The Life Safety Code® has long required special protections for “hazardous areas." Locations commonly considered under this designation include storage rooms, soiled utility rooms, boiler rooms, maintenance workshops, and bulk laundry areas. While the provisions for these areas have not greatly changed in the Life Safety Code® over the years, compliance with the requirements specific to hazardous areas continues to be a top five finding nationally (K-321).
For existing hazardous areas (in place prior to July 2016), these spaces are required to be enclosed with smoke resisting construction (assuming the room is provided with sprinkler protection). This means no louvers, half-walls, open alcoves, or any type of unprotected opening to the corridor. Doors shall be self-closing and positive latching. However, doors are not required to be rated.
If the hazardous area was constructed after July 2016, or the space lacks sprinkler protection, a 1-hour fire resistance rated enclosure is required. This includes a ¾ hour rated door assembly that is self-closing and positive latching.
Like so many new focus areas and challenges brought on by the pandemic, the emphasis on personal protective equipment (PPE) has created some unintended consequences regarding Life Safety Code® compliance. With various states mandating significant PPE quantities to be on-hand, some organizations have been forced to create new storage locations. This sometime involves the repurposing of existing spaces that were utilized differently in the past. In many cases, this essentially creates “new" hazardous areas.
Historically, if an organization looked to convert an existing space into a storage room, for PPE or any type of combustible storage, the conversion of the space triggered the provisions for “new" construction in the Life Safety Code®. However, such rooms or spaces usually do not have 1-hour rated enclosures.
The 2012 edition of the Life Safety Code® provides some potential relief to organizations who are converting existing spaces into storage areas. The 2012 edition includes a new chapter (Chapter 43 – Building Rehabilitation) that clarifies the requirements applicable when implementing repairs, renovations, changes of use, or even changes in occupancy type. In particular, Section 43.7.1.2(2) provides guidance on the requirements around converting existing spaces into newly designated hazardous areas. Essentially, a 1-hour enclosure of the newly created hazardous area is not necessary if the following criteria are met:
- The area is not greater than 250 square feet.
- The room is being converted to a location used for storage.
- The building is fully sprinklered.
This provision in Chapter 43 provides much more flexibility when reallocating space and developing additional storage locations, a common practice as organizations continue to maintain greater stocks of PPE. All door provisions for hazardous areas still apply.
As always, knowledge of the applicable codes and standards is your best tool for ensuring compliance. You can purchase a copy of the Life Safety Code® (NFPA 101) online at
www.nfpa.org.
The
AHCA/NCAL website is also a good source for on-going life safety education, tools, and resources.