Changes with Construction Barriers When the New 2012 LSC is Adopted

There will be significant changes for facility managers to deal with when the Centers for Medicare & Medicaid Services (CMS) finally adopts the 2012 edition of the Life Safety Code. This excerpt from a new upcoming book by Brad Keyes and published by HCPro, titled “Preparing for the New Life Safety Code” discusses changes involving the life safety equipment.

Plastic Barrier Web 2Construction and renovation in healthcare facilities is a necessary force that needs to be reckoned with. It is going to happen, and the facility is not going to be shut down in order to accommodate it. A complete renovation of a unit will require the removal of the patients and staff, while the area is under construction. To protect the rest of the occupants of the building from the construction activities, sections 18/19.7.9.2 of the 2012 edition of the LSC has referenced compliance with NFPA 241 Standard for Safeguarding Construction, Alteration, and Demolition Activities, 2009 edition. In previous editions of NFPA 241, non-flammable smoke-tight partitions were all that was required between the area under renovation, and the occupants of the building, which is typically what the accreditation organizations have been enforcing. The 2009 edition of NFPA 241 will now have these new requirements:

  • Temporary construction barriers must be erected to separate occupied areas of the building from those areas undergoing alterations, construction or demolition, when such operations are considered as having a higher level of hazard than the occupied portion of the building

One may think the issue of ‘higher level of hazard’ may be open for interpretation, but NFPA has defined a hazardous area as one that poses a degree of hazard greater than that normal to the general occupancy of the building. Most construction areas would qualify as hazardous areas, under this definition. Other requirements involving the temporary construction barriers:

  • The walls must have a 1-hour fire resistive rating, and the door assemblies (if provided) must have a ¾ hour fire rating.
  • Non-rated walls and opening protectives are permitted when an automatic sprinkler system is installed (construction tarps are not considered appropriate barriers or opening protectives)
  • Where sprinkler protection is to be provided, the installation must be placed in service as soon as practicable

In a construction area that does not have automatic sprinklers installed and placed in service, the temporary barriers must be 1-hour rated, which means non-flammable plastic sheeting will no longer be permitted. Walls meeting 1-hour fire resistive rating usually are constructed with steel studs, and ¾ inch gypsum board on both sides, taped and mudded, and sealed to resist the transfer of smoke. All openings in the walls must be ¾ hour fire rated self-closing, positive latching doors, mounted on fire-rated frames. The clearance between the bottom of the door and the floor covering cannot exceed ¾ inch. It is interesting that NFPA 241 says construction tarps are not permitted where the barriers are not required to be fire-rated. This would lead one to believe that the non-flammable plastic sheeting will no longer be permitted in healthcare occupancies for temporary construction barriers.

The standard says non-rated walls and doors are permitted where sprinklers are installed and operating. Since all new construction in healthcare occupancies has to include the installation of sprinklers, NFPA 241 now requires the sprinklers to be installed as soon as practicable. This usually means temporary upright sprinklers are installed and tested and placed into service, as soon as demolition is completed. Occupancy of the renovated area is not permitted until the fire-safety features are properly tested and inspected.

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