Significant changes have been made to NFPA 101.
NFPA Journal®, March/April 2008
The 2006 edition of NFPA 101®, Life Safety Code®, includes a new Chapter 43 on building rehabilitation, which replaces the sections in previous editions on renovation work in existing buildings.
For example, the 2003 edition of NFPA 101 included Section 4.6.7, Modernization or Renovation, which stated, "Any alteration or any installation of new equipment shall meet, as nearly as practicable, the requirements for new construction." In addition, Section 4.6.2, Historic Buildings, permitted the authority having jurisdiction to modify requirements "where reasonable safety is provided."
These sections have been replaced by Section 4.6.7, Building Rehabilitation, which states,
"Rehabilitation work on existing buildings shall be classified as one of the following work categories in accordance with 22.214.171.124:
(5) Change of use or occupancy
Section 126.96.36.199 further states, "Rehabilitation work on existing buildings shall comply with Chapter 43."
The first four work categories—repair, renovation, modification, and reconstruction—address different degrees of rehabilitation work in an existing building. As now defined in Chapter 43, repair work involves no to very limited changes in the facility, whereas reconstruction involves major changes in the building arrangement. Properly selecting the subcategory of rehabilitation work is important in correctly applying the relevant code requirements to any rehabilitation project.
Now that rehabilitation work is divided into four subcategories, one must first determine which category of work will be performed to determine whether the changes must comply with the requirements in the existing occupancy chapter or with those for new construction.
For example, Section 188.8.131.52 defines a modification as "the reconfiguration of any space; the addition, relocation, or elimination of any door or window; the addition or elimination of load-bearing elements; the reconfiguration or extension of any system; or the installation of any additional equipment." Any new work must comply with the requirements for new construction.
However, Section 184.108.40.206 defines a renovation as "the replacement in kind or strengthening of loadbearing elements, or the refinishing, replacement, bracing, strengthening, or upgrading of existing materials, elements, equipment, or fixtures, without involving the reconfiguration of spaces." This type of renovation work can comply with the requirements for existing construction.
Section 43.7.2 addresses changes of occupancy that occur as a result of a rehabilitation project. Newly added is Table 43.7.3, which classifies the hazard level of occupancies. As the table notes, a change of occupancy in the same or a lower hazard level requires compliance with the requirements of the chapter for existing construction. However, fire alarm and sprinkler requirements must comply with the requirements for new construction.
Additions, which are addressed in Section 43.8, must generally comply with the requirements for new construction. There is a special Section 43.10 for historic buildings.
This is a significant change in the code philosophy regarding rehabilitation work in existing buildings. Be sure to read Chapter 43 carefully to determine which category of rehabilitation work is being done in the building so that you can determine the specific code requirements for each part of the project.
Chip Carson, P.E., is owner and president of Carson Associates, Inc., in Warrenton, Virginia. He is also a member of NFPA’s Board of Directors.