
ALL occupancies, UNLESS specifically
prohibited by an occupancy chapter.
9/29/2015 Flad Code Forum 10
“Unless prohibited” Examples
• 7.2.1.4.1 Swinging-Type Door Assembly Requirement. – (4) Horizontal-sliding door assemblies shall be permitted … unless prohibited by Chapters 11
through 43 …
• 7.8 Illumination of Means of Egress. – 7.8.1.2.2 Unless prohibited by Chapters 11 through 43, automatic, motion sensor-type lighting
switches shall be permitted …
• 7.13 Normally Unoccupied Building Service Equipment Support Areas.– 7.13.1.1 Unless prohibited by Chapters 11 through 43, the provisions of Section 7.13 shall
apply …
• 8.6.6 Communicating Space. – Unless prohibited by Chapters 11 through 43, unenclosed floor openings forming a
communicating space between floor levels shall be permitted …
• 8.6.7 Atriums. – Unless prohibited by Chapters 11 through 43, an atrium shall be permitted …
9/29/2015 Flad Code Forum 11
“Chapter 18 & 19” References
• 7.1.9 Impediments to Egress. Any device or alarm installed to restrict the improper use of a means of egress shall be designed and installed so that it cannot, even in case of failure, impede or prevent emergency use of such means of egress, unless otherwise provided in 7.2.1.6 and Chapters 18, 19, 22, and 23.
• 7.2.1.5 Locks, Latches, and Alarm Devices. – 7.2.1.5.4 The requirements of 7.2.1.5.1 and 7.2.1.5.3 shall not apply
where otherwise provided in Chapters 18 through 23.
• 7.2.4 Horizontal Exits. – 7.2.4.1.3 The requirement of 7.2.4.1.2 shall not apply to the following:
• (1) Health care occupancies as otherwise provided in Chapters 18 and 19
9/29/2015 Flad Code Forum 12
“Chapter 18 & 19” References
• 7.2.4.2 Fire Compartments.– 7.2.4.2.1.1 Any fire compartment not having an exit leading outside shall be considered as
part of an adjoining compartment with an exit leading to the outside.
– 7.2.4.2.1.2 The requirement of 7.2.4.2.1 shall not apply to the following: • (1) Health care occupancies as otherwise provided in Chapters 18 and 19
– 7.2.4.2.4 The floor area on either side of a horizontal exit shall be sufficient to hold the occupants of both floor areas and shall provide at least 3 ft2 (0.28 m2) clear floor area per person, unless otherwise permitted for the following: • (1) Health care occupancies as provided in Chapters 18 and 19
• 7.3.2 Measurement of Means of Egress. – 7.3.2.3 In health care and ambulatory health care occupancies, projections shall be permitted
in corridors in accordance with Chapters 18 through 21.
• 9.6.3 Occupant Notification. – 9.6.3.5.2 Visible-only signals shall be provided where specifically permitted in health care
occupancies in accordance with the provisions of Chapters 18 and 19.
9/29/2015 Flad Code Forum 13
LSC Application
• 1.3 Application. – 1.3.1* New and Existing Buildings and Structures. The
Code shall apply to both new construction and existing buildings and existing structures. • *A.1.3.1 Various chapters contain specific provisions for
existing buildings and structures that might differ from those for new construction.
• EXAMPLE– Doors in Boiler Rooms, Heater Rooms, and Mech
Equip Rooms may be held open in EXISTING HC occupancies but not in NEW HC occupancies.
9/29/2015 Flad Code Forum 14
Suggested Procedure :
Code RequirementsAnnex A Explanatory Material
A.1.1 The following is a suggested procedure for determining the Code requirements for a building or structure:
1. Determine the occupancy classification by referring to the occupancy definitions in Chapter 6 and the occupancy Chapters 12 through 42. (See 6.1.14 for buildings with more than one use.)
2. Determine if the building or structure is new or existing. (See the definitions in Chapter 3.)
3. Determine the occupant load. (See 7.3.1.)
4. Determine the hazard of contents. (See Section 6.2.)
5. Refer to the applicable occupancy chapter of the Code, Chapters 12 through 42. [See Chapters 1 through 4 and Chapters 6 through II, as needed, for general information (such as definitions) or as directed by the occupancy chapters
6. Determine the occupancy subclassification or special use condition, if any.
7. Proceed through the applicable occupancy chapter to verify compliance with each referenced section, subsection, paragraph, subparagraph, and referenced codes, standards, and other documents.
8. Where two or more requirements apply, refer to the occupancy chapter, which generally takes precedence over the base Chapters 1 through 4 and Chapters 6 through 11.
9. Where two or more occupancy chapters apply, such as in a mixed occupancy (see 6.1.14), apply the most restrictive requirements.
9/29/2015 Flad Code Forum 15
Suggested Procedure :
Code Requirements
• Step 1 : Determine the occupancy
classification
– Health Care (Hospital)
• Step 2 : Identify the Approval Dates to
determine if the building or structure is NEW
or EXISTING
– Document investigation
9/29/2015 Flad Code Forum 16
“Existing” Definition
• 3.3.36* Building. Any structure used or intended for supporting or sheltering any use or occupancy.
– 3.3.36.5* Existing Building. A building erected or officially authorized prior to the effective date of the adoption of this edition of the Code by the agency or jurisdiction.
• A.3.3.36.5 Existing Building. With respect to judging whether
a building should be considered existing, the deciding factor
is not when the building was designed or when construction
started but, rather, the date plans were approved for construction
by the appropriate authority having jurisdiction.
– 3.3.79* Existing. That which is already in existence on the date this edition of the Code goes into effect.
9/29/2015 Flad Code Forum 17
Step 2 : Identify Approval Dates
• Per CMS's S&C-11-05-LSC– "Review the date the facility first applied for admission into
the program. The use of the EXISTING or NEW chapters of the LSC depends on the date of plan approval or the date of construction (if there is no plan approval process) for the facility’s building(s). If the facility’s building plans were approved or a building permit was issued or construction started after the effective date, (March 13, 2003), of the final regulation, the building or addition must be surveyed under 2000 NEW LSC. If the facility’s building plans were approved by a State Agency or building permit issued or construction started prior to the effective date, (March 13, 2003), of the final regulation, the building must be surveyed under 2000 EXISTING LSC."
9/29/2015 Flad Code Forum 18
Major vs. Minor Rehabilitation
• 18.1.1.4.3.1. (LSC 2003) New text establishes
threshold for major and minor rehabilitation
for determination of when a smoke
compartment (SC) needs to be sprinklered as
part of a rehabilitation.
– Major
• 50% or more of SC or more than 4500 SF
– Minor
• Less than 50% of SC and less than 4500 SF
9/29/2015 Flad Code Forum 19
Chapter 43 : Building Rehabilitation
• Ch 43 first appeared in the 2006 LSC. It was added to “promote the adaptive reuse of EXISTING buildings without sacrificing needed life safety.”
• Prior to that, any alteration to an EXISTING building was required to meet the requirements for NEW construction.
• Rehabilitation Classifications are a stepped approach to mandate requirements.– (1) Repair
– (2) Renovation
– (3) Modification
– (4) Reconstruction
– (5) Change of use or occupancy classification
– (6) Addition
• Repair is least and Addition is most
• The term “REMODEL” is not found in the LSC
9/29/2015 Flad Code Forum 20
Chapter 43 : REPAIR
• 43.2.2.1.1 Repair. The patching, restoration, or paintingof materials, elements, equipment, or fixtures for the purpose of maintaining such materials, elements, equipment, or fixtures in good or sound condition.
• Examples
– Ceiling tiles, damaged by a water leak, are replaced in an existing office.
– A portion of the original plaster-on-lath wall is patched with a piece of GWB, sanded, and painted to match the adjacent wall.
9/29/2015 Flad Code Forum 21
Chapter 43 : RENOVATION
• 43.2.2.1.2 Renovation. The replacement in kind, strengthening, or upgrading of building elements, materials, equipment, or fixtures, that does not result in a reconfiguration of the building spaces within.
• Examples
– Ceiling tiles are replaced with newer ones in an existing office.
– Existing lavatories and water closets are replaced on a one-to-one basis & in the same locations for aesthetic reasons.
9/29/2015 Flad Code Forum 22
Chapter 43 : MODIFICATION
• 43.2.2.1.3 Modification. The reconfiguration of any space; the addition, relocation, or elimination of any door or window; the addition or elimination of load-bearing elements; the reconfiguration or extension of any system; or the installation of any additional equipment.
• Examples– (2) adjacent offices are combined into a single larger office by
removing the wall between the rooms. All work occurs within the (2) offices .
– A sprinkler system is voluntarily (not statutorily) added to a warehouse. (See 43.5.2.2 for exclusively Fire Protection work)
9/29/2015 Flad Code Forum 23
Chapter 43 : RECONSTRUCTION
• 43.2.2.1.4* Reconstruction. The reconfiguration of a space that affects an exit or a corridor shared by more than one occupant space; or the reconfiguration of a space such that the rehabilitation work area is not permitted to be occupied because existing means of egress and fire protection systems, or their equivalent, are not in place or continuously maintained.
• A.43.2.2.1.4 It is not the intent that a corridor, aisle, or circulation space within a suite be considered as a corridor that is shared by more than one occupant space. The suite should be considered as only one occupant space. The following situations should be considered to involve more than one occupant space: – (1) Work affecting a corridor that is common to multiple guest rooms on a
floor of a hotel occupancy
– (2) Work affecting a corridor that is common to multiple living units on a floor of an apartment building occupancy
– (3) Work affecting a corridor that is common to multiple tenants on a floor of a business occupancy
9/29/2015 Flad Code Forum 24
Chapter 43 : RECONSTRUCTION
• Examples
– An entire floor of an existing hospital is gutted to the columns and exterior walls. New patient rooms and staff support areas are added.
– A portion of an existing hospital floor is closed to occupancy and isolated from the remainder of the floor by temporary fire-resistance rated barrier. The remainder of the floor remains occupied during the rehabilitation and has independent Means of Egress from the work area.
9/29/2015 Flad Code Forum 25
Modification vs. Reconstruction
• Rehabilitation of an entire building or an
entire occupancy within a building :
– Classified as Reconstruction
• Modification of over 50% of the building area :
– Classified as Reconstruction (43.5.2)
9/29/2015 Flad Code Forum 26
Chapter 43 : CHANGE OF USE
• 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.
• Examples– A patient room is converted into a storage room that is
greater than 100 sf and stores combustible materials making it a hazardous location.
– A living area in a small board and care (16 or less residents) is converted to a resident room requiring it to meet the large board and care requirements (more than 16 residents)
9/29/2015 Flad Code Forum 27
Chapter 43 : CHANGE OF USE
• 18/19.1.1.4.2 (2012 LSC) exempts some
changes from one health care occupancy
subclassification to another from being
considered a change of use.
9/29/2015 Flad Code Forum 28
Chapter 43 : ADDITION
• 43.2.2.1.7 Addition. An increase in the
building area, aggregate floor area, building
height, or number of stories of a structure.
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Repair vs Renovation
• Repair vs Renovation = Matter of Quantity
– Major Repair = Renovation
– Minor Renovation = Repair
• Examples
– Replacing a section of corridor carpet = Repair
– Replacing all corridor carpet = Renovation
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Repair vs Renovation
• Repair vs Renovation = Matter of Quality
– Repair permits the use of “similar” materials to
those existed before the repair work was done
provided the use of that material is not prohibited
by other code sections.
– Renovation requires the use of materials that are
permitted by other code sections for existing or
new buildings.
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Renovation Requirements
• Interior Finish Requirements = NEW
– All other renovation work = EXISTING
• Renovation work must not reduce the level of
code compliance
• Minor reductions* of clear openings of
replacement doors and windows are allowed.
– *AHJ determines how much deviation is permitted
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Modification Requirements
• Newly constructed elements, components,
and systems shall comply with NEW
construction.
• Work must also comply with Renovation
• Renovation work must not reduce the level of
code compliance
• Building must meet the applicable EXISTING
occupancy chapter.
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EXTENSIVE Modifications
• 43.5.2 Extensive Modifications.
– 43.5.2.2 Modification work that is exclusivelyelectrical, plumbing, mechanical, fire protection system, or structural work shall not be considered a reconstruction, regardless of its extent.
– 43.5.2.4 Rehabilitation work areas in which the modification work is exclusively plumbing, mechanical, fire protection system, or electrical workshall not be included in the computation of total area of all rehabilitation work areas.
• Note : Structural not included in this scope
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Reconstruction
• Newly constructed elements, components, and systems shall comply with NEWconstruction.
• Work must also comply with Renovation & Modifications
• Renovation work must not reduce the level of code compliance
• Building must meet the applicable EXISTINGoccupancy chapter.
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Reconstruction : Means of Egress
• EXISTING occupancy requirements that may be more stringent than EXISTING conditions
– Illumination of the Means of Egress (M of E)
– Emergency Lighting
– Marking the M of E
• (3) M of E Components in Recon Area = NEW
• If Recon Area > 50% of Floor
– (3) M of E Components for entire Floor = NEW
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Reconstruction : Extinguishing Systems
• If Recon Area > 50% of Building Area
– Sprinkler Systems (SS) – highest Recon floor & all
floors below per NEW
• If Recon Area > 50% of Floor Area
– Sprinkler Systems (SS) – entire floor per NEW
• If EXISTING occupancy chapter requires a
standpipe, one shall be provided up to the
floor of the Recon Area
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Reconstruction : Fire Alarm Systems
• Smoke Alarms required in any Recon Area to
meet the NEW occupant requirements
– Lodging or Rooming Houses
– Hotels & Dormitories
– Apartment Buildings
– Guest rooms
– Dwelling Units
– Residential Board and Care
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Reconstruction : Elevators
• In High-Rise Buildings where the Recon Area is
20% or more of the occupied floor area, all
floors must be accessible by at least (1)
elevator.
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Change of Use - Options
• Change of Use only
– No Change of Occupancy
– No change of Hazard Level
• Change of Use only
– No Change of Occupancy
– Change of Hazard Level - Comply w/(1) :
• Compliance w/the requirements to the new Change of Use in accordance with its NEW occupancy chapter
• Existing HC protected throughout by a supervised automatic sprinkler system & the Change of Use room/space is <250sf, it does not need to meet the NEW occupancy chapter
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Change of Occupancy Classification
• Other than a COC to an Assembly occupancy, ALL other occupancies w/in the same/lesser hazard category & classification (T43.7.3) must meet :– EXISTING occupancy chapters
– NEW occupancy chapters• Automatic Sprinkler & Detection
• Alarm & Communication Systems
• Hazardous Areas
• Example – Hospital (Hazard Category 2) is rehabilitated to an
Ambulatory HC (Hazard Category 3)
– Must meet EXISTING & NEW
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Change of Occupancy Classification
• Other than a COC to an Assembly occupancy, ALL other occupancies w/in the higher hazard category & classification (T43.7.3) must meet :
– NEW occupancy chapters
• Example
– Ambulatory HC (Hazard Category 3) is rehabilitated to a Hospital (Hazard Category 2)
– Must meet NEW
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Addition
• Additions to an Existing Building :– Must meet NEW occupancy chapter(s)
– Must NOT create or extend any nonconformity that affects fire safety or the Means of Egress in the Existing Building
– Examples• Increased travel distance
• Number of Stories based on Construction Type
• Existing Building :– Must meet its EXISTING occupancy chapter(s)
– Any rehabilitation work that affects the Existing Bldg must meet those requirements
– Need separation from Addition or be sprinkled if the combined areas of the Addition + Exist Bldg require it per NEW
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History of Hospital Regulation
• 1946 : Hospital Survey and Construction Act – Hill Burton Act
– Code : Building Exits Code (pre-NFPA 101 LSC)
• 1971 : CMS adopts the 1967 NFPA 101 LSC
• 1987 : CMS adopts the 1985 NFPA 101 LSC
• 1995 : International Code Council formed– Combined ICBO, BOCA, & SBCI into ICC
• 2003 (3/11/03) : CMS adopts the 2000 NFPA 101 LSC
• 2011: CMS announces adoption of the 2012 NFPA 101 LSC
• 2012 : CMS issues waivers for 2012 NFPA 101 LSC
• 2016 (?) : CMS adopts the 2012 NFPA 101 LSC
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Code Questions from HC Clients
• Q : What is the maximum allowable "undercut" for hospital corridor doors?
• A : It depends … NEW or EXISTING?
• There are no restrictions for undercuts in non-hazardous doors for EXISTING HC occupancies that are "protected throughout by an approved, supervised automatic sprinkler system."
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Code Questions from HC Clients
• Q : What is the required ratings and/or sprinkler requirements for Hazardous Areas?
• A : It depends … must determine which LSC edition the Hazardous Areas were approved.
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LSC (2000)
SECTION 1.4 APPLICATION• 1.4.1 * New and Existing Buildings and Structures. The Code shall apply to both
new construction and existing buildings and existing structures.
• *A.1.4 – It is the intent of Section 1.4 that a building, addition, or alteration designed to meet the
requirements of a prior edition of the Code be required to meet those requirements for the life of the building. It is intended that the initial assessment of the building, when new, should be based on new occupancy requirements for the edition of the Code in effect on the date of plan approval.
– Subsequent assessments of the building should be based on new occupancy requirements of that same edition of the Code for the life of the building. Requirements for existing buildings in this edition of the Code apply if those requirements are more restrictive.
– There are some cases where the requirements for new construction are less restrictive, and it might be justified to permit an existing building to use the less restrictive requirement. However, extreme care needs to be exercised when granting such permission, because the less restrictive provision might be the result of a new requirement elsewhere in the Code.
– For example, in editions of the Code prior to 1991, corridors in new health care occupancies were required to have a 1-hour fire resistance rating. Since 1991, these corridors have been required only to resist the passage of smoke. However, this provision is based on the new requirement that all new health care facilities be protected throughout by automatic sprinklers.
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• 1950 Hospital + 1967/1970 Additions– All approved prior to adoption of 1967 LSC in 1971
– No (federal) code requirements for this building
– 1970’s Business Addition separated with a 2-Hr FB
– No automatic sprinkler protection throughout
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• 1990 Addition– Connected to 1950/1967 Hospital w/o a 2-Hr FB
– NEW Health Care Occupancy (1985 LSC)
• 1950 Hospital + 1967/1970 Addition– Must NOW meet EXISTING Health Care Occupancy (1985 LSC)
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• 1950 Hospital + 1967/1970 Additions– EXISTING Health Care Occupancy (1985 LSC)
• Fire Alarm System required - Added
• Smoke Detection System required - Added
• Automatic Sprinkler System required – Not Added – Exception : Type II (111) – 1 Story … Bldg’s “1st Flr” is >50% below grade = 1 Story
• Smoke Compartments - Added
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• 2000 Addition– Connected to 1950/1967/1970 Hospital w/o a 2-Hr FB
– Must meet NEW Health Care Occupancy (1985 LSC)
• 1950 Hospital + 1967/1970/1990 Additions– Must STILL meet EXISTING Health Care Occupancy (1985 LSC)
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• March 3, 2003 : CMS adopts 2000 NFPA 101 Life Safety Code
• 2000 Addition– SHOULD meet EXISTING Health Care Occupancy (1985 LSC)
• 1950 Hospital + 1967/1970/1990 Additions– SHOULD meet EXISTING Health Care Occupancy (1985 LSC)
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CMS's S&C-11-05-LSC
"Review the date the facility first applied for admission into the program. The use of the EXISTING or NEW chapters of the LSC depends on the date of plan approval or the date of construction (if there is no plan approval process) for the facility’s building(s). If the facility’s building plans were approved or a building permit was issued or construction started after the effective date, (March 13, 2003), of the final regulation, the building or addition must be surveyed under 2000 NEW LSC. If the facility’s building plans were approved by a State Agency or building permit issued or construction started prior to the effective date, (March 13, 2003), of the final regulation, the building must be surveyed under 2000 EXISTING LSC."
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• March 3, 2003 : CMS adopts 2000 NFPA 101 Life Safety Code
• 2000 Addition– MUST meet EXISTING Health Care Occupancy (2000 LSC)
• 1950 Hospital + 1967/1970/1990 Additions– MUST meet EXISTING Health Care Occupancy (2000 LSC)
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• 2000 Addition
– Automatic Sprinkler System required – Not Added?
– Exception : Type II (111) – 1 Story … Bldg’s “1st Flr” is
>50% below grade = 1 Story
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S U M M A R Y
• When discussing the adoption of the 2012 LSC
by CMS sometime in 2016-2017 with our HC
clients, stress the following points :
– This adoption will “wipe the slate clean” of
previous “rehabilitation” projects needing to meet
different editions (1967, 1985, 2000) of the LSC.
– All hospitals will be EXISTING Health Care
occupancies and be required to meet Chapter 19.
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S U M M A R Y
• Any “rehabilitation” projects should be identified per its classification and a key plan kept up-to-date.
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