Construction Involving the Fire Alarm System

Q: Our projects team currently disables our fire alarm control panel each morning during periods of construction and restores the panel each evening. They do this to prevent unwanted fire alarms that would be a nuisance to our staff and local fire department. This doesn’t seem to me to be the best method to deal with construction and the fire alarm panel. Do you have any thoughts or suggestions on this topic?

A: Your message did not address whether or not Interim Life Safety Measures (ILSM) are implemented during the time the fire panel is disabled, and that would be my number 1 concern. Section of the 2000 edition of the Life Safety Code® (LSC) discusses alternative life safety measures acceptable to the authority having jurisdiction (AHJ) need to be in place whenever construction, repair, alterations or additions are in progress. Also, section requires the AHJ shall be notified and a fire watch be implemented (or evacuate the entire facility, which is not desirable) whenever the fire alarm system is out of service for 4 or more hours in a 24 hour period. Those are mandatory actions that need to be followed. Other option, in lieu of disabling the entire fire alarm system, is to just remove from service the specific detectors or initiating circuit in the construction area, although you would still have to follow ILSM procedures. Most modern fire alarm systems have the ability to program initiating devices out-of-service to allow construction activities. Another option is to physically remove the detectors from their bases if this is possible. Some hospitals place protective coverings over smoke detectors during time of construction, although I am not a supporter of that practice. I have seen multiple situations where someone forgot to remove the protective cover from the detector and it remained in place long after the construction was completed. The bottom line is this: You need to develop a plan for alternative measures that is acceptable with your AHJ, presumably the local fire department, whenever a feature of fire safety is impaired. You are also required to develop a ILSM policy with written criteria for evaluating when and to what extent you should follow special measures to compensate for an increase risk to life safety, if your are accredited by the Joint Commission.


Stairwell Closed for Construction

Q: We have a stairwell in our hospital that extends from the 8th floor to the 1st floor, where there is a door that discharges the occupants to the outdoors. We have construction in progress on the 2nd floor, which affects the stairwell and we have closed the stairwell at the 2nd floor level, however, we have allowed the stairwell to remain open from the 3rd floor to the 8th floor. Our safety officer thinks allowing people to travel from the 8th to the 3rd floors in a stairwell that is closed on the 2nd floor is not allowed, and wants to close the entire stairwell. This would be a hardship for our staff that wants to use the stairs rather than wait for an elevator. Do we have to close the stairwell entirely, or can we allow it to remain open on the upper floors?

A: Construction projects never make it easy on facility managers and safety officers, do they! My answer to your question is dependent on the precautions and alternative measures that you have implemented. First let me say that when working with something that is such an integral part of safety such as an exit stairwell, the most effective safety precautions should be taken. If it were my decision, I would agree with your safety officer and want to shut the entire stairwell down as the construction project has caused the path of egress to be obstructed.  However, there is another option. If you implemented the appropriate Interim Life Safety Measures (ILSMs) and provided adequate signage on each floor declaring the stairwell is no longer an exit, explaining that it now terminates at the 3rd floor, and if you provided adequate signage explaining where the closest alternative exit is located, then you would be able to allow the stairwell to be used for communicating purposes to get from floor to floor, and it is no longer an exit. Any ‘Exit’ signs that direct the path of egress towards and into this stairwell would have to be covered or removed and the construction in progress would have to be separated from the occupants in the stairwell with appropriately rated materials. Other ILSMs would have to be considered as well, according to your hospital’s policy. While this would not be my first choice, I agree that this modified use of the stairwell would be permitted by the NFPA 101 Life Safety Code (LSC), 2000 edition.

Construction Type Barriers vs. Occupancy Separation Barriers

Q: I read with interest the article Understanding the Importance of Construction Types in the February, 2011 issue of HLSC. The article said a 2-hour fire resistance horizontal barrier is not allowed to separate different construction types, only vertical barriers. Isn’t a 2-hour rated floor assembly permitted to separate different construction types? Isn’t a 2-hour barrier sufficient to distinguish a barrier between different buildings?

A: You may be confusing different purposes for a 2-hour fire resistance rated barrier. Separating different construction types requires a 2-hour vertical barrier. Separating different occupancies that involves healthcare requires a 2-hour vertical and/or horizontal barrier. Section 8.2.1 of the 2000 edition of the Life Safety Code® (LSC) only permits vertical 2-hour fire resistance rated separations between different construction types, and does not permit horizontal barriers. The reason behind this requirement is very logical. The requirement for the fire resistance rating of construction types is based on the estimated time it takes to evacuate the building in the event of a fire. Most multi-story hospitals are required to be at least Type II (222) construction which allows for the extra time it would take to evacuate non-ambulatory patients from the building. If a lower floor was permitted to be less that Type II (222) construction, even if it were separated by a 2-hour fire rated floor assembly, a fire on the lower floor which has less fire resistance rating on its structural support members may cause the building to collapse before all of the patients are evacuated. Section does not restrict the 2-hour barrier between different occupancies to either vertical or horizontal, therefore they are both permitted.

Temporary Construction Barriers

Q: Our project team insists on using non-combustible plastic sheeting for temporary barriers between construction areas and occupied areas of our hospital. Is this acceptable according to the Life Safety Code (LSC)? I thought we had to have 1-hour fire rated barriers in these applications.

A: The appropriate section of the LSC (2000 edition) that covers construction operations is This section requires the means of egress must comply with section and with NFPA 241 (1996 edition) Standard for Safeguarding Construction, Alterations, and Demolition Operation. Section simply states that the means of egress must be free from obstructions and impediments. However, NFPA 241 has more information on temporary construction barriers.

Section 2-2 of the 1996 edition of NFPA 241 discusses temporary enclosures which are required to be noncombustible panels or flame-resistant tarpaulins or approved materials of equivalent fire-retardant characteristics. This section also requires appropriately sized and type of fire extinguishers be placed inside the enclosure. This is all the 1996 edition says about the requirement for temporary construction barriers.

However, we need to take a look at the 2000 edition of NFPA 241. In this newer edition, NFPA created an entire new section entitled “Temporary Separation Walls” and is found under section 8.6.2. This new section requires a temporary barrier between an occupied portion of the facility and the construction area to be 1-hour fire rated (with 45-minute fire rated doors) when such construction operations are considered to be a higher level of hazard. The 2000 edition permits nonrated walls and doors when an approved automatic sprinkler system is installed, and does not consider construction tarps as appropriate barriers or opening protectives.

So, technically speaking, the 2000 LSC requires compliance with the 1996 edition of NFPA 241, not the 2000 edition. And, as pointed out above, the 1996 edition does not have a requirement for 1-hour fire rated walls for temporary construction barriers. The Joint Commission has previously stated that they will accept noncombustible plastic sheeting for temporary construction barriers, and not require 1-hour fire rated barriers. However, in unofficial conversations with CMS inspectors from various states, I find that many CMS offices across the country will mandate 1-hour fire rated temporary construction barriers regardless what the 1996 edition permits. While it may appear that you have the right to decide when and where a 1-hour fire rated temporary construction barrier is required in your hospital, my advice to you is to contact your local and state authorities and ask what they require, and ask them to quote the standard reference and see which edition they are enforcing.