Kitchens as Hazardous Areas – Revisited

Q: You recently posted a question about whether or not hospital kitchens are hazardous areas. Your response noted that kitchens are not included in the list of 8 specific scenarios listed in 19.3.2.1. While that is true, 19.3.2.6 Cooking Facilities would seem to cover the hazards found in a kitchen (aside from the storage areas associated with a kitchen). 19.3.2.6 requires compliance with 9.2.3 which in turn references NFPA 96. It would seem that if the criteria of NFPA 96 is met, then it would not be necessary to define the kitchen itself as a hazardous area. Storage areas associated with a kitchen (particularly dry stores) would be hazardous areas. Am I overlooking something, or is a kitchen where the cooking facilities comply with NFPA 96 not a hazardous area?

A: We both agree that kitchens are not listed in the specific areas found under 18/19.3.2.1 of the 2000 Life Safety Code. I agree with you that 18/19.3.2.6 of the 2000 LSC requires cooking facilities (kitchens) to be protected in accordance with 9.2.3 of the 2000 LSC, which in turn requires compliance with NFPA 96, 1998 edition. NFPA 96, 1998 edition includes language that requires fire extinguishing systems in the exhaust hoods used in commercial kitchens.

Nowhere in 18/19.3.2.1, 18/19.3.2.6, 9.2.3, or NFPA 96 addresses whether or not kitchens are hazardous areas. It simply is not discussed, so there is no reference to draw on to say that kitchens are (or are not) hazardous areas. So, why do I believe they are hazardous areas? Take a look at section 3.3.13.2 in the 2000 LSC, which defines hazardous areas as: “An area of a structure or building that poses a degree of hazard greater than that normal to the general occupancy of the building or structure, such as areas used for the storage or use of combustibles or flammables; toxic, noxious, or corrosive materials; or heat-producing appliances.” (Underline mine). I think we would all agree that cooking appliances are heat-producing appliances.

So, NFPA defines an area with heat producing appliances as a hazardous area, which applies to kitchens since they have heat-producing appliances. Going back to 19.3.2.1 in the 2000 LSC, it says any hazardous area shall be safeguarded, and it continues to describe how the hazardous area must be safeguarded. Section 18.3.2.1 of the 2000 LSC has a similar approach to safeguarding hazardous areas, but it takes into the account that all new or renovated areas must be sprinklered.   

So, from the NFPA definition of a hazardous area alone, it is apparent that kitchens are hazardous areas, and according to 18/19.3.2.1 they have to be safeguarded. To address your question directly; there is no language in the 2000 Life Safety Code that says if kitchens comply with NFPA 96, they are not considered hazardous areas. I recently took this issue to the national authorities having jurisdiction (AHJ) over hospitals and asked them directly if they considered kitchens to be a hazardous area solely based on the NFPA definition of hazardous areas according to the 2000 LSC, and here is what they said:

  • CMS:                          Yes, kitchens are hazardous areas
  • HFAP:                        Yes, kitchens are hazardous areas
  • DNV:                         Yes, kitchens are hazardous areas
  • Joint Commission:      No, kitchens are not hazardous areas

So, most of the national AHJs say kitchens are hazardous areas, but Joint Commission (the accreditor who accredits the most hospitals) says they are not. I remind you that hospitals have to comply with all of the AHJs standards and interpretations, so if a hospital is Joint Commission accredited and receives funds for Medicare & Medicaid services, then they must treat kitchens as hazardous areas because CMS says they are even though Joint Commission says they are not.

Now, the technical committee for NFPA 101 (Life Safety Code) understood this dilemma and decided to make a change. Take a look at section 18/19.3.2.5.5 of the 2012 LSC, which says: “Where cooking facilities are protected in accordance with 9.2.3, the presence of the cooking equipment shall not cause the room or space housing the equipment to be classified as a hazardous area with respect to the requirements of 18/19.3.2.1, and the room or space shall not be permitted to be open to the corridor.” So, when the 2012 edition of the LSC is finally adopted, this whole issue of “is a kitchen a hazardous area?” will finally be resolved and everyone will be on board with the same interpretation. Then, the LSC will agree with your point, that as long as kitchens comply with 9.2.3 and NFPA 96, they will not be have to be classified as hazardous areas.

Thanks for being a reader….