NFPA Journal

It is a common misconception that new code editions must contain numerous new requirements that mandate expensive additional protection features. While new minimum life safety requirements that were previously lacking might have been added to a particular code, in many cases those revisions allow for greater design flexibility that might not have been permitted under prior editions. That’s the case with the 2024 edition of NFPA 101®, Life Safety Code®, slated for issuance by the NFPA Standards Council in August.
  
Few events in our lifetime have impacted society to the extent that the COVID-19 global pandemic has, and few industries were impacted as much as health care. At the pandemic’s onset, when hospitals were overrun with patients requiring critical acute care, public health officials were faced with the daunting task of converting non-health care facilities—convention facilities, hotels, even parking structures—into temporary hospitals. No code directly addressed how to safely provide such necessary emergency health care services in buildings that were not designed with the requisite features to protect nonambulatory patients. Agencies including the U.S. Army Corps of Engineers mobilized to execute the needed conversions extraordinarily quickly while incorporating protection strategies in codes such as NFPA 101—if not the precise prescriptive requirements of the codes, which in many cases would have been impractical. 

RELATED: COVID Learnings: How the pandemic helped shape many of the proposed changes to the 2024 edition of NFPA 99, Health Care Facilities Code

Incorporating lessons learned from the early days of the pandemic, chapters on health care occupancy in the new edition of NFPA 101 have been updated with new requirements for what are called alternate care sites to ensure that minimum life safety precautions are taken while simultaneously meeting the emergent needs created by a public health emergency. A new annex provides valuable guidance to providers and authorities having jurisdiction (AHJs) on planning and design, construction, operations and maintenance, and facility decommissioning.

Another lesson learned from the pandemic was that the Life Safety Code did not adequately address the need to use larger quantities of alcohol-based hand-rub (ABHR) solution than previously anticipated. Revised requirements for other than health care occupancies and ambulatory health care occupancies allow for up to 0.5 gallon (2 liter) dispensers or up to 1 gallon (4 liter) dispensers in areas separated from corridors and in sprinklered buildings. Aggregate quantity limits have been increased from 10 gallons (37.8 liters) to 20 gallons (75.6 liters) in sprinklered buildings. A new exemption was added for personal-use ABHR containers up to 16.9 ounces (500 milliliters). ABHR requirements for health care and ambulatory health care occupancies remain unchanged.

Door locking requirements in health care occupancies to accommodate patient special needs (such as locking systems to prevent infant abductions in newborn nurseries) have been modified in the new edition of NFPA 101 to make them more readily applicable to existing buildings that are not fully sprinklered. Recognizing the need to balance life safety from fire requirements with security, these locking arrangements will be permitted where the locked compartment and all smoke compartments leading to the required exits serving the locked compartments are sprinklered. This is another example of the code adjusting to societal needs to maintain an appropriate level of life safety. (For other code changes applicable to the health care industry, see “COVID Learnings” on revisions to the 2024 edition of NFPA 99, Health Care Facilities Code.)

Emergency plans, exit requirements, and more
Related to security needs, buildings are increasingly provided with complex security features in response to the growing frequency of targeted violence events such as active shooters. It is critical that these features do not compromise life safety from fire. Accordingly, the emergency action plans required in educational and day-care occupancies will be required to address the operation of both passive and active security features in addition to fire protection and life safety systems to ensure that they are assessed under normal circumstances and during emergencies. By including these features in the approved emergency action plan, building owners and AHJs will be able to evaluate the impact of security and life safety features on each other. It is noted that the new language in NFPA 101 does not require an evaluation of the effectiveness of security features, which is outside the scope of the Life Safety Code.

Refinements to exit requirements in the new edition of the code recognize the reliability and effectiveness of automatic sprinkler systems and allow for greater design flexibility where sprinklers are provided. In one example, horizontal exit fire barriers were previously required to be vertically continuous to the ground unless a two-hour separation was provided between stories with horizontal exit barriers and those on which they were omitted, and all other exits (e.g., stairs) discharged directly outside. Interior exit discharge will now be permitted if the building is sprinklered and the additional interior exit discharge requirements of Section 7.7 are met. A second example recognizing the effectiveness of sprinklers is a change to the interior exit discharge requirements of Section 7.7. Previously, up to 50 percent of a building’s exit stairs were permitted to discharge through interior building areas where the interior discharge area was protected by automatic sprinklers or where the interior discharge was through a relatively small, protected vestibule. In the 2024 edition, up to 75 percent of a building’s exits will be permitted to discharge through small, protected vestibules where the interior discharge level is sprinklered. 

Changes to the next edition of NFPA 101 address topics including temporary health care facilities and school safety practices that can conflict with fire safety. Above, an active shooter drill at a high school. 

In another example of the code’s response to real-world practices, the next edition of NFPA 101 will recognize and mandate the requisite life safety from fire protection for valet trash collection services in apartment buildings. Valet trash collection is a service where apartment residents place their trash and recycling in containers in the corridor or on the egress balcony outside their units for removal by attendants at designated times. The Life Safety Code previously contained no information relating to valet trash services, which have proliferated in recent years. (A Google search of the term “valet trash” yields more than four million results.) With no code requirements, AHJs have been left to determine the needed protection on their own or whether the operation of such services should even be permitted, since the placement of trash in corridors and on egress balconies obviously increases the fire and life safety risk to residents and firefighters. The outright prohibition of valet trash collection services was deemed to be impractical, so reasonable requirements were developed to mitigate the hazard. 

Requirements in NFPA 101 will include limited-size containers that are covered and liquidtight, and that are noncombustible or that have a limited peak heat release rate, unless the corridor is sprinklered or the building is sprinklered where egress balconies are not noncombustible or limited combustible; maintaining the minimum required egress width; and limiting the duration that containers can be located in a corridor to 18 hours at a time and the time that combustible waste can be located in a corridor to 5 hours at a time. The recognition and regulation of valet trash collection services will allow the ongoing operation of a convenient service for apartment residents that otherwise might create a substantial fire hazard.

The Life Safety Code we know today got its start in the early part of the twentieth century as the Building Exits Code, and as its title implied, it primarily regulated exits from buildings in response to historic fires such as the Triangle Shirtwaist Factory in New York (146 deaths) and the Cocoanut Grove nightclub in Boston (492 deaths). Its scope has expanded over the years to provide a complete package of protection from the effects of fire and similar emergencies. The term similar emergencies has allowed the code’s scope to address nonfire related events such as hazardous materials emergencies (added in the 2018 edition) and the prevention of accidental carbon monoxide poisoning (added in the 2012 edition). The general requirements for carbon monoxide detection apply only when referenced by the various occupancy chapters. With each new edition of the code, additional occupancy chapters mandate carbon monoxide detection protection. For the 2024 edition, carbon monoxide detection requirements have been added for existing educational, new and existing day-care, new health care, new ambulatory health care, new and existing detention and correctional, existing one- and two-family dwelling, existing lodging or rooming house, and existing apartment building occupancies.

In summary, the upcoming edition of NFPA 101 is set to introduce a range of important revisions that reflect current industry best practices and lessons learned from real-world situations. These changes reflect the code’s ongoing commitment to balance life safety with societal needs and maintain an acceptable level of safety from fire. Overall, the revisions offer greater design flexibility while ensuring that the minimum life safety precautions are taken.

It is important to note that these changes are subject to consideration by the NFPA membership at the NFPA Annual Technical Meeting in Las Vegas in June, which could yield further revision to, or deletion of, the changes described here. 
For more information on NFPA 101, visit nfpa.org/101. For more on the next edition of NFPA 101, visit nfpa.org/101next. 

Gregory Harrington, PE, is a principal fire protection engineer at NFPA. Top photo: GETTY