Q: We have a construction project that involves removing all of the ceiling tiles in the area. Do we have to relocate the sprinklers heads to within 12″ from the deck above? Do you have any guidance on what’s required for fire protection in the construction area?
A: If your organization is required to be in compliance with the 2000 edition of the Life Safety Code, then sections 18/18.104.22.168 requires compliance with the provisions of NFPA 241 Standard for Safeguarding Construction, Alteration and Demolition Operations, (1996 edition) during renovation and construction that includes a means of egress. The phrase ‘means of egress’ pretty much covers everything, so it would be a safe bet that NFPA 241 applies whenever any construction or renovation is underway. The 1996 edition of NFPA 241 does not require an active water-based sprinkler fire protection system to be installed and operating during the construction phase, but if there is one, it must comply with NFPA 13 Standard for Installation of Sprinkler System, which means sprinkler heads would have to be mounted within 12 inches of the deck if the suspended acoustical tile ceiling had been removed. The 1996 edition of NFPA 241 also only requires fire resistant and smoke resistant temporary construction barriers, rather than 1-hour fire rated barriers. Now, the 2012 edition of the Life Safety Code requires compliance with the 2009 edition of NFPA 241, which did undergo a change in regards to temporary construction barriers. The requirement for temporary construction barriers changed to be either 1-hour fire rated, or non-rated fire resistant if the construction area is fully protected with automatic sprinklers. Again, sprinklers are not mandatory, but if you have them, they must comply with NFPA 13. If the decision for temporary construction barriers is to go with 1-hour fire rated walls, then a ¾ hour fire rated door, which is self-closing and positive latching must be provided. To answer your question directly, I would say ‘No’, there is no requirement whereby you must relocate the heads to within 12 inches of the deck. However, if you do, it may save you with considerable expenses in other areas. If the area is properly sprinklered according to NFPA 13, then a fire watch would not have to be implemented, and the temporary construction barriers would not have to be 1-hour fire rated. This may become a significant expense which could be avoided. If this construction area is located underneath an occupied inpatient unit, then it makes much more sense to provide properly installed sprinklers in the construction project for added protection, which should reduce the risk of the renovation to the inpatients.