Emergency Department Classification

Q: Should Emergency Departments be classified as healthcare, ambulatory healthcare, or business occupancies?

A: According to the 2012 Life Safety Code, a typical Emergency Department (ED) may be classified as healthcare or ambulatory care occupancies, but never business occupancy. The patients brought to a typical ED are not necessarily ambulatory or put in the NFPA vernacular, “capable of self-preservation”. So that would eliminate the business occupancy as a choice.

But informal communications from CMS reveals that they do not agree with this interpretation, entirely. While the typical ED does not provide sleeping rooms, it is understood that the ED may have 24-hour observation beds. In the way that CMS thinks, they consider these 24-hour observation beds as sleeping accommodations, so the designation of healthcare occupancy is mandatory.

Now, if your ED does not have 24-hour observation beds, then it is clear the ED could be classified as ambulatory healthcare occupancy.

Other issues that hospitals may have in deciding whether to classify the ED as ambulatory care or healthcare occupancy are:

  • A 2-hour fire rated barrier is necessary to separate ambulatory care occupancy from the rest of the hospital that is classified as healthcare occupancy;
  • Exiting from the healthcare occupancy through the ambulatory has to meet all of the requirements for healthcare occupancy, unless there is a horizontal exit involved;
  • Suites are permitted in ambulatory occupancies, and according to the 2012 Life Safety Code, they are allowed to be unlimited in size, but still have certain travel distance limitations;
  • Corridors in ambulatory care occupancies are only required to be 44 inches wide in clear width;
  • As long as the ambulatory care occupancy is a single tenant, or as long as the ambulatory care occupancy is fully protected with automatic sprinklers, rooms are not required to be separated from the corridors. Therefore, there are no requirements for doors to ED exam rooms, and if they do have doors, they are not required to positively latch.

Most of the times that I have observed organizations classify their EDs as ambulatory care occupancies, it was due to the fact that the ED did not qualify as a suite as described in the healthcare occupancy chapters, but they wanted to take advantage of the 44 inch wide corridors issue, and the no-door issue permitted in the ambulatory care occupancy. That would allow them to pretty much maintain the ED similarly to a suite, with some limitations.


Brad Keyes
Brad Keyes, CHSP

Brad is a former advisor to Healthcare Facilities Accreditation Program (HFAP) and former Joint Commission LS surveyor. He guides clients through  organizational assessment; management training; ongoing coaching of task groups; and extensive one-on-one coaching of facility leaders. He analyzes and develops leadership effectiveness and efficiency in work processes, focusing on assessing an organization’s preparedness for a survey, evaluating processes in achieving preparedness, and guiding organizations toward compliance. 

As a presenter at national seminars, regional conferences, and audio conferences, Brad teaches the Keyes Life Safety Boot Camp series to various groups and organizations. He is the author or co-author of many HCPro books, including the best-selling  Analyzing the Hospital Life Safety Survey, now in its 3rd edition. Brad has also authored a variety of articles in numerous publications addressing features of life safety and fire protection, as well as white papers and articles on the Building Maintenance Program. Currently serving as the contributing editor of the monthly HCPro newsletter Healthcare Life Safety Compliance  gives Brad further insight into the industry’s trends and best practices.