Smoke Compartments in ASC

Q: We are a freestanding ambulatory surgical center (ASC) and we only perform gastrointestinal (GI) procedures, not surgery. We lease a suite on the ground level in a 3 story building with multiple tenants. During a recent state inspection, I was asked where our smoke compartments are located. I know that we have a 2-hour fire barrier between us and the other suites on our level, but I am not aware that we have any designated smoke compartments. Do we need smoke compartments?

A: You did not mention how many patients are incapable of self-preservation at any one time, so I will assume it is at least 4 or more patients, since that is the threshold to decide if the ASC is required to comply with ambulatory health care occupancy requirements, or business occupancy requirements. Ambulatory health care occupancy smoke compartment requirements are found in section 21.3.7.2, which requires your ASC to be sub-divided into not less than two smoke compartments. However, there are some exceptions to this requirement:

  1. ASC facilities that are less than 5,000 square feet and are protected by an approved smoke detection system do not need to be sub-divided.
  2. ASC facilities that are less than 10,000 square feet and are protected throughout by an approved automatic sprinkler system do not need to be sub-divided.
  3. An area in an adjoining occupancy may be permitted to serve as a smoke compartment for the ASC facility, provided all of the following criteria is met:
  • The separating barrier must be at least 1-hour fire rated, and have doors that are self-closing.
  • The ASC facility is less than 22,500 square feet.
  • Access from the ASC facility to the other occupancy is unrestricted.

So, to answer your question, based on the size of your ASC and whether it has smoke detection or sprinkler protection, it may not require a smoke compartment barrier. If a smoke compartment barrier is required, you might be able to utilize the 2-hour fire rated barrier between you and your neighbors, if you are less than 22,500 square feet and if there is unrestrictive access to the other occupancy.