Q: How do I determine a project is considered major or minor renovation? This makes a difference on whether we follow chapter 18 or chapter 19 requirements in the Life Safety Code.
A: NFPA 101 Life Safety Code 2000 edition does not address the issue of defining ‘major’ and ‘minor’ modification. But the 2003 edition of the Life Safety Code did define the difference between the two, and CMS adopted this interpretation in the S&C-04-05 memo, dated 12/11/03, which says:
“Major” means the modification of more than 50 percent, or more than 4,500 square feet, of the smoke compartment. “Minor” means the modification of less than 50 percent, or less than 4,500 square feet, of the smoke compartment. The replacement of a system, such as a fire alarm system, would be “major” for that system only. Thus, that system would have to meet the requirements for New buildings, not the entire building itself. Traditionally, when a renovation or modernization is more than fifty percent of the size of the area being renovated or modified it must comply with the requirements for New. However, cosmetic changes such as painting and wallpapering by themselves, would not constitute a “major” rehabilitation regardless of the size of the area affected. These general principles should be applied by surveyors to the particular circumstances of each case. The following examples may be helpful in providing further guidance: When an entire floor is gutted, the renovation of that floor should be considered “major” and meet the requirements for New. If corridor walls or partition walls between rooms are removed in their entirety (to make additional space or to reconfigure rooms), the replacement wall should meet New requirements. In such a case, it may not be necessary for the entire building to be upgraded to New requirements, merely the replacement area. Any sprinklers installed in a patient sleeping zone should be of the quick response type (i.e., those which are tested under the same product testing criteria as standard sprinklers, but also exhibit the fast response characteristics of listed residential sprinklers).
However, accreditation organizations also recognizes section 4.6.7 of the 2000 edition of the Life Safety Code, which says, in effect, any alteration must meet the conditions for new construction. That means any change that you make, such as installing a new door assembly, must meet the requirements for new construction. So, to answer your question, all renovation must meet new construction requirements. If the question arises as to how much renovation would constitute having to renovate the entire smoke compartment to meet new construction, the accreditation organizations would follow the guidelines of ‘major’ and ‘minor’ as specified in the CMS memo.