Life Safety Assessments in Business Occupancies

Many hospitals have facilities located offsite or adjacent to the main building which are classified as business occupancies. These buildings may be physician’s offices, clinics, administrative buildings and storage faclities. All too often, the facility manager for the hospital is assigned the responsibility of plant operations and maintenance for these business occupancies, which typically includes life safety compliance.

While these non-healthcare occupancy buildings are classified as a business occupancy, the approach to a life safety assessment would be similar as conducting a life safety assessment for the healthcare occupancy (hospital), but you do not assess them to the same set of standards as you would the hospital. Healthcare occupancies must comply with the core chapters of the Life Safety Code (LSC), which are chapters 1-4, and 6 – 11, and they have to comply with the occupancy chapters 18 and 19. Business occupancies likewise have to comply with chapters 1 – 4, and 6 – 11, but they have a different set of occupancy chapters to comply with; chapters 38 & 39.

Chapter 38 is for new construction and chapter 39 is for existing construction. A facility is considered new construction if its construction plans and documents were approved by the local authorities on or after March 11, 2003. A facility is considered existing construction if its construction plans and documents were approved by the local authorities before March 11, 2003. Also, any renovation conducted in existing construction buildings on or after March 11, 2003 must comply with new construction requirements. Why the date of March 11, 2003? Because that is the date that the Centers for Medicare & Medicaid Services adopted the 2000 edition of the LSC.

Assuming the business occupancies qualify for existing construction occupancy, you must assess the building for compliance with chapter 39. You will find that the life safety requirements are far less restrictive for business occupancies as compared to healthcare occupancies. Examples were there will be significant differences (and leniencies) in compliance, are:

  • Construction Type                          (39.1.6)
  • Overhead Rolling Fire Doors       (
  • Means of Egress Arrangement     (39.2.5)
  • Emergency Lighting                        (39.2.9)
  • Hazardous areas                              (39.3.2)
  • Fire alarm systems                          (39.3.4)
  • Sprinkler systems                            (39.3.5)
  • Corridor walls                                   (39.3.6)
  • Smoke compartments                     (39.3.7)
  • Fire Drills                                           (39.7.1)
  • Fire Extinguisher Training             (39.7.2)

There are other life safety requirements found in the healthcare occupancy chapters (such as elevator recall testing) that are not found in the business occupancies. However, while fire damper testing in healthcare occupancies enjoys a 6-year cycle, that is not the case in business occupancies, which requires a 4-year testing interval.

To make sure that you are assessing your business occupancies correctly, you will have to research each issue individually to determine your level of compliance.