Author(s): Angelo Verzoni. Published on May 1, 2017.

Safety 101

Integrated testing, door locking for educational and day care occupancies, occupant loads for business occupancies, and proposed increase in smoke compartment size in hospitals are among the topics up for consideration in the 2018 edition of the life safety code

INTERVIEW CONDUCTED BY ANGELO VERZONI

If a fire breaks out while you’re taking a bath, is the bathtub part of your means of egress? How can classroom doors allow entry by first responders while also preventing entry by active shooters and other unwanted visitors? These are questions that will be addressed as part of the revision cycle for the 2018 edition of NFPA 101®, Life Safety Code®.

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Read the second draft report for the 2018 edition of NFPA 101

One of NFPA’s most widely used codes, NFPA 101 traces its origins back to the creation of the association’s Committee on Life Safety in 1913. First used to standardize the construction of stairwells, fire escapes, and other egress routes in the event of a fire, today the code is used for myriad situations to provide the highest level of safety for a building’s occupants. A prime example is seen in the push to update the 2018 edition to address the threat of active shooters in schools—a threat that has been enforced through highly publicized tragedies such as the 2012 Sandy Hook Elementary School shooting.

2017 NFPA Conference & Expo Life Safety Code Sessions
NFPA Conference & Expo, Boston, June 4-7, 2017

CMS Adoption of NFPA 101-2012: A year in Review
Sunday, June 4, 8:30–9:30 a.m.

James Merrill, Centers for Medicare & Medicaid Services


Effective Messaging on Classroom Door Locking
Sunday, June 4, 8:30–9:30 a.m.

Ron Coté, NFPA


NFPA 101, Life Safety Code: Proposed Changes
Monday, June 5, 8–9 a.m.

William Koffel, Koffel Associates, Inc.


College Campus Safety: A Case Study in Balancing Fire Code Application and Security Needs
Monday, June 5, 9:30–10:30 a.m.

Paul Winfrey and Bridget Steele Mourao, Emory University


Health Care Facility Rehabilitation—Applying NFPA 101 Chapter 43 Effectively
Monday, June 5, 2–3 p.m.

Ron Coté, NFPA


NFPA 101A-2013 and Fire Safety Evaluation Systems in Health Care Facilities
Monday, June 5, 3:30–4:30 p.m.

Lennon Peake, Koffel Associates, Inc.; William Koffel, Koffel Associates, Inc.


Creating an Emergency Response Team—A Case Study
Monday, June 5, 3:30–5 p.m.

Ralph Davis, Molina Healthcare, Inc.

Bill Koffel, chair of the Life Safety Correlating Committee, will speak about the expected changes and certified amending motions to NFPA 101 during an education session at the Conference & Expo. A number of other conference sessions will also explore issues related to NFPA 101. NFPA Journal spoke with Koffel about a few of the key changes that have been proposed for NFPA 101, the proposals he thinks will be the most contentious, and what might be in store for future editions of the code.

How might the scope of NFPA 101 change for the 2018 edition?

The committee has proposed to expand the scope of the document in three areas. The first is to address occupant protection while egressing during an event involving hazardous materials. The second is to address reducing injury to building occupants from falls. The third is to address providing communication to occupants under emergency conditions which may or may not be a fire event.

Are any of these proposals contentious?

In addition to changing the scope of NFPA 101 in Chapter 1, there are recommendations for adding requirements for grab bars in shower enclosures and bathtubs in certain occupancies. Some people don’t think the code should include grab bars, and there are some people that think the requirements should be limited just to residential occupancies and not to other occupancies like health care and assembly occupancies. One of the main questions for this proposal is, what defines a means of egress? Is a shower or bathtub part of the means of egress? If so, grab bars might be appropriate to help people egress in an emergency. While these questions garnered a lot of discussion with both the technical committee and the correlating committee, it looks like it will remain in the code for the new edition.

What are some of the technical changes under discussion for the 2018 edition of NFPA 101?

One proposal is to address safety and security concerns in educational facilities. For example, during an active shooter situation, if your plan is to try to secure people in a safe area like a classroom, that’s going to require some locking of the classroom door. What’s being proposed for the Life Safety Code is to introduce language recognizing the increased need for security but do it in a way that is still going to provide an acceptable level of life safety in the event of a fire. It was interesting to see the provisions that were developed specifically for the educational occupancy chapters also be picked up by other committees, including the committee that deals with business occupancies. It is clear that this type of threat is not limited to schools.

If that proposal isn’t approved, what happens? It’s not like the threat of active shooters is going away anytime soon.

There are after-market products that are available that schools can purchase and put on these doors, but there’s concern that these products don’t provide an acceptable level of life safety. For example, with these products installed, you might not be able to open a classroom door from the corridor side, so as a first responder, if you have a rescue to perform, it’s going to take additional time to access that space. With the proposed changes, the committees are trying to balance the need for additional security to address our changing environment, yet do it in a manner where we’re still providing a reasonable level of life safety.

Are these after-market products currently causing any problems?

I know that some of these products are clearly being purchased and they’re being placed in educational facilities. I personally am not aware of any incidents where they have hindered the response of any emergency personnel. But we know the products are out there and they are not code compliant.

What are some other key technical changes proposed for the code?

One proposal from three years ago that is being proposed again is increasing the allowable area of hospital smoke compartments, which is the space separated from adjacent areas by smoke barriers. The proposal would increase the allowable area from 22,500 square feet to 40,000 square feet. When the item came before the NFPA membership three years ago, it was controversial. It was subject to a very close vote, and ultimately, the Standards Council determined a consensus had not been reached and they did not increase the area of the smoke compartments.

People sit down on a sidewalk with arms up as police officers respond to reports of a campus shooting at UCLA.

Police officers respond to reports of a campus shooting at UCLA in 2016. Photograph: Getty Images

What’s the reasoning behind increasing the area?

The primary reason is that the Facility Guidelines Institute (FGI), which develops guidelines for building hospitals and other health care facilities, increased the area required in health care facilities to perform certain services. Additionally, more and more health care facilities are going toward single-patient rooms—the committee was presented with a study that indicated that about the same number of patients and services would be performed in a 40,000-square-foot area using these new requirements as historically existed in a 22,500-square-foot area. So the change is really to coordinate with other requirements that hospitals have to meet where the newer FGI criteria has been adopted.

Centers for Medicare & Medicaid Services (CMS) recently adopted the 2012 edition of NFPA 101. If the area of smoke compartments is increased in the 2018 edition, what does that mean for those facilities?

Assuming the proposal for a 40,000-square-foot limit goes through, the only way those facilities would be allowed to increase their smoke compartment size would be if CMS were to adopt the 2018 edition or were to adopt this portion of the 2018 edition. Prior to adopting the 2012 edition of the Life Safety Code, CMS did allow facilities to comply with portions of the 2012 edition of the code. I have no idea what CMS is going to decide. They’ll review the document. But there is the opportunity for CMS to stay with the 2012 edition of the code but issue a notice that they would allow a categorical waiver for a 40,000-square-foot smoke compartment that complies with the 2018 edition criteria.

How many notices of intent to make a motion, or NITMAMs, have you received overall?

We received 43 NITMAMs. They have to be reviewed and certified. After that, I’ll have a better feel for what the content of those certified amending motions is. In Boston, a major part of my presentation will focus solely on those certified amending motions because part of my intent is to share with people the perspectives of the various interested parties to help them prepare for voting [at the NFPA Technical Meeting] later in the week.

Is 43 a lot?

It’s higher than what we might normally have for this document. But I think what has happened is there are some topics where more than one motion is necessary to accomplish what the submitter is trying to do, and that’s why we’re seeing the number that we have. For example, one of the issues deals with integrated testing of life safety systems. Since this concept is dealt with throughout the code, 22 of the 43 NITMAMs deal with that one subject. In other cases, I expect that several of the NITMAMs cannot be certified due to the nature of the changes that were being suggested.

What do you think the discussion on NFPA 101 at the Conference & Expo will center on?

Integrated testing provisions, door locking provisions for existing educational and day care occupancies, occupant load factors for business occupancies and the proposed increase on smoke compartment size previously mentioned will occupy most of the floor discussion during the NFPA Conference & Expo in June when NFPA 101 is voted on.

What issues do you see coming up again as future editions of NFPA 101 are developed?

I think the work that was done to address unwanted entry into schools will continue to evolve in the next edition. The incidents aren’t limited to education facilities. We know there’s been active shooter incidents in health care facilities, office buildings, and factories. We know of at least two mass casualty events in a business environment. We know there’s been several in an assembly occupancy—like the movie theater in Colorado and the nightclub in Orlando. I think the work that’s been done in this cycle will be step one of some work that’s going to be ongoing for the next cycle as well.

ANGELO VERZONI is staff writer for NFPA Journal. Top Photograph: Getty Images