Temporary Construction Barriers

Q: Regarding the 2012 Life Safety Code referencing the 2009 edition of NFPA 241 Standard for Safeguarding Construction, Alteration and Demolition Operations which does not allow “tarps” for construction barriers, what is their definition of a tarp? Will using fire resistant sheet poly be allowed or is that now defined as a tarp?

A: The definition of a tarp has yet to be explained. Since the NFPA 241 does not adequately explain it, it will be up to CMS and the accreditation organizations (AOs) to decide if flame retardant plastic sheets are acceptable or not. I suspect some AOs will be lenient and allow the flame retardant plastic, and I suspect some AOs will not, and consider flame retardant plastic sheet to not be acceptable. Until CMS provides a definitive answer, I suspect there will be different interpretations.

Section 8.6.2 of the 2009 edition of NFPA 241 has changed how the temporary construction barriers must be built. Now, a 1-hour fire rated barrier must be constructed to separate a construction area from an occupied area, if the construction area is not equipped with a properly installed active sprinkler system. This means steel studs and 5/8 gypsum board on both sides must be constructed from the floor to the deck above, and include a 3/4 hour fire rated doors assembly that is equipped with a closer and positive latching hardware. And the seams on the gypsum boards will have to be properly taped and mudded with joint compound.

However, if the construction area is protected with a properly installed active sprinkler system, then the temporary construction barrier is permitted to be non-rated. But it quickly says “tarps” are not permitted in the Annex section. That’s where the issue becomes cloudy. It seems without tarps, the only way you can achieve a non-rated construction would be by using steel studs and 1 layer of gypsum board.

The Annex section is not considered part of the enforceable standard, but information is inserted there as a guide to authorities having jurisdiction to help them understand what the technical committee was thinking when the standard was written.

But in conversations with un-named experts who are in a position to know, it appears that the major accreditation organization will not allow flame retardant plastic sheeting for temporary non-rated construction barriers.

I suggest you contact your AO directly and ask them what they will accept, before you are surprised during a survey.

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.