Deactivating a Magnetic Lock

Q: When deactivating a magnetic lock but leaving it in place, what is the exact/excepted wording used noting that this magnetic lock is no longer in use?

A: What you are saying is not compliant with section 4.6.12.3 of the 2012 LSC which says existing life safety features obvious to the public, if not required by the LSC, shall be either maintained or removed.

If you want that maglock out of service, you must remove it since it is obvious to the public. 

 

Sprinklers in Lieu of Smoke Detectors

Q: We are seeking to reduce activation of smoke heads contained in our construction areas. In your opinion, if the construction area has existing sprinkler coverage or if new active sprinklers are installed in the construction area, would it be acceptable to remove the smoke heads in this space? In other words, are sprinklers a proper substitute for smoke heads?

A: No… sprinklers are never an acceptable substitute for smoke detectors, because sprinklers do not sense the presence of smoke. Conversely, smoke detectors are never an acceptable substitute for sprinklers because they do not extinguish a fire. However, if the smoke detectors are not required by code or regulation, then they can be removed without any alternative life safety measures applied.

According to 4.6.10.1 of the 2012 Life Safety Code, only deficiencies of required features of life safety necessitate alternative life safety measures (ALSM), also known as Interim Life Safety Measures (ILSM). However, be aware that not all surveyors will likely understand this and they may cite an organization for impaired smoke detectors even if the smoke detectors are not a required feature of life safety.

It is not uncommon for designers to over-install smoke detectors and place them in areas where they are not required. But if the smoke detectors are required, and you desire to remove them for construction purposes (not a bad idea) then you will have to assess them for ALSM and likely implement a fire watch, which can be very costly since it is now required to have a continuous fire watch. Replacing the smoke heads with heat detectors still does not change the result. If the smoke detectors are required then a heat detector is not an acceptable substitute.

Air Handler Unit

Q: Can we have a fan unit installed in a clean supply room? We have a room where an air handler unit is installed for cooling another equipment room. The unit is in the open and clean supplies are near it. Is this a violation of a code or standard?

A: Sounds like the room is now a mechanical room with clean supplies in it. As far as the Life Safety Code goes, and any referenced NFPA standards, I don’t see a problem. You must maintain 36-inches clearance around the equipment and have clear access to the unit. All electrical connections need to be enclosed (inside junction boxes, etc.).

If the clean supplies are combustible, then the room must be constructed to be a hazardous room. Check with your state and local AHJ to determine if they have any other requirements.

Business Occupancy Smoke Detectors

Q: What are the requirements for the use of smoke detectors in a business occupancy physician office that does not have an automatic sprinkler system? The fire marshal is telling me that this is not required, but I cannot find a specific clause in NFPA and want to confirm that statement.

A: The fire marshal is sort-of correct. Smoke detectors are not mandatory in a business occupancy, if the building already has manual pull stations. According to section 39.3.4.2 of the 2012 LSC, only one of the following means to initiate of the fire alarm system is required:

  • Manual pull stations
  • Smoke detectors
  • Sprinkler system water-flow

Of course, you can have more than one type to initiate the fire alarm system, but if you have manual pull stations, then smoke detectors are not required. But, if you don’t have manual pull stations or a sprinkler system, then smoke detectors would be required if the building requires a fire alarm system. Some smaller business occupancies do not require a fire alarm system. Check with your state and local authorities to see if they have other regulations concerning initiating devices.

Exit Enclosures

Q: I have been reading about stairwells and what the code addresses. I am interpreting that the AHJ’s are stringent of what can be placed in a stairwell. Is it permissible to install wireless access points (antenna) in the stairwell? We have no phone coverage in the stairwells because of the absence of these antennas. I believe without phone coverage creates a safety issue. If an emergency would arise in the stairwell we do not have access to contact anybody.

A: Well… section 7.1.3.2.1 (10)(b) of the 2012 LSC does say electrical conduits serving the exit enclosure are permitted to penetrate the exit enclosure, but the Annex section clarifies that the only electrical conduits permitted to penetrate the exit enclosure are those serving equipment permitted in the exit enclosure, such as security equipment, PA systems, and fire department emergency communication devices. Wireless access point antennas typically are not considered essential equipment in the stairwells and does not meet the intent of the list identified in the Annex section.

While you may get a local AHJ to approve such an installation, I think you will have trouble with national AHJs for accreditation. I suggest you install your antennas outside of the stairwell.

Lower Bottom Rods

Q: My department is assisting with a fire/smoke barrier door assessment. I have noticed that some of the ¾-hour corridor doors have had the lower bottom rods removed from the latching hardware with cups still visible in the floor. It is unclear why they were removed however the top latches still work and secure the door. There are small screw holes in the door as well where the hardware was removed. My thoughts are the door has been modified and no longer compliant. What are your thoughts?

 A: You are absolutely correct… By your description, the lower bottom rods were required when the door was installed, but have since been removed (They do get hit and bent by carts and are simply removed rather than replaced by poorly informed maintenance staff.) This door no longer meets the UL listing it received by the manufacturer when it was installed, and should be flagged as not passing an annual inspection.

ABHR Dispensers in Business Occupancy Corridors

Q: Do you know of any other information on alcohol-based hand-rub (ABHR) dispensers not allowed in the egress corridors of business occupancies? I need more information than what you have already posted:

Please be aware that alcohol-based hand-rub (ABHR) dispensers are not permitted in the egress corridors of Business Occupancies. This is found in section 38/39.3.2.1 of the 2012 Life Safety Code which references section 8.7 of the same code. Section 8.7.3.2 states: “No storage or handling of flammable liquids or gases shall be permitted in any location where such storage would jeopardize egress from the structure…” Since corridors are used as paths of egress in business occupancies that means ABHR dispensers are not permitted in business occupancy corridors. Now, sections 18/19/20/21.3.2.6 of the 2012 Life Safety Code allows ABHR dispensers in corridors of healthcare occupancies and in ambulatory health care occupancies…. but not business occupancies.

A: Nope… that’s all there is. It is very clear that the Life Safety Code does not permit the storage or handling of flammable liquids in egress areas, based on section 8.7.3.2. However, the Life Safety Code makes specific exceptions for healthcare occupancies (i.e. hospitals, nursing homes, long term care centers, etc.) and ambulatory health care occupancies (ASC, physical therapy units) based on section 18/19. 3.2.6 and 20/21.3.2.6. The problem is, these exceptions do not apply to Business Occupancies and chapters 38/39 do not contain anything that would over-ride 8.7.3.2.

Is a Fire Watch Necessary?

Q: We have a complete gut renovation project that consist of two buildings (Admin. Bldg. & Lab Bldg.). The buildings are connected in all three levels and will be unoccupied. Both buildings are connected on the first level only to the adjacent occupied building. A one-hour barrier will be built to separate the occupied building from the construction areas. Is a fire watch required once the sprinklers system and fire alarm system is demolished?

A: According to section 9.6.1.6, whenever a required fire alarm system is out of service for 4 or more hours in a 24-hour period, you are required to do the following:

  • The AHJ must be notified. Don’t forget to notify your state AHJ, your insurance company AHJ, as well as your local AHJ. There is no need to notify your accreditation AHJ.
  • The building must be evacuated, or an approved fire watch must be conducted. An approved fire watch consists of a designated, trained individual who has no other responsibilities, continuously patrols the entire area affected by the outage looking for signs of fire and potential situations where fire could start, and has the ability to communicate to call the local fire responders in case of fire. This individual cannot leave the impaired area until the fire watch is discontinued or is relieved by another designated, trained individual.

So, you are saying these buildings will be unoccupied, so it appears you do not have to conduct a fire watch for the impaired fire alarm system, provided you have a 2-hour fire-rated barrier separating the unoccupied building and the occupied building. But let’s look at NFPA 25-2011, section 15.5.2 which says this about sprinkler impairments: Before authorization is given, the impairment coordinator shall be responsible for verifying that the following procedures have been implemented:

  1. The extent and expected duration of the impairment have been determined;
  2. The areas or buildings involved have been inspected and the increased risks determined;
  3. Recommendations have been submitted to management or the property owner or designated representative;
  4. Where a required fire protection system is out of service for more than 10 hours in a 24-hour period, the impairment coordinator shall arrange for: A) Evacuation of the building or portion of the building affected by the system out of service; B) An approved fire watch, which must be the same as the approved fire watch described above; C) Establishment of a temporary water supply; D) Establishment and implementation of an approved program to eliminate potential ignition sources and limit the amount of fuel available to the fire;
  5. The fire department has been notified;
  6. The insurance carrier, the alarm company, property owner or designated representative, and other authorities having jurisdiction have been notified;
  7. The supervisors in the areas to be affected have been notified;
  8. A tag impairment system has been implemented;
  9. All necessary tools and materials have been assembled on the impairment site.

So, again since you have an unoccupied building, it appears to me that you do not have to conduct a fire watch for an impaired sprinkler system, provided you have a 2-hour fire-rated barrier separating the unoccupied building and the occupied building. Item #4 above clearly states a fire watch is not required if you have evacuated the building.

Business Occupancy Soiled Utility Room

Q: Do business occupancy buildings with soiled utility rooms have to be one-hour fire-rated or just sprinkled if the building falls under a hospital license and will be inspected by State and CMS surveys?

A: It depends…. Is the soiled utility room used for general storage? In business occupancies, soiled utility rooms are not considered outright to be a hazardous area like they are in healthcare occupancies. However, many soiled utility rooms are also general storage rooms, and section 38/39.3.2.1 of the 2012 Life Safety Code specifically says general storage rooms are considered hazardous areas and must be maintained in accordance with section 8.7. Section 8.7.1.1 says the room needs to be either 1-hour fire rated or protected with sprinklers.

Whether or not the business occupancy falls under the hospital license is not a factor, regardless who inspects the building. The LSC is clear: If used for general storage, then the room is either sprinklered or 1-hour fire rated. If the room is not used for general storage, then there is no requirement. This is based on its occupancy; not its license.

Clinical Needs Locks

Q: For clinical needs locks, can occupants pass through four locked doors (patient room door, a cross-corridor door, another cross-corridor door, and a door at exit discharge) in a required single path of egress? (All options have 4 locked doors in the path.)

A: The 2012 Life Safety Code does not address any restrictions on how many doors in the path of egress may be equipped with Clinical Needs locks. Therefore, if the LSC does not prohibit it, then it is permitted.

However, not all AHJs permit it. For example; I am told that the IBC prohibits more than one Clinical Need lock in the path of egress (or, at least they used to). When I worked at the hospital, I tried to get the state to allow two locked doors in the path of egress from the Psychiatric unit but they would not allow it.

But in my travels, I have seen multiple doors in the path of egress equipped with Clinical Needs locks where permitted in various states around the country. The most common use of multiple Clinical Needs locks create a ‘Sally Port’ or ‘airlock’ that allows one locked door to open but the other locked door must be closed. This is an added security to prevent anyone from eloping.

So, the LSC does not prohibit it, but the IBC and some AHJs do.