Q: Our facility is a four story facility, and is a combination of different structures built in different years. All of the different structures are protected with sprinklers except for our power plant. Our power plant is 24 hours manned and has Fire Alarm System devices installed or equipped. Do we need to ask for a waiver as per the new NFPA 101 2012 edition that is to be implemented this year?
A: Existing healthcare occupancy buildings are not required to be fully protected with sprinklers. There is no requirement with the new 2012 LSC to install sprinklers in existing buildings (unless the building is a high-rise) so there is no need to ask for waivers.
Now, it is very desirable for healthcare occupancy buildings to be fully sprinklered because if they are, it allows you to do many terrific things. Take a look at the following 2012 Life Safety Code references, which describes the many advantages of having a fully sprinklered building:
- 126.96.36.199.1 – Delayed egress locks are allowed only if the entire building is protected with sprinklers or smoke detectors
- 188.8.131.52 – Capacity factors for egress components improve if entire building is sprinklered
- 7.7.2 – No more than 50% of required exits may discharge through the level of exit discharge if area is sprinklered
- 184.108.40.206 – A hazardous area may not have to have 1-hour fire rated walls if protected with sprinklers (Note: This does not supersede section 18/220.127.116.11.)
- 10.2.8.1 – Class C interior finishes are permitted in locations where Class B is permitted, and Class B interior finishes are permitted in locations where Class A is permitted, provided the area is protected with sprinklers. (Note: This does not supersede section 18/18.104.22.168.)
- 10.2.8.2 – Class II interior floor finish is permitted in locations where Class I is permitted providing the area is protected with sprinklers.
- 10.3.3 – Upholstered furniture must meet the requirements in accordance with NFPA 260 and NFPA 261, unless the furniture is located in rooms protected by sprinklers.
- 10.3.4 – Mattresses must meet the requirements in accordance with Part 1632 of the CFR 16, and NFPA 267, unless the mattresses are located in a room that is protected with sprinklers.
- 22.214.171.124 – Lesser levels of Construction Types are permitted if the entire building is protected with automatic sprinklers.
- 126.96.36.199.2- Travel distances between any point in a room and the exit increases by 50 feet if the entire building is protected with automatic sprinklers
- 188.8.131.52- Hazardous areas are not required to be 1-hour fire rated if the walls are smoke resistant and area is protected with automatic sprinklers
- 184.108.40.206 – No interior floor finish requirements apply in smoke compartment protected with automatic sprinklers
- 220.127.116.11 – Areas open to the corridor are afforded exceptions if the smoke compartment is protected with automatic sprinklers
- 18.104.22.168.4 – Corridor walls are not required to be ½ hour fire rated provided they resist the passage of smoke and the smoke compartment is protected with automatic sprinklers.
- 22.214.171.124.2 – Corridor doors do not have to be 1 ¾ inch thick, solid-bonded wood core or of construction that resists fire for not less than 20 minutes provided they resist the passage of smoke and the smoke compartment is protected with automatic sprinklers.
- 126.96.36.199 – Smoke dampers are not required in fully ducted penetrations of smoke barriers provided both smoke compartments served by the barrier is protected with automatic sprinklers.
By the way, CMS will not consider a waiver request until such time the Life Safety Code deficiency has been cited in a report. So, don’t plan on submitting a waiver request until after you have been cited.