GFCI Receptacles

Q: Where can I find the requirements for ground-fault circuit interrupters (GFCI) protection in the dietary/kitchen area of a nursing home? I thought it was 6′ within a water source. But when I look in the 2011 NEC it does not say that. The way I read it, it is everywhere in the kitchen/dietary that is 110v. What is your thought, and where can I find the clarification?

A: According to NFPA 70-2011, section 210.8, says:

All 125-volt, single-phase, 15- and 20-ampere receptacles installed in the locations specified in 210.8(A)(1) through (8) shall have ground-fault circuit interrupter protection for personnel.

(6) Kitchens— where the receptacles are installed to serve the countertop surfaces

(7) Sinks — located in areas other than kitchens where receptacles are installed within 1.8 m (6 ft) of the outside edge of the sink

While section 210.8 is discussing receptacles in dwelling units, there does not appear to be a specific standard in NFPA 70-2011 regarding GFCI receptacles in kitchens in healthcare facilities.

Surveyors will often use section 210.8 in assessing GFCI compliance in healthcare occupancies.

Fire Drills

Q: There is a lot of confusion on how many fire drills we have to complete. We have 3 towers where there is healthcare, all connected, but different building names. Do we only need to complete 1 fire drill per shift per quarter in EACH building or can we combine the 3 towers into one healthcare? They are breaking out each tower and conducting the required amount in each building, which seems overkill.

A: The intent of the Life Safety Code is to conduct fire drills once per shift per quarter in all healthcare occupancies per building. If you have more than one building on campus that contains healthcare occupancies, then you would have to conduct separate fire drills for each shift and each quarter in each building.

However, if the buildings that contain healthcare occupancies are contiguous (connected together) and there is no fire rated barrier serving as a separation barrier between the buildings, then you could do one fire drill per shift per quarter that would cover all the buildings.

A separation barrier would be a fire-rated barrier that is vertically aligned (meaning the barrier does not extend horizontally) from the lowest floor to the roof. The fire rating of the barrier could differ depending on the applicable codes and standards, but the NFPA 101 Life Safety Code would require at a minimum a 2-hour fire rating.

Contiguous Facilities

Q: If an inpatient in a hospital (healthcare occupancy) is taken into a building that is not a healthcare occupancy for say CT or MRI, does this building have to then meet the requirements in the Life Safety Code for a healthcare occupancy?

A: According to section 19.1.3.4.2 of the 2012 LSC, it says ambulatory care facilities, medical clinics, and similar facilities that are contiguous to healthcare occupancies shall be permitted to be used for diagnostic and treatment services of inpatients who are capable of self-preservation. This is new for the 2012 LSC and was not found in the 2000 edition, so not everyone may be aware of this.

But the kicker is “inpatients who are capable of self-preservation”. The inpatient really does need to be capable of taking action for their own self-preservation without the assistance of others.

All healthcare occupancy inpatients, even if it is just one inpatient, that are brought into a contiguous facility that is not a healthcare occupancy for diagnostic or treatment purposes must be capable of self-preservation. Otherwise, it is not permitted.

Exiting from Hospital into Medical Building

Q: A main circulation corridor in a Hospital (Institutional Use I-2, 8′ wide) passes thru the 2-Hr Use Group separation of adjacent medical offices (Business Use B) and re-enters the Institutional zone (2-Hr wall) for egress to a fire egress stair. Building has automatic sprinkler system. Are egress corridor movements between Institutional and Business Use permitted? Must all sections of that corridor sequence maintain a consistent width of 8′ clear?

A: [Boy… I wish you architects would use NFPA nomenclature instead of IBC…]. If I understand your question correctly, my reply would be yes… you can exit from the hospital into a business occupancy, but there are extenuating circumstances. Section 6.1.14.1.2 of the 2012 LSC says when an exit access (i.e. corridor) from an occupancy traverses another occupancy, the multiple occupancy must be treated as a mixed occupancy. For you, that means the most restrictive occupancy requirements apply, which in your case would be healthcare occupancy.

So, this means everything required for healthcare occupancy must be met in the business occupancy building, such as:

  • Construction type
  • Fire alarm system
  • Sprinklers
  • Fire-dampers/smoke dampers
  • Corridor width
  • Corridor doors
  • Fire safety plans
  • Door latching and locking requirements
  • Etc.

However, if you can call the 2-hour fire barrier separating the healthcare occupancy from the business occupancy, a horizontal exit, then you would not have to meet the requirements of healthcare occupancy, in the business occupancy building.

Hazardous ER Department

Q: In a hospital emergency department, can the corridors be 6 feet wide? Can the hospital install an 18-inch deep lockable computer cabinet in the 8 foot ED corridor?

A: Well… It depends.

If you claim the ER is a suite, then there would be no problem with a cabinet in the 8-foot wide hallway…. Because there are no corridors in a suite. What looks like a corridor in a suite is a communicating space and you would only have to maintain 36-inches clearance for aisles.

But if the ER is not a designated as a suite, then you must maintain corridor widths. But the required width of the corridor is different depending on the occupancy classification of the ER. CMS has said that Emergency Departments must be classified as healthcare occupancies (HCO) if the ER has patient observation beds. CMS’s logic on this is if patients are under observation in the ED, then they consider this patient sleeping accommodations. In this logic, then all areas providing patient sleeping accommodations must be healthcare occupancies, and the required width of the corridor must be 8-feet.

However, CMS does permit the Emergency Department to be classified as an ambulatory health care occupancy (AHCO) if the ER does not contain any patient observation beds. Then the corridor width is only required to be 44-inches wide.

But keep in mind, the maximum corridor projection permitted by CMS is 4-inches. If your ER is not designated as a suite, then you must maintain corridor widths (either HCO widths of 8-feet, or AHCO widths of 44-inches) and you cannot have corridor projections more than 4-inches, and the cabinet would not be permitted.

Healthcare vs. Ambulatory Healthcare Occupancy

Q: A surgery suite (5 ORs), PACU (8 bays), and ASU (17 rooms), newly built on the 3rd floor of a business occupancy building. A 2 hour box was constructed all the way around the floor (above, below, adjacent) and it was designed to meet healthcare occupancy. These are the operating rooms not only for ambulatory surgery (same day) patients but for the hospital’s in-patients as well. How should this area be classified in regards to occupancy designation? Does the potential for a large number of in-patients in the units mean it gets classified as healthcare even if there is no overnight sleeping?

A: One may agree with your logic that as long as there are not any overnight sleeping rooms provided within the unit, it could be classified as an ambulatory healthcare occupancy. But, to take an inpatient out of the healthcare occupancy and perform surgery on them in the ambulatory healthcare occupancy seems to be contrary to the intent of having different occupancies. Is the patient an inpatient or an outpatient? If inpatient, they have surgery in healthcare occupancies. If an outpatient, they have surgery in an ambulatory healthcare occupancy.

The bottom line… You are bringing inpatients from the hospital into the surgery area, therefore the surgery area must be healthcare occupancy. From my perspective, healthcare organizations should not be taking inpatients out of healthcare occupancies to ambulatory healthcare occupancies to perform surgery on them.