Separation of Occupancies

Q: Do different occupancies have to be separated by fire-rated barriers both horizontally as well as vertically? We are considering installing a dialysis unit on the second floor of a medical office building and the CMS interpretive guidelines say it must be separated from other tenants on the same floor by a one-hour fire wall. Shouldn’t a horizontal barrier be required as well?

A: Yes, I would agree. The 1-hour fire rated separation that the Life Safety Code (2000 edition), section requires does include horizontal separations as well as vertical. I agree with you that the interpretive guidelines do not clearly state horizontal separations, but the LSC does make the generic statement that the ambulatory care occupancy must be separated from other occupancies with 1-hour fire rated construction, and does not limit the separation to just vertical barriers.

Ambulatory Care Occupancy Sprinklers

Q: We are in the process of renovating an existing two story office building where a dialysis unit will be located on the lower level. According to our state requirements, we have to designate the dialysis area to meet ambulatory care occupancy. We plan on installing automatic sprinklers in the renovated dialysis area, but do we have to install sprinklers in the rest of the building?

A: It depends on the construction type of the building. According to section of the 2000 edition of the Life Safety Code, new construction standards for ambulatory care occupancies will require the installation of an automatic sprinkler system throughout the entire building (even though only part of it is ambulatory care) if the construction type is unprotected (000). Also, if the lower level that the dialysis unit is located on is below the level of exit discharge, then the floor must be at least 1-hour fire rated, unless the entire facility is under your organization’s control and all hazardous rooms are properly protected in accordance with section 8.4.

Conversion from Business Occupancy to Ambulatory Care Occupancy

Q:  We discovered our offsite free standing Dialysis center is in a building that is classified as Business Occupancy, but we were recently told by a consultant that the building has to be classified as Ambulatory Care Occupancy. Is this true? If so, what differences between the two occupancies should we be aware of?

A: It really depends if you are under the authority of CMS or not. If the dialysis center receives Medicare & Medicaid reimbursements, then you must follow CMS’s requirements. In a memo to their state survey agencies (S&C Letter 09-24) dated February 11, 2009, the dialysis unit must be classified as either existing ambulatory care occupancy, or new ambulatory care occupancy. In this memo CMS defines a new occupancy as a dialysis facility that receives their approval for construction on or after February 9, 2009, and they define an existing occupancy which receives approval for construction or renovation prior to February 9, 2009. However, if you are not under the authority of CMS, then the occupancy type is determined by the number of patients in the unit that are incapable of self-preservation. If there are 4 or more patients incapable of self-preservation at any given time, then the unit would have to be considered ambulatory care occupancy. But many authorities having jurisdiction (AHJ) have made the interpretation that all patients on dialysis is incapable of self-preservation, therefore, if you have 4 or more patients in the Dialysis center, then ambulatory care occupancy requirements apply. To be sure, you need to determine how your AHJ interprets the capability of the average dialysis patient to be able to disconnect themself from the machine, arise, and walk out of the unit under their own power, without assistance from anyone. There are differences between ambulatory care and business occupancies. Here is a short-list of ambulatory care occupancy requirements that differ from business occupancy:

  • Construction type: sprinklers required if Type II (000) Type III (000) and Type V (000)
  • Corridor width (44 inches)
  • Two approved exits from the unit
  • Travel distance to the exit cannot exceed 150 feet (200 feet if sprinklered)
  • Minimum door opening is 32 inches
  • A manual fire alarm system
  • Smoke compartment barriers unless the unit is less than 5,000 square feet and protected with smoke detectors, or unless the unit is less than 10,000 square feet and the area is protected with automatic sprinklers
  • A 2-hour fire rated barrier separating the dialysis unit from a healthcare occupancy, or a 1-hour fire rated barrier separating it from any other occupancy

Ambulatory Care Soiled Utility Room

Q: We have an ambulatory healthcare occupancy which has clean supply and soiled linen rooms.  Since these rooms are considered storage with combustibles, the Life Safety Code (LSC) views them as hazardous areas.  These rooms are sprinklered which does not require the room to have 1-hour rated barriers. Do these rooms require doors that need to latch?  It does not appear so, as I read the LSC.

A: You’re right. A soiled utility room in an ambulatory care occupancy that is protected with automatic sprinklers does not require fire rated walls and no doors are required. Sounds strange but this is why: Section 21.3.2 of the 2000 edition of the Life Safety Code refers to section 39.3.2 for protection from hazards, which identifies storage rooms as hazardous rooms that need to comply with section 8.4. This section allows on option to sprinkler the room or to provide 1-hour fire rated walls. If you chose the 1-hour fire rated walls, then you would have to provide a ¾ hour fire rated door and frame, that self-closes and positive latches. But in your scenario, your clean supply and soiled linen rooms were sprinklered, and 8.4 does not require self-closing and latching doors. Also, section 21.3.6 says there are no requirements for corridors, so that means there are no requirements for corridor doors. This is quite different than healthcare occupancy which would require self-closing and latching doors even if the rooms were sprinklered.