Changes to Unoccupied Rooms Open to Stairwells

The current edition of the Life Safety Code (2000 edition) does not allow an unoccupied room (such as a mechanical room, janitor’s closet, storage room) to have an opening (doorway) from an exit enclosure (stairwell). There have been many hospitals designed and constructed since WWII that have at least one stairwell that extends up to the mechanical room penthouse, without the proper fire rated separation. I would venture to say that nearly half of the hospitals I consulted in over the past 5 years, has this problem. I can only surmise that the Building Code that the hospitals were originally designed and constructed to, did not share this requirement.

The picture to the left was taken from the landing between the top occupied floor, and the mechanical room above it. As you can see, the top of the stairwell has a door directly into the mechanical room, which is a violation of 7.1.3.2.1 (d) of the 2000 edition. You will also note there is a rope suspended down from the roof, in the picture. Having once worked in the construction trades, I knew what it was for, but the facility director saw me looking at it and offered his take on it: “That rope is for our Suicide Assistance Program.” (Everyone is a comedian….). I asked him to remove it.

Now, when CMS finally adopts the new 2012 edition of the Life Safety Code, there will be a change that should help those facility directors that still have this problem. Section 7.1.3.2.1 (9)(c) of the 2012 edition has an exception to openings on exit enclosures (stairwells) that says:

“Existing openings to mechanical equipment spaces protected by approved existing fire protection-rated door assemblies shall be permitted, provided that the following criteria is met:

  • The space is used soley for non-fuel fired mechanical equipment
  • The space contains no stoarge of combustible materials
  • The building is protected through-out by an approved automatic sprinkler system.”

So, what does this mean? Well, if you have yet to resolve an existing mechanical room that opens onto an exit enclosure, and your building qualifies for this exception, then it appears to me that you will not have to resolve this problem when the new 2012 LSC is finally adopted. In the mean-time, I suggest you identify this deficiency as a PFI on your Statement of Conditions (if you are Joint Commission accredited) with an 18-month completion date. In the section of the PFI where you describe how you will resolve the problem, just say the issue will be resolved with the adoption of the new 2012 edition of the LSC.

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