The 2012 edition of the National Fire Protection Association’s NFPA 101®, Life Safety Code®, in section 126.96.36.199, emphasizes the importance of maintaining life safety features in accordance with applicable NFPA standards.
If code requires it, compliance is mandatory, and diminishing the level of life safety is not permitted. However, if building changes are made or if, for example, a fire door was accidentally installed when not required by the building or fire code, then the device is permitted to be taken out of service unless the life safety feature is a requirement for new construction as required by 188.8.131.52.
But what is the process when life safety features are no longer required by code?
NFPA 101 (2012) section 184.108.40.206 requires that “existing life safety features obvious to the public, if not required by the Code, shall be either maintained or removed.” Often this leads to many questions, individual interpretations, accrediting organization (AO) citings and a general misunderstanding of the intent. AOs will ultimately make their own interpretation, but the intent behind this section of code is clearly explained in the annex section of NFPA 101 (2012). The intent is to remove inoperable or out-of-service features and/or devices that are no longer required by code, as they present a false sense of safety to the public. Upon further exploring this intent, Merriam-Webster defines “public” as “people as a whole: Populace – The common masses.” This does not include those who work daily in facilities maintenance and compliance.
Once a facility professional has determined that a life safety feature is no longer required by the Life Safety Code, then the item can be removed, but only the visible portions obvious to the public must be removed.
One example of a life safety feature that can be decommissioned are smoke dampers which are no longer required by code in an area that was renovated and provided with sprinklers throughout.
The American Society for Health Care Engineering has created a tool that provides additional clarification.