Separation of Different Occupancies

Q: There is an existing clinic which is classified as business occupancy that leases space within a rehabilitation and nursing center. Does this need to be separated by a 2 hour rated partition? Does the egress corridor from the clinic to the exterior need to be rated?

A: Uhm… my answer is … it depends. You state the clinic is a business occupancy, but you did not state what occupancy the rehabilitation and nursing center is. I’m not sure what you mean by a ‘nursing center’… is that a hospital, a nursing home, or is it something else? Is the rehabilitation center classified as a hospital or a nursing home? Or is it outpatient only? Are there any patients in the rehabilitation center that are incapable of self-preservation? If so; how many?

If the rehabilitation center and the nursing center is a different occupancy than the clinic (which you say is a business occupancy), then yes, the different occupancies must be separated by fire rated barriers. The fire rating of these barriers depends on whether or not the occupancy (other than the business occupancy) is healthcare occupancy. Where healthcare occupancy is separated from any other occupancies, the fire rating on the barrier must be 2-hours. However, if the occupancy of the rehabilitation and nursing center is not healthcare occupancy, then the fire rating on the barrier separating the occupancies is only required to be 1-hour rated.

Corridors in new construction business occupancies must be constructed with 1-hour fire rated walls, according to section 38.3.6.1 of the 2012 LSC. But the exceptions to 38.3.6.1 say the requirement for 1-hour fire rated walls does not apply:

  • Where exits are available from an open space;
  • Within a space occupied by a single tenant;
  • Within buildings protected throughout by an approved sprinkler system.

If the business occupancy is considered existing construction, then there are no requirements for the corridor walls. If the rehabilitation and nursing center exits into and through the business occupancy, then the corridor in the business occupancy must meet the requirements for corridors in the occupancy where the rehabilitation and nursing center is located.

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.