Q: How do I determine if our outpatient facility is an ambulatory healthcare occupancy?
A: Based on what the 2000 Life Safety Code says, an ambulatory healthcare occupancy is a building or portion thereof used to provide services or treatment simultaneously to four or more patients that: 1) Provides on an outpatient basis, treatment for patients that renders the patients incapable of taking action for self-preservation under emergency conditions without the assistance of others; or 2) provides on an outpatient basis, anesthesia that renders the patients incapable of taking action for self-preservation under emergency conditions without the assistance of others. Ambulatory healthcare facilities shall be separated from other tenants and occupancies by walls and barriers not less than 1-hour fire resistance rating. The ambulatory healthcare facility shall be divided into not less than two smoke compartments. Facilities of less than 5,000 square feet and protected with approved automatic smoke detection system do not have to be subdivided, and facilities of less than 10,000 square feet and protected throughout by an approved, supervised automatic sprinkler system do not have to be subdivided into two smoke compartments. Not less than 15 net square feet per ambulatory healthcare facility occupant shall be provided within the aggregate area of corridors, patient rooms, treatment rooms, lounges and other low hazard areas on each side of the smoke compartment for the total number of occupants in adjoining compartments. I also bring to your attention that in their proposed rule to adopt the 2012 Life Safety Code (issued in April, 2014) CMS stated they will seek to change the rules that govern ambulatory healthcare occupancies. Currently it requires four or more persons incapable of self-preservation to be classified as an ambulatory healthcare occupancy. If CMS gets their way that will be reduced to 1 or more persons incapable of self-preservation will require an ambulatory healthcare occupancy, and all of the above LSC references would apply. The big thing here is the 1-hour fire rated separation barriers and the ambulatory healthcare area divided into at least two smoke compartments. That would be a substantial cost to retroactively install those barriers after the area is occupied.