Business Occupancy Storage Room

Q: We have a new facility which has recently opened, and it is a physician’s office/business occupancy. There is a medical record storage room which contains combustible files which we have determined to be a general hazard.  Per the LSC, the hazardous room needs to be either one-hour fire-rated or sprinkled.  If sprinkled (which we are), the room needs to be smoke partitioned with a smoke door and a closer (no mention of latching). The door to the room has a closer and opens onto an egress corridor, yet it is not supplied with a latch.  My gut tells me this door should latch. What are your thoughts?

A: My thought is a gut reaction is usually very reliable. The storage room is required to comply with section of the 2000 edition of the LSC, which refers to section 8.4. Section 8.4 requires a hazardous area to be protected with either 1-hour fire rated barriers, or protected with an automatic sprinkler system, so your code assessment is correct. In your case, the storage room is protected with automatic sprinklers and smoke resistant barriers, since new construction requires that. Technically the door to the storage room is not required to latch because it is not a fire rated door and corridor doors in business occupancies are not required to latch according to section 38.3.6. I agree with you that one would think it should latch, especially since the same scenario in a hospital would require it to. But, the LSC does not require it in a business occupancy, which is one of the many advantages to having an area classified as a business occupancy. I still would check with your local and state authorities to see if they have any requirements you need to meet on the subject. Final thought on the issue: If your gut tells you the door needs a latch, then by all means, follow your instinct. The codes are minimum standards, and there is nothing wrong in exceeding the minimum standards.

Life Safety Assessments in Business Occupancies

Many hospitals have facilities located offsite or adjacent to the main building which are classified as business occupancies. These buildings may be physician’s offices, clinics, administrative buildings and storage faclities. All too often, the facility manager for the hospital is assigned the responsibility of plant operations and maintenance for these business occupancies, which typically includes life safety compliance.

While these non-healthcare occupancy buildings are classified as a business occupancy, the approach to a life safety assessment would be similar as conducting a life safety assessment for the healthcare occupancy (hospital), but you do not assess them to the same set of standards as you would the hospital. Healthcare occupancies must comply with the core chapters of the Life Safety Code (LSC), which are chapters 1-4, and 6 – 11, and they have to comply with the occupancy chapters 18 and 19. Business occupancies likewise have to comply with chapters 1 – 4, and 6 – 11, but they have a different set of occupancy chapters to comply with; chapters 38 & 39.

Chapter 38 is for new construction and chapter 39 is for existing construction. A facility is considered new construction if its construction plans and documents were approved by the local authorities on or after March 11, 2003. A facility is considered existing construction if its construction plans and documents were approved by the local authorities before March 11, 2003. Also, any renovation conducted in existing construction buildings on or after March 11, 2003 must comply with new construction requirements. Why the date of March 11, 2003? Because that is the date that the Centers for Medicare & Medicaid Services adopted the 2000 edition of the LSC.

Assuming the business occupancies qualify for existing construction occupancy, you must assess the building for compliance with chapter 39. You will find that the life safety requirements are far less restrictive for business occupancies as compared to healthcare occupancies. Examples were there will be significant differences (and leniencies) in compliance, are:

  • Construction Type                          (39.1.6)
  • Overhead Rolling Fire Doors       (
  • Means of Egress Arrangement     (39.2.5)
  • Emergency Lighting                        (39.2.9)
  • Hazardous areas                              (39.3.2)
  • Fire alarm systems                          (39.3.4)
  • Sprinkler systems                            (39.3.5)
  • Corridor walls                                   (39.3.6)
  • Smoke compartments                     (39.3.7)
  • Fire Drills                                           (39.7.1)
  • Fire Extinguisher Training             (39.7.2)

There are other life safety requirements found in the healthcare occupancy chapters (such as elevator recall testing) that are not found in the business occupancies. However, while fire damper testing in healthcare occupancies enjoys a 6-year cycle, that is not the case in business occupancies, which requires a 4-year testing interval.

To make sure that you are assessing your business occupancies correctly, you will have to research each issue individually to determine your level of compliance.

Compressed Gas Cylinders in Business Occupancies

I was recently asked what the requirements were for storing compressed gas cylinders in a business occupancy. According to section 1-2, NFPA 99 (1999 edition) applies to all health care facilities, and section 2-1 defines a health care facility where medical care is provided. Therefore a clinical business occupancy such as those which provides services for cardiac rehab, physical therapy, physician’s office, and pulmonary rehab programs is considered to be a health care facility. Assuming you are either Joint Commission accredited, or receive federal reimbursement monies for Medicare or Medicaid services, you are required to comply with NFPA 99 (1999 edition) Health Care Facilities standard.

Chapter 13 in NFPA 99 is the chapter for “other” health care facilities which are not hospitals, nursing homes and limited care facilities. Section 13-3.8 requires all gas equipment to conform to chapter 8. Section 8-3.1.11 lists the storage requirements for nonflammable gases greater than 3000 cubic feet and quantities less than 3000 cubic feet which are similar (but not the same) as those requirements for hospitals.

For storage of quantities of nonflammable gas greater than 3000 cubic feet, the requirements are the same as those for hospitals, which are found in section 4- of NFPA 99. However, for quantities less than 3000 cubic feet, there is a difference in storing nonflammable gas cylinders is in the 300 cubic feet or less quantity. Hospitals have the advantage of having a special dispensation granted by The Centers for Medicare & Medicaid Services (CMS), in the form of S&C Letter 07-10, published January 12, 2007. In this letter, CMS allows hospitals (but not medical offices or clinics) the advantage of following the 2005 edition of NFPA 99, which permits quantities up to 300 cubic feet of nonflammable gas per smoke compartment to not be stored in any special rooms or areas. This exception for ‘up to 300 cubic feet’ is not found in the 1999 edition of NFPA 99. Therefore, your business occupancy must store all nonflammable gas cylinders in quantities from 0 to 3000 cubic feet in accordance with section 8-, which requires a specially designated room which has a door capable of being locked, and all oxidizing gases in this room must be separated from combustibles by 20 feet (or 5 feet if the room is protected with automatic sprinklers), or the oxidizing gases are to be stored in a flammable cabinet with a fire rating of at least 30 minutes.