Smoke Dampers, Story Counting, and More
Important changes to the Life Safety Code® that you need to know.
NFPA Journal®, May/June 2009
There were several substantive changes to NFPA 101®, Life Safety Code®, in 2009. In previous issues of Journal I talked in general about the changes and the new annexes. In this issue, I would like to discuss several additional changes in the 2009 edition of the code, and to stress again how important it is to carefully review the changes in any new edition of a code or standard.
The method of counting the stories of a structure has been expanded in Section 4.6.3. The code requires that stories be counted starting from the level of exit discharge, which Chapter 3 now defines as "the story that is either (1) the lowest story from which not less than 50 percent of the required number of exits and not less than 50 percent of the required egress capacity from such a story discharge directly outside at the finished ground level; or (2) where no story meets the conditions of item (1), the story that is provided with one or more exits that discharge directly to the outside to the finished ground level via the smallest elevation change."
The requirements for emergency plans have also been expanded for most occupancies. Section 4.8.2, Plan Requirements, now addresses the appropriate use of elevators and evacuation procedures appropriate for the building. The requirement for emergency plans is located in the individual occupancy chapters under the "Operating Features" section.
Section 18.104.22.168.2 now contains the requirements for inspecting, testing, and maintaining smoke dampers in accordance with NFPA 105, Installation of Smoke Door Assemblies and Other Opening Protectives. In addition, doors in most occupancies must be inspected in accordance with Section 22.214.171.124, which requires that swinging doors that swing in the direction of egress be inspected annually.
The section also contains a list of 11 items that have to be included in the door inspection. Fire-rated doors must be inspected in accordance with NFPA 80, Fire Doors and Other Opening Protectives. The requirement for such inspections is located in the "Operating Features" section of each occupancy chapter.
The remoteness requirements of Section 126.96.36.199 have been expanded to include all three portions of the means of egress: the exit, the exit access, and the exit discharge. The code now clearly requires that all three portions comply with the remoteness requirements.
Provisions that allow alcohol-based, hand-sanitizer dispensers have been added to Chapters 14 and 15, which address educational occupancies, and to Chapters 16 and 17, which address daycare occupancies. These provisions are similar to those found in the health care chapters.
The provisions for door locking in health care occupancies were expanded. Previously, locking was permitted only "where the clinical needs of the patients require specialized security measures," primarily psychiatric wards. In the new edition, section information has been added to address locking "where patient special needs require specialized protective measures for their safety." This might include nurseries and Alzheimer’s wards.
Chapter 43, which covers building rehabilitation, was revised to eliminate some redundancies and to include some new items. This chapter defines the extent of improvements required based on the extent of work being done. The requirements of the applicable occupancy chapter must be met, as must any requirements found in Chapter 43.
NFPA’s technique for identifying changes in the codes from the previous edition is a vertical line in the margin, which simply indicates a change in a particular paragraph. It does not identify the type of change.
Readers must compare the revised paragraph with that in the previous code to fully understand the extent of the change or determine whether it is a whole new paragraph. A bullet in the margin indicates that a section of the code was removed.
Chip Carson, P.E., is president of Carson Associates, Inc., a fire engineering and code consultancy. He is a former member of NFPA's Board of Directors.