Path of Egress Through a Construction Area

Q: Are there any problems with maintaining an emergency exit for a hospital OR area that travels through an adjacent construction project? Also, can these doors be taped or sealed with a tape/barrier to limit construction dust?

A: In regards to your first question, what would your infection control practitioner say about exiting OR patients (who could possibly have open incisions) into and through a construction area? I’m sure that the IC person would have a fit about that. No… you can’t exit OR patients into and through a construction area. A construction area is typically a dirty, hazardous area depending on the level of demolition and construction. Section 7.5.1.6 of the 2012 Life Safety Code does not permit exiting through a hazardous area. Taping the seams and jamb of a door to prevent dust and dirt contamination would be a good approach to prevent dust and dirt from transferring from the construction to the clean side, but you can’t tape a door closed if the Exit signs tell you that is the path of egress.

You have to close the path of egress if the path is under construction. That is what alternative life safety measures are for (aka Interim life Safety Measures, or ILSM). It is okay to close one path of egress for the needs of construction as long as you conduct an assessment to evaluate what ILSMs are to be implemented. Then you follow what your ILSM policy says regarding closed (or obstructed) exits.

But you can’t tape a door shut that is in the path of egress and expect staff to use that door in the event of an emergency. And you need to come up with alternative measures to compensate for closing that path of egress. It is my observation that project people are not all that familiar with the ILSM method. It’s okay to close an exit if you have to remodel that exit. That’s why the LSC has a standard on ILSM. Most project people don’t know this and they try to maintain what they think has to be: two forms of exiting.

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.