A common question facing health care facilities managers is, “Does this existing condition, which may not meet code, require remediation?” The answer is not always clear and may require further investigation.
Most codes and standards are intended for new construction, while some contain a significant number of requirements that apply to existing buildings, such as the National Fire Protection Association’s NFPA 1, Fire Code; NFPA 101®, Life Safety Code®; and the International Code Council’s International Fire Code. Additionally, NFPA 99, Health Care Facilities Code, contains requirements that apply to existing facilities, which are detailed in the “Applicability” sections at the beginning of several chapters.
When renovating an existing area, it is important to remember that a life safety feature cannot be downgraded below the requirement for new construction. For example, a 10-foot-wide corridor in an existing health care occupancy is permitted to be reduced to 8 feet during a renovation project; however, the width cannot be reduced below 8 feet, even though existing buildings only require 4-foot-wide corridors.
Also, where there is a conflict between the requirements of a reference standard and NFPA 101, NFPA 101 states that its requirements shall govern. However, authorities having jurisdiction (AHJs) will usually enforce the most stringent of the conflicting requirements.
Compliance with reference standards is generally required but, in limited instances, may not be required for all existing conditions. An existing building is permitted to meet the reference standard enforced at the time of construction, provided the lack of conformity does not pose a hazard to life safety as determined by the AHJ. However, it can be difficult determining which reference standard was enforced when the area was constructed.
Determining the best approach to address existing conditions that may or may not be code compliant is not a simple task. Thorough code research and obtaining documented local AHJ approval is a good first step before addressing the issue with the Centers for Medicare & Medicaid Services or an accrediting organization.
