Q: I have a procedure room in our Cath Lab that Administration wants to convert to a storage room. The building is fully sprinkled and as I look at NFPA 184.108.40.206 of the 2012 LSC, it refers me to section 8.7. It would seem that I could use this room for hazardous storage (combustibles) as long as I have a smoke barrier and a self-closing 20-minute door, because that is what section 8.7 permits. The room is over 100 square feet. Other storage rooms in this building are protected with a 1-hour fire rated wall system, that includes a 45-minute fire rated door assembly… so, can I or can’t I use non-rated smoke partitions for this new storage room?
A: Well… not quite. You have the right idea, but section 220.127.116.11 of the 2012 LSC over-rides section 8.7. Take a look at 18.104.22.168 which says any hazardous area shall be protected in accordance with section 8.7, and the areas described in Table 22.214.171.124 shall be protected as indicated. Table 126.96.36.199 says storage rooms larger than 100 square feet and storing combustible material requires 1-hour fire rated barriers. You state your former Cath lab procedure room is more than 100 square feet, so by the looks of things, this is the governing statement on new hazardous rooms.
However, there may be an exception that might apply to your situation. There is a new chapter in the 2012 LSC that was not in the 2000 edition: Chapter 43, which is on building rehabilitation. Take a look at 188.8.131.52 which says a change of use that does not involve a change of occupancy classification shall comply with the requirements applicable to the new use in accordance with the applicable existing occupancy chapter, unless the change of use creates a hazardous contents area as addressed in 184.108.40.206.
Looking at 220.127.116.11 (2), it says for existing healthcare occupancies protected throughout by an approved, supervised automatic sprinkler system in accordance with 18.104.22.168 (1), where a change in use of a room or space not exceeding 250 square feet results in a room or space that is described by 22.214.171.124.5 (7), the requirements for new construction shall not apply, provided that the enclosure meets the requirements of 126.96.36.199.2 through 188.8.131.52.4.
Okay… what this is saying is the change in use of the Cath lab procedure room to a storage room that is a hazardous room, does not have to meet new construction requirements for hazardous rooms (i.e. 1-hour fire rated barriers and ¾ hour fire rated door assembly), but may comply with existing construction requirements for hazardous rooms (i.e. smoke partitions and non-rated self-closing door), PROVIDED:
- The room does not exceed 250 square feet
- The entire building is protected with sprinklers.
Measure the area of the old Cath lab procedure room. If it does not exceed 250 square feet, then you do not have to meet 1-hour fire rated barrier requirements. However, if it does exceed 250 square feet, then I’m sorry to say, you do have to meet 1-hour fire rated barrier requirements, with a ¾ hour fire rated door assembly.