In the last post that I made, I mentioned ‘Hot Work’ in construction sites in a hospital require special fire barrier protection, which is a 1-hour fire rated barrier from the floor to the deck above, between the construction and any occupied areas. This is found in NFPA 241 Standard for Safeguarding Construction, Alterations, and Demolition Operations (2000 edition), section 8.6.2. Now, Joint Commission does not enforce this level of protection, and all they require is flame resistant smoke-tight barriers that extend from the floor to the ceiling, mainly because the 2000 edition of the Life Safety Code only references the 1996 edition of NFPA 241, and not the 2000 edition of NFPA 241. The 1996 edition of NFPA 241 did not require the 1-hour barriers around ‘Hot Work’, only flame resistant smoke-tight barriers.
As a hospital facility manager, you need to be aware of this difference because many of the state agencies who survey on behalf of CMS will enforce NFPA 241 (2000) requirements. Here are examples of what ‘Hot Work’ can be:
- Cutting with a torch
It is suggested that you review your own policies on construction barriers and consider having 1-hour fire rated barriers whenever any ‘Hot Work’ is being done on a demolition, renovation, construction or remodel project.
There may be times when a service technician will need to use an open flame torch to solder or braze a fitting for a repair function. While this should be tracked and covered with your own ‘Hot Work Permit’ program, it is important to identify that it is not construction and 1-hour fire rated barriers are not required.
NFPA does not define ‘construction’ so I turned to the dictionary which says construction is: The act of putting together to form an assembly. So, remodeling something, or a renovation process appears to me to be construction and would require the 1-hour barriers for ‘Hot Work’. But repairs would not.
But my opinion does not count. Since NFPA does not clearly define what ‘construction’ is, the authorities having jurisdiction (AHJ) are the ones who get to make this determination. Don’t be caught by surprise: If you haven’t already done so, I suggest you contact you local and state AHJs and ask them what they require for fire barriers when you have ‘Hot Work’ in construction sites inside the hospital.