In September, the International Code Council (ICC) completed the second cycle of code changes resulting in the 2009 edition of the International Codes.
This article highlights changes of significant interest to health care facilities. Readers should remember that the 2009 edition of the International Codes will be available in early 2009 but will have no immediate impact on health care facilities until they are adopted by appropriate regulatory agencies.
Existing buildings
One of the more significant changes that affects all existing health care occupancies is a requirement that existing health care facilities be protected with automatic sprinkler protection. The provision is located in the International Fire Code and thus applies to existing buildings. The requirement is that sprinkler protection be provided on any floor containing a health care occupancy and all floors between the health care occupancy and the level of exit discharge.
The substantiation submitted with the code change proposal focused on nursing home fire data and referenced the National Fire Protection Association’s NFPA 101 Life Safety Code for sprinkler protection in existing nursing homes. However, the language that will appear in the International Fire Code applies to all health care occupancies.
The change does not require the entire building to be protected with automatic sprinkler protection. However, should a facility choose to provide sprinkler protection only on the floors required, the International Codes would not allow many of the modifications permitted by NFPA 101 for smoke compartments protected with automatic sprinklers. This is because the International Codes require the entire building to be protected with automatic sprinklers for many of the modifications to apply.
Ambulatory care facilities
The International Codes previously have not contained specific provisions for ambulatory care facilities. Outpatient clinics were defined as a business use group, and the intent of the health care provisions was that they applied to facilities providing overnight patient accommodations.
Ambulatory health care facilities will still be considered a business use group, but special requirements will apply. Thus, the 2009 edition of the International Building Code will contain provisions for ambulatory care facilities.
Although several proposals were submitted, the one that was eventually approved was submitted by the Washington Department of Health and for the most part was modeled after the NFPA 101 Life Safety Code requirements. However, the final version approved by ICC members has some differences. One of the most notable differences is a requirement to provide sprinkler protection in fire areas containing an ambulatory care facility.
In many instances, a two-hour fire separation will be required to consider an adjacent space a different fire area. Therefore, sprinkler protection may be required throughout most buildings containing an ambulatory care facility. In addition, if the building is not protected throughout with an automatic sprinkler system, automatic smoke detection is required in any fire areas containing an ambulatory health care facility.
More specific territory
Moving into more specific territory, changes in individual building elements include the following:
Locking arrangements. Numerous proposals were submitted to provide some additional options for locking doors in health care occupancies, similar to those that exist in NFPA 101. The language that was approved references “approved delayed egress locks.”
The proposal’s proponent stated that it was not their intent that the reference to delayed egress locks limit the hardware to the special locking arrangement already permitted by the International Building Code or NFPA 101. Instead, the new language’s intent is to accept a locking arrangement, approved by the code official, where the clinical needs of patients require additional security.
The use of the locking arrangement is restricted to a specific set of criteria that includes remote unlocking from a nurses’ station or other approved location, and the building must be protected throughout with automatic sprinklers or automatic detection.
Elevator lobbies. Based on the concern for vertical smoke spread, a means of protection must be provided to restrict the spread of smoke through the elevator shaft when the elevator shaft connects more than three stories.
The requirement has been debated and revised in every edition of the International Building Code. The 2009 edition has lowered the threshold for health care occupancies from high-rise buildings to shafts that connect more than three stories.
There are several ways to meet the requirement, including an elevator lobby enclosure, an additional door in front of the elevator or pressurizing the elevator shaft. Doors provided to satisfy the requirement—either the additional door or elevator lobby doors—must be smoke- and draft-control assemblies.
Smoke-barrier doors. Numerous proposals were submitted, attempting to achieve consistency between the International Codes and NFPA 101, in an attempt to improve the likelihood that the Centers for Medicare & Medicaid Services would recognize the International Codes as an acceptable alternative to complying with NFPA 101.
For a variety of reasons, only a limited number of the proposals were accepted. However, in a separate action, a proposal was approved that would require doors in smoke barriers to be provided with positive latching hardware, unless the listing of the door does not require latching devices. Because the code requires the doors to have a 20-minute fire protection rating and to be smoke- and draft-control assemblies, latching devices will likely be required by the listing. The exception in the 2006 edition of the International Building Code did not require latching devices on cross-corridor doors in smoke barriers.
The history behind the current exception for latching devices was the desire to have the door close completely and to reduce the likelihood that door hardware would keep the door from closing completely. Because cross-corridor doors in health care occupancies are not permitted to have mullions, the latching devices are typically at the top and bottom of the door.
Inactive door leaf. Language has been added to the International Building Code to permit a pair of doors to serve a patient sleeping room. One leaf shall be inactive and provided with self-latching edge- or surface-mounted bolts. The provision in the International Building Code requires that the active leaf meet all egress width requirements.
This is more restrictive than the requirements in the NFPA 101 Life Safety Code, which permit the combined width of the active and inactive leaves to be considered for meeting the egress width requirements, provided the active leaf affords at least 32 inches of clear width.
Suites. Two changes were made to the suite provisions contained in the International Building Code. The first change deletes the language that there is “direct and constant visual” supervision of the patients, as required by the NFPA 101 Life Safety Code. The language that replaces the deleted words merely requires that staff be in attendance in the suite. A second change revises the code to permit egress through adjoining suites, as is specifically permitted in the 2006 edition of NFPA 101.
Laundry carts. The International Fire Code will contain requirements that limit the materials used in the construction of laundry carts. The materials must be noncombustible or must have a limited heat release rate.
The change will not impact many health care facilities because there is an exception that the requirement does not apply when the area is protected throughout with an automatic sprinkler system.
Significant revisions
The intent of this article was to highlight significant revisions that specifically affect health care occupancies that will appear in the 2009 editions of the International Codes.
As noted, the new requirements will only apply once appropriate regulatory bodies have adopted the 2009 edition of one or more of the International Codes.
For more information on the ICC and its family of building codes, readers can log on to the organization’s Web site at www.iccsafe.org.
William E. Koffel, P.E., FSFPE is president of Koffel Associates Inc., an Elkridge, Md.-based fire protection engineering and code consulting firm that actively participates in the codes and standards development processes of the International Code Council and National Fire Protection Association. He can be reached at wkoffel@koffel.com.
This article first appeared in the November 2008 issue of HFM.
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