A client of mine contacted me last week and wanted to know if they could temporarily store combustibles in a patient room that is currently under renovation. Apparently the suite where the patient room is located is undergoing a facelift, involving wall coverings and floor coverings, and the patients have been relocated.
I don’t know if my answer was what they wanted to hear, but I informed them whenever combustibles are stored in a room greater than 50 square feet, the room must comply with section 188.8.131.52 of the 2000 edition of the LSC. The reason we need to follow chapter 18 instead of chapter 19 is by placing combustibles in storage in a patient room, we are now changing the use of the room, and a change in use requires compliance with chapter 18.
Section 184.108.40.206 requires all new construction to be sprinklered and Table 220.127.116.11 requires rooms that are over 50 square feet but no more than 100 square feet to have a self-closing door. For combustibles stored in a room exceeding 100 square feet the room must be sprinklered (per 18.104.22.168), have 1-hour fire rated barriers, and have a 3/4 hour fire rated self-closing, positive latching door.
What if the patient room is over 100 square feet and is not constructed to 1-hour fire rated standards, do you have to spend thousands of dollars to modify the room for temporary storage? I say no, you don’t. That’s what section 22.214.171.124 on Alternative Life Safety Measures (or Interim Life Safety Measures as some AHJs call them) is for. Conduct a risk assessment of the combustibles temporarily stored in the patient room and compare the results with your policy on ALSM (or ILSM). Implement whatever compensating measures are needed according to your policy, and document the assessment.
Make sure you do what your policy says you will do, and document all actions, and you should be OK.