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NFPA Today - September 02, 2022

How does NFPA 101 categorize work in an existing building?

Under NFPA 101, Life Safety Code, once a building has been approved by the Authority Having Jurisdiction (AHJ) and a new version of the code is adopted, that building becomes an existing building. Any changes to an existing building, from as small as touching up paint to as large as gutting an entire building, are covered in Chapter 43. The first step in determining the requirements for a specific change is to categorize the work being done in one of the seven work categories. The work category will drive the code requirements for the work areas so selecting the correct one is important. This blog will review the categories and walk through some examples of different projects and the category or categories they could fall under.

The seven work categories are as follows:

Repair - The patching, restoration, or painting of materials, elements, equipment, or fixtures for the purpose of maintaining such materials, elements, equipment, or fixtures in good or sound condition (NFPA 101 - 43.2.2.1.1 2021 edition).

Renovation - The replacement in kind, strengthening, or upgrading of building elements, materials, equipment, or fixtures, that does not result in a reconfiguration of the building spaces within (NFPA 101 – 43.2.2.1.2  2021 edition).

Modification - 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 (NFPA 101 – 43.2.2.1.3  2021 edition).

Reconstruction - The reconfiguration of a space that affects an exit or a corridor shared by more than one occupant space; or the reconfiguration of a space such that the rehabilitation work area is not permitted to be occupied because existing means of egress and fire protection systems, or their equivalent, are not in place or continuously maintained. (NFPA 101 – 43.2.2.1.4  2021 edition).

Addition - An increase in the building area, aggregate floor area, building height, or number of stories of a structure (NFPA 101 – 43.2.2.1.7  2021 edition).

Change of Use - A change in the purpose or level of activity within a structure that involves a change in application of the requirements of the Code (NFPA 101 – 43.2.2.1.5  2021 edition).

Change of Occupancy Classification - The change in the occupancy classification of a structure or portion of a structure (NFPA 101 – 43.2.2.1.6  2021 edition).

To help identify the appropriate category the flow chart below is one way to walk through the decision points for a particular work area to arrive at the rehabilitation work category. Each work area should be considered separately to ensure all requirements are captured.

Rehabilitation Category Flow Chart
See a larger view of this diagram.

In this method, the initial decision point is whether the work will result in a change to how the building will be used or occupied. If the work being done creates a change to the occupancy classification it is a change of occupancy, if not, it is a change of use. Although these are their own rehabilitation categories, it’s important to continue to evaluate the work associated with this change to ensure it complies with all the code requirements as a change in use or occupancy often result in additional work being performed. The second decision point will be if the work will add any areas, height or increase the number of stories, in which that case it will be classified as an addition. If not an addition, will any space or system be reconfigured? If so, it will either be a modification or reconstruction based on the level and type of work being done. If not, then the classification will be a repair where nothing is replaced or a renovation if construction elements or systems are replaced in kind.

Let’s walk through a few examples of how different projects would be classified. You own and operate a warehouse and need to hire a team to manage the warehouse. The team is new to your operation and no office space exists. To address this need, you plan to convert some of the warehouse space into offices. This type of work would change how the building or space is being utilized, specifically you’d be changing from a warehouse which is a storage occupancy to offices which is a business occupancy. The work project would be classified in the change of occupancy rehabilitation work category.  Since this work also include reconfiguring space, you’ll need to continue to evaluate to see if other rehabilitation categories apply. You won’t be adding any area, height, or stories to the building. If you’re impacting an exit, the fire protection systems cannot remain operational, or the area is more than 50% of the floor the work would also be classified as a reconstruction. Otherwise, the work would also be considered a modification.

Another example would be reconfiguring the entire second floor of your office building to convert the space to better serve a new tenant. The old tenant had several small offices off a hallway that provided access to the exit stairs. The new tenant would like two open office areas separated by the original corridor on the second floor. They also need a large office on the first floor, so you plan to convert two small offices into a larger one. In this instance, the use and occupancy would remain the same and the project would not add any area, height, or increase the number of floors to the building. The work would involve reconfiguring space. It would not impact a corridor or exit that is shared by more than one occupant space, and the fire protection systems and egress systems could continue to function during the construction. The work would not encompass the entire building, but since the work would involve more than 50% of the building area, it would be classified as a reconstruction.

After the work has been classified in the appropriate rehabilitation work category or categories the next step would be to determine the requirements from Chapter 43. Each rehabilitation work category has a section in Chapter 43 of NFPA 101, which outlines the requirements. It is possible to have multiple categories in a single work project, that under certain conditions can be considered independently, for example the reconfiguration of a second-floor office area and the renovation of the first-floor lobby. Each of these areas would need to comply with the requirements of their specific category. 

Historic buildings have their own section in Chapter 43. This is because sometimes special consideration is needed to balance historic perseveration and code compliance. To help address this, NFPA 101 allows three options for historic buildings, they can comply with:

  1. Section 43.10 for historic buildings,
  2. The applicable work category from chapter 43 or
  3. NFPA 914, Code for the Protection of Historic Structures.

It may be best to investigate all three options to determine which best suits the historic structure being rehabilitated.

When making changes to an existing building, whether as minor as replacing a ceiling in kind or as major as an addition NFPA 101 provides a roadmap for completing the work. The appropriate rehabilitation category will drive relevant requirements.  For more information on how to apply chapter 43 of NFPA 101 to a given building check out this blog How do I apply the provisions for rehabilitation to work at my building?, and for more on existing buildings check out this blog on Do all buildings have to comply with the latest code?

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Robin Zevotek
Robin Zevotek
Principal Fire Protection Engineer with NFPA Technical Services, specializing in fire engineering and emergency response

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