Q: We previously built personal protective equipment (PPE) cabinets that are permanently mounted to the wall. These cabinets protrude in to the hallway 5-inches. The previous NFPA guidelines allowed 6-inch projections so we were within the limits. Now, the new NFPA 2012 decreased that projection allowance to 4-inches. Since these are isolation cabinets, are they allowed to stay in the hallway?
A: Well… you’re not quite correct…
The 2012 LSC actually does permit 6-inch projections into corridors. See section 188.8.131.52 (2). What has changed is the CMS Final Rule to adopt the 2012 Life Safety Code and the 2012 NFPA 99 Health care Facilities Code, where CMS said they will enforce the ADA requirements of a maximum corridor projection of 4-inches.
And this does apply to existing conditions where the removal of barriers to accessibility are readily achievable. So, since CMS adopted the 2012 LSC on July 5, 2016, this 4-inch maximum corridor projection rule does apply to new and existing conditions. And no, the cabinets are not allowed to stay in the corridor just because they are isolation supply cabinets.
You do have a few options:
- Look into converting the area where your PPE cabinets are installed to be a suite-of-rooms, which eliminates the corridors and the 4-inch rule goes away;
- Consider not doing anything and when (or if) you get cited, apply for a waiver based on ‘financial hardship’;
- Remove the cabinets.