Last year, the 2012 edition of NFPA 101 the Life Safety Code was adopted by the U.S. Centers for Medicare & Medicaid Services (CMS), mandating that healthcare facilities move from the 2000 NFPA 101: Life Safety Code to the 2012 edition. Hospitals, nursing homes, skilled nursing facilities, ambulatory surgical centers, and free-standing emergency departments must comply with the 2012 edition of NFPA 101 to receive Medicare or Medicaid reimbursement.
Since the ruling, NFPA has developed various resources to help health care facility managers meet the requirements of the CMS Conditions of Participation (CoPs). Below are some observations on how the Code is intended to be applied as developed by NFPA’s Technical Committees on Safety to Life.
NFPA 101 is an occupancy-based code, so understanding the Code and its requirements assures that occupants are well protected from life safety hazards and building owners are focused on the safety protocols that are warranted. Within NFPA 101 there are three occupancy classifications related to medical facilities: business occupancies, ambulatory health care occupancies, and health care occupancies.
Business Occupancy. An occupancy used for the transaction of business other than mercantile.
The definition might seem misaligned with medical facilities, but doctors’ offices, dentists’ offices, and urgent care clinics, with three or fewer occupants who are incapable of self-preservation at any time, are considered business occupancies because patients will be able to evacuate on their own, if there is an emergency. The occupant life-safety risk is no different than that found in an office building. Sure, EMS might occasionally get called to a doctor’s office to assist an incapacitated patient experiencing an unanticipated health scare, but the occupant’s original intent was to consult with a medical expert, much as one might seek out guidance from a business.
Ambulatory Health Care Occupancy. An occupancy used to provide services or treatment simultaneously to four or more patients that provides, on an outpatient basis, one or more of the following:
- Treatment for patients that renders the patients incapable of taking action for self-preservation under emergency conditions without the assistance of others
- Anesthesia that renders the patients incapable of taking action for self-preservation under emergency conditions without the assistance of others
- Emergency or urgent care for patients who, due to the nature of their injury or illness, are incapable of taking action for self-preservation under emergency conditions without the assistance of others
Business occupancies and ambulatory health care occupancies differ because the latter pertains to occupancies where four or more patients are incapable of self-preservation. This occupancy is different from a health care characterization, because care is “on an outpatient basis,” implying that a doctor has not admitted the patient to a facility that provides longer-term care and sleeping accommodations. The occupant receives medical attention and leaves, or if additional treatment is needed, will subsequently be admitted to a health care facility.
Think about a medical facility where treatment is administered that would make the occupant unable to evacuate without medical assistance, like a dialysis clinic. The patient would need help disengaging from the dialysis machine in order to evacuate. Or consider a patient that walks in to receive anesthesia for a procedure. After observation, they can walk out of the facility on their own, the same day. Dentists’ offices can be classified as ambulatory health care settings if, at any time, four or more patients are incapable of evacuating a compromised occupancy on their own. (This could include two patients undergoing procedures while two other patients are simultaneously in recovery.)
Ambulatory health care occupancies also include emergency departments that are attached to a hospital and those that are free-standing facilities. Added to the 2003 edition, the Code indicates that if the emergency department is attached to a hospital and considered ambulatory health care, it must be separated from the remainder of the building by two-hour fire barriers (see 184.108.40.206 of the 2012 edition and 220.127.116.11 of the 2015 edition). Classifying an emergency room as ambulatory health care means that it will not be subject to suite size limitations applicable to health care occupancies, patient rooms can be open to the corridor, and the health care occupancy corridor protection requirements don’t apply. Emergency room patients are outpatients; but once four or more inpatients that are incapable of evacuating themselves are within the facility, it is then classified as health care.
Health Care Occupancy. An occupancy used to provide medical or other treatment or care simultaneously to four or more patients on an inpatient basis, where such patients are mostly incapable of self-preservation due to age, physical or mental disability, or because of security measures not under the occupants’ control.
Health care occupancies include four or more patients who are incapable of self-preservation; they are inpatients, rather than outpatients. Occupants are undergoing extended care at hospitals, nursing homes, and limited-care facilities, and have sleeping accommodations. Optimal life safety features exist in these facilities because there are a high number of patients who are unable to evacuate themselves.
The occupancies referenced above all provide health care services but life safety in the event of fire varies significantly within each setting. The authority having jurisdiction (AHJ) determines occupancy classification and applies the Code in the manner deemed appropriate.
NFPA 101 is available to review online for free.
Contributing Author: Gregory Harrington, Principal Engineer, National Fire Protection Association.
Gregory Harrington is a Principal Engineer at the National Fire Protection Association (NFPA).