Q: I am a consultant hired by a health system to review a potential building they want to purchase. The architect on this project tells me that the building is NFPA 220 construction type II (111) which is basically a 1-hour rated assembly. The building is a fully sprinklered three story building, and has a mixed use including business and ambulatory healthcare occupancies. The health system is planning on buying the building and is looking to put a free-standing emergency clinic on the first floor which you’ve said needs to be healthcare occupancy. The second floor is a business occupancy. Here’s where it gets strange and I want to make sure I’m not crazy. The floor separation between the first and second floors in this case (business and healthcare) would need to be two-hour fire rated. But Type II (111) buildings have one-hour fire rated floors. I’ve received a drawing from the architect that states the construction type as II (111), but it shows the floors being upgraded to two-hour fire rated construction. The question is, can we have a two-hour floor supported by a one hour steel frame?
A: From my point of view, if they can document that the floor is 2-hour fire rated, then that should be enough for an AHJ to approve the separation between healthcare and business occupancies. I would view it as this: The floor is 2-hour fire rated, and it meets the requirements for a separation between healthcare and business occupancies, and it meets the requirements for Type II (111) construction type. Now, my opinion does not count, so I suggest they get an interpretation from their AHJs, including their accreditation organization.
By the way… CMS was the one who said in late 2016 that Emergency Departments need to be healthcare occupancies. Since then, they have modified their position a bit. Now they are saying an ED must be healthcare occupancy if they provide patient observation rooms. CMS’ rationale is if the patient is sleeping in an observation bed, then that should qualify it as healthcare occupancy. (I don’t agree, but my opinion does not count.) CMS does concede that an ED may be classified as ambulatory healthcare occupancy provide there are no observation beds.