Author(s): Jesse Roman. Published on November 1, 2018.

'Critter Life Safety Code'

The latest edition of NFPA 150, Fire and Life Safety in Animal Housing Facilities Code, is bigger, brawnier, and more comprehensive than its predecessors, and offers stakeholders meaningful guidance on a range of animal safety topics. But getting there wasn't easy.


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Ajay Gulati, a senior engineer at the Smithsonian Institution, had heard from the zookeepers at the National Zoological Park in Washington, D.C., that many animals can react unpredictably, sometimes angrily, at the sound of a blaring fire alarm. When he arrived recently to test the new alarm system installed in the zoo’s orangutan house, he was prepared for a degree of chaos.

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He got it.

“Their behavior just flipped—they were very upset,” Gulati said of the animals’ response when he activated the horn for the first time. One orangutan spit a mouthful of water on Gulati as he stood by the alarm panel near the apes’ enclosure. The strobe light and piecing horn prompted frenzied behavior from several other apes, who ran back and forth and banged violently on the walls.

The alarm upgrade and testing were part of a larger, multi-year effort to revamp the zoo’s fire safety systems, including outfitting many of its more than 100 structures with fire sprinklers and new alarms. Gulati, who serves as the zoo’s de facto fire marshal and helped shepherd the project since it began in 2007, has learned over the past decade that many of the conventional strategies employed by fire protection engineers to protect life and property can quickly go out the window when the occupants have hooves, fur, scales, tails, or feathers.

“A lot of the [technical] solutions we came up with [during the zoo renovation] would have never occurred to me if I had to do this alone,” he said. “You have to talk to the experts and understand these animals and what their needs are when you design these systems. It doesn’t matter if it’s a kennel, a stable, or a great ape house.”

Gulati was able to apply that hard-won knowledge to his work as a member of the Animal Housing Facilities Committee, the body responsible for NFPA 150, Fire and Life Safety in Animal Housing Facilities Code. In August, NFPA released the 2019 edition of NFPA 150 to help designers, authorities having jurisdiction (AHJs), and others navigate the unique complexities of addressing the fire protection issues inherent in animal-related buildings, which range from zoos, pet stores, shelters, stables, and veterinarian clinics to research facilities, agricultural barns, and many more.

It is the first code of its kind to tackle the issue in depth. Although NFPA 150 has existed as a standard in some form since 1979—it focused exclusively on racehorse stables until 2006—the 2019 edition is essentially a new document that underwent a comprehensive rewrite. The new version is roughly five times longer than its predecessor, and instead of lumping animal housing facilities into overly simplistic “A” and “B” categories—where, depending on interpretation, a pet store, chicken house, kennel, or zoo building might all be treated as the same type of occupancy—the code is now organized into seven separate animal housing categories with specific requirements.

Elephant walks around in the National Zoo in Washington, D.C.

ANIMAL-CENTRIC An elephant at the National Zoo in Washington, D.C. Technical committee members of the new NFPA 150 say many protections schemes for animal housing facilities need to be performance-based, taking into account the needs and behaviors of particular animals. Photograph: Andrea Pohlman/Smithsonian's National Zoo

“It was a tremendous task to refine the document, take it apart, then decide how to put it back together and what to retain,” said Joe Scibetta, the codes and standards manager at a company called BuildingReports and a longtime member of the NFPA 150 committee. “For many years, NFPA 150 was just a small, obscure document that most professionals didn’t even know to look for, and if they did, most would find it too simplistic for their needs. I think this will be much more palatable for fire marshals and protection engineers.”

Experts say more thorough guidance was badly needed for animal facilities, which for years have existed in a kind of regulatory gray area, shoehorned into existing occupancy types that often did not provide the right fit. “For someone designing or operating such a facility, it’s been really difficult to figure out what they should be providing in terms of protection for the animals themselves,” said Clay Aler, a former senior fire protection engineer at the Maryland State Fire Marshal’s Office who now directs code consulting services at Koffel Associates. “AHJs have just been applying whatever seems like the most applicable occupancy type based on the local building code and/or the Life Safety Code®, but none of those occupancy requirements really takes into account the needs of animals during a fire event.”

As the orangutans’ reaction to the alarm proved, often the standard fire protection methods that work in the human world aren’t viable for animals. Gulati and other experts on the NFPA 150 technical committee drew on their insights from working in animal facilities to craft a code that attempts to navigate those discrepancies and find protection schemes that work for man and beast alike.


With billions of animals living in human-built structures across the United States and the rest of the world, committee members believe that the revamped NFPA 150 has the potential for widespread usage. Some NFPA staff are already informally referring to NFPA 150 as “the critter life safety code,” a play on the bigger and better-known NFPA 101®, Life Safety Code®.

The comparison is apt, said Tracy Vecchiarelli, an NFPA fire protection engineer and the NFPA 150 staff liaison. “When the committee was deciding what we were trying to accomplish with the rewrite, it became clear that the Life Safety Code was a good model to follow,” she said, adding that both codes have similar objectives. As a result, during NFPA 150’s creation, the committee mirrored the Life Safety Code in both layout and style, and it soon became clear that, as with the Life Safety Code, NFPA 150’s “size, scope, and application would be more suited for adoptability as a code rather than a standard,” Vecchiarelli said.

The document is certainly necessary. No agency or organization closely tracks the number of animals lost each year in fires, but anecdotal evidence suggests that the number is vast. In a report released in October, the Animal Welfare Institute estimated that, from 2013 to 2017, more than 2.7 million farm animals died as a result of barn fires—95 percent of those were chickens. (The estimate was derived from analyzing media reports of fires.) The total number is likely much higher due to unreported fires and animal losses, the report said. This year alone, many thousands of animals have died in fires in the U.S., including a massive fire at a farm in Ohio that killed 5,000 pigs; a fire on a poultry farm in Washington that killed 25,000 chickens; a barn fire in New York state that killed 28 racehorses; and a blaze at a kennel in Georgia that killed 22 dogs and a cat. Last year, a single fire at an egg-producing facility in Indiana killed more than 1 million chickens.

According to NFPA data, from 2012 to 2016, there was an average of 3,010 fires reported per year in or at livestock production properties in the U.S., resulting in more than $60 million in annual property damage. During that same period, there was an average of 1,190 fires reported annually in or at livestock or poultry storage properties, resulting in $31 million in property damage each year.

Despite the need, crafting codes and standards for animal-related facilities has always been fraught with a surprising level of complexity. “If there was ever a special structure, it’s an animal housing facility,” Scibetta said. “We have a secondary population wholly reliant on a primary population for its well-being, and many technical and humane questions come into play that have to be weighed together.”

A similar dynamic exists for human beings in hospitals and prisons, where, because of restricted or limited mobility, occupants aren’t capable of self-preservation in an emergency. In those facilities, protecting human life at all cost is the clear priority. But when it comes to animal facilities, the line between cost and life safety can blur, and questions abound—issues that formed the heart of the debates that went on for three years during the development of NFPA 150.

For example, should animals be protected like commodities, or, as living beings, should they be afforded the same level of life safety protection as people? If the answer is “it depends,” where should the line be drawn? Should a chicken destined for a dinner plate be treated differently than a gorilla in a zoo or a rat in a lab?

Complicating those questions is the sheer variety of animal species and facilities, which presents enormous technical challenges. During a fire, animals of the same species can exhibit very different, as well as unpredictable, behavior, and those differences are magnified between different species. Survivable conditions can also vary dramatically between species; smaller animals, for example, generally succumb to smoke faster than larger ones. Because of these variations, traditional fire protection methods meant to protect humans might be unusable in animal settings. Many sensitive marine animals, for instance, could more readily die from sprinkler water contaminating their tanks than from the immediate effects of fire.

Different types of alternations necessary for animal life safety

At the National Zoo in Washington, D.C., a variety of precautions are taken to balance safety with animal well-being. Clockwise from above: a silence button connects to the fire alarm outside the orangutan enclosure to ensure the animals do not become overstressed by the sound of the alarm; and beam smoke detectors (top) and sprinklers are protected against the probing trunks of elephants, which could damage the devices. Photograph: Ajau Gulati

There is also human safety to consider in these facilities. Large animals can pose serious or life-threatening dangers to their handlers during an emergency. Highly contagious research animals could prove deadly to unsuspecting first responders, or in a worst-case scenario unleash a pandemic. At the National Zoo, the orangutans were clearly stressed by the alarm test, some to the point of injuring themselves or their cage mates, but could a different type of alarm be used, even if it’s arguably less effective at alerting the human occupants? It begs the question: Is it ever acceptable to reduce the level of safety for the humans in an animal housing facility if it will lead to safer conditions for the animals?

“We learned through this process that you can’t only focus on the technical aspect, and you certainly can’t just be humane—you have to look at both perspectives,” Scibetta told me. “You need to hear from engineers, you need to hear financial considerations from industry groups, you need to consider the animal’s well-being. You have to bring all of those perspectives together to get a good end result.”


The new document divides animal housing facilities into seven distinct categories: animal healthcare, horse facilities, research, exhibition/public viewing, general board and care, agriculture, and emergency housing facilities. Each chapter provides guidance specific to each type of facility, including details on fire protection systems, egress, smoke control, risk management plans, and facility operations. The document also contains general guidance on other details, such as construction and separation, performance-based design options, and more.

“We tried to address as many things as we could in each chapter, and make it easy for people to understand what may be involved,” Vecchiarelli said. There are unique prescriptive guidelines for safety characteristics such as egress—doorways must be one and a half times the average width of the largest animal—that apply to all facilities, and myriad bits of guidance specific to various facilities. For example, in research facilities, there must be clear signage for first responders on the biological or other threats the animals might pose. In racehorse stables, bells cannot be used in fire alarms, because the bell is an audible prompt for the horses to bolt.

Previous iterations of NFPA 150 did not include specific provisions for agricultural facilities, a category that includes literally billions of animals. The new code now gives farmers and facility managers specific requirements for an array of life safety items, including the location of automatic smoke and CO detection, minimum distances to exits, storage of hazardous or flammable materials, minimum spacing between barn buildings, fire drill frequency, and more.

Farm Hazard Inforgraphic


Most farms are already required to follow safety and maintenance guidelines set by the big food processors that contract with them, said Paul Pressley, the former vice president of industry programs of the U.S. Poultry & Egg Association and an NFPA 150 committee member. He thinks the specific guidance offered in the code will help farmers ensure no safety detail is overlooked.

“Clarifying things like means of egress requirements, where to locate alarms, and what’s required in a risk management plan and assessment makes a lot of sense regardless of what occupancy you’re talking about,” he said. “We support that approach, and I’m pleased this document addresses those clearly.”

While certain aspects of animal facilities can be addressed with specific prescriptive requirements, the unlimited variety and uniqueness of individual facilities and animal species make it impossible to address every scenario. As a result, much of NFPA 150’s guidance is centered on risk assessment, emergency planning, and performance-based design—an approach that focuses more on safety outcomes rather than the means to achieve them. To that point, the code instructs users, as part of the design phase, to consult animal experts well versed in a particular species’ needs and temperament.

Some of these ideas were inspired by lessons Gulati learned while designing the National Zoo’s new fire safety systems. As part of the recent NFPA 150 overhaul, Gulati took the committee on a behind-the-scenes tour of the zoo and its fire systems upgrade. “I wanted to show them the uniqueness of some of these facilities and some of the changes we needed to make in NFPA 150 and the typical, traditional fire protection systems to address our animal program requirements,” he said.

Heeding his own advice, during the design phase Gulati and other engineers at the Smithsonian Institution met multiple times with the zoo’s animal program managers to learn more about specific animals’ needs, behaviors, and characteristics. The results of those discussions led to several unusual one-off design features included in the zoo’s new fire protection schemes.

For instance, zoo experts had warned Gulati that the orangutans were likely to react negatively to the fire alarm horn, so engineers included a big red button next to the alarm box that zookeepers can press to instantly shut off the horn in areas where the animals live; a red light remains on so that human handlers remain aware of the fire threat and can calmly evacuate without stressing the animals. If the alarm occurs at night when no humans are present, the horn in the animals’ living quarters will shut off automatically after a minute to minimize their exposure to the noise. When Gulati was unceremoniously spat on during the system’s testing, he was able to push the button to silence the alarm, and the apes quickly settled down.

In the elephant house, any sprinkler or alarm device within five feet of a cage (which is the length of an elephant trunk) or within 25 feet of the floor (the height a mature bull elephant can reach) is protected by a specially designed steel cage to guard against the elephants’ sometimes destructive curiosity and the probings of their dexterous trunks.

In many of the large-animal buildings, where evacuating the animals isn’t an option, engineers designed and installed powerful smoke-capturing ventilation systems so the animals could survive sheltering in place during a fire event. Engineers again consulted closely with animal experts to determine where to place the systems to create survivable air zones for each type of animal. For instance, when distressed, birds may fly to the top of an enclosure, while elephants may lower their trunks—knowing where to locate the systems could mean the difference between life and death.

No matter the species or type of facility, the technical solutions for the zoo project were derived collaboratively through risk assessment and emergency planning—essentially, brainstorming what might go wrong and how the animals might respond in each case, and then designing systems and procedures to maximize safety for both humans and animals, Gulati said.

That risk assessment process, whether it’s for a zoo or a chicken house, is critical for animal facilities, said Vecchiarelli. “It’s not just about having a plan, but for facility managers to be able to clarify what is in their buildings that they should focus on,” she said. “Just going through this exercise will help prevent fires. You might discover small issues, like an electrical cord placed where an animal can chew through it, that could possibly cause a fire.”

Committee members expect the document to expand further, and have intentionally reserved several chapters in the new document for yet-unspecified categories that may emerge as professionals apply the code to a range of animal housing.

“We tried to be as exhaustive as we could in addressing all types of facilities, but it’s going to be interesting to get the public input during the next revision cycle and see what’s missing,” Scibetta said. “We all realize that this is just the beginning, but I think we are all very happy with the start.”

JESSE ROMAN is associate editor of NFPA Journal. Top Photograph: Getty Images