I was a co-presenter in a recent HCPro webinar on the new 2012 Life Safety Code along with my good friend and colleague Jim Murphy, and I received quite a bit of feed-back after the session. In the webinar we covered many of the changes that may add to the work-load of the facility manager. In a handout, I summarized them as follows:
- Annual fire door inspections
- New stairwell identification signs
- Certain wheeled equipment will be allowed to be left unattended in corridors
- Existing high-rise hospitals will need to be fully sprinklered within 12 years of the adoption of the 2012 LSC
- Changes to the NFPA 72 fire alarm system test report
- Changes to temporary construction barriers
And that last item on my list (changes to temporary construction barriers) was the one that I received the most feed-back. It appears that this issue is catching facility managers off-guard, probably because not many organizations are actually discussing this change.
To be sure, no one knows how accreditation organizations and state agencies inspecting on behalf of CMS will actually enforce this issue. First, they have to be aware of this change and as mentioned, not many organizations are talking about it, so perhaps the accreditation organizations and state agencies are not aware of the new requirements.
The issue of temporary construction barriers is found in section 18/18.104.22.168 of the 2012 LSC, and says:
The means of egress in any area undergoing construction, repair, or improvements shall be inspected daily for compliance with 22.214.171.124 and shall comply with NFPA 241, Standard for Safeguarding Construction, Alterations, and Demolition Operations.
126.96.36.199 is the chapter 7 requirement for marking the means of egress. The edition of NFPA 241 which is referenced by the 2012 LSC is the 2009 edition, and it says this about temporary construction barriers:
188.8.131.52 Protection shall be provided to separate an occupied portion of the structure from a portion of the structure undergoing alteration, construction, or demolition operations when such operations are considered as having a higher level of hazard than the occupied portion of the building.
184.108.40.206 Walls shall have at least a 1-hour fire resistance rating.
220.127.116.11 Opening protectives shall have at least a 45-minute fire protection rating.
18.104.22.168* Nonrated walls and opening protectives shall be permitted when an approved automatic sprinkler system is installed.
A.22.214.171.124 Construction tarps would not be considered appropriate barriers or opening protectives.
There are still some unknowns about this new requirement that are not clear yet:
- Will flame retardant plastic visqueen be permitted as temporary nonrated walls when the construction area is protected with sprinklers? The portion that says “construction tarps” in NFPA 241 is found in the Annex section which is explanatory information and is not considered part of the enforceable standard.
- Will accreditation organizations and state agencies allow a ‘grace’ period from the start of demolition until such time that the construction area is fully protected with sprinklers, without the need for 1-hour barriers? At times, it may take multiple days to demo the suspended ceiling before temporary upright sprinklers are installed.
- Are the 1-hour fire rated temporary barriers only required where the construction area is contiguous to occupied means of egress areas (corridors), or are the 1-hour barriers required wherever the construction area is contiguous to occupied areas?
My advice: Start working now with your construction people to not only be aware of this new requirement, but to begin incorporating 1-hour temporary barriers in their projects. When the new 2012 LSC is finally adopted, you will be expected to be in full compliance with this, as well as all the new changes. Eventually, the accreditation organizations and the state agencies will explain what their expectations are.
For a copy of the handout that I made for the webinar, go to “Tools”, and click on “Changes the New 2012 Life Safety Code Will Bring”.