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1.31.19 – Consulting-Specifying Engineer – William E. Koffel

Some of the changes to the 2018 edition of NFPA 101: Life Safety Codehave resulted in a change in the scope of the document. It should be noted that this article will not include all changes between the 2015 and 2018 editions.

Scope of NFPA 101

Historically, the scope of NFPA 101 has been limited to provide an acceptable level of life safety for building occupants during a fire or similar emergency. However, the scope was expanded in three ways in the 2018 edition. The first change of scope was to add considerations that provide protection for occupants during emergencies involving hazardous materials. For the most part, this expansion of scope has been addressed by adding references to other NFPA standards that specifically address hazardous materials. More specifically, NFPA 101 now states that, where required by an occupancy chapter, the stricter requirements of NFPA 101 or reference standards—such as NFPA 30: Flammable and Combustible Liquids Code, NFPA 45: Standard on Fire Protection for Laboratories Using ChemicalsNFPA 55: Compressed Gases and Cryogenic Fluids CodeNFPA 58: Liquefied Petroleum Gas Code, NFPA 400: Hazardous Materials Code, and NFPA 495: Explosive Materials Code—apply (see NFPA 101; Paragraphs 7.12.2 and

This is critical in that Chapter 2 of NFPA 101 states that where a conflict exists between NFPA 101 and a reference standard, the requirements of NFPA 101 apply. However, in this instance Paragraph 7.12.2 of NFPA 101 provides a more specific provision that overrides the general provision in Chapter 2. For example, if NFPA 30 contains a travel distance to the door from a storage room that is different than what is contained in Chapter 42 of NFPA 101, the provisions of NFPA 30 would apply.

The second change in scope indicates that NFPA 101 also addresses reducing injury to occupants from falls. In reality, some provisions in previous editions of NFPA 101 already did this. For example, the stair geometry, stair uniformity, handrail, and guard requirements were already based on the need to reduce slips and falls on stairs. In the past, the argument was made that these provisions needed to be in NFPA 101 to provide safe use of stairs during a fire emergency and to provide consistency with requirements in other codes that address the same features. The primary technical changes related to the expanded scope are requirements for grab bars for bathtubs and showers. In a departure from the typical code format, these requirements are found in Chapter 24; the occupancy chapters that have chosen to require grab bars contain a provision that state grab bars shall be provided in accordance with the requirements in Chapter 24. The base requirements were added in Chapter 24 instead of Chapter 7 as well to reduce duplicity by having the base requirements in two locations, therefore avoiding conflicting requirements should the technical committees responsible for the two chapters choose a different set of requirements.

The third change in scope is that NFPA 101 addresses communication to occupants and others during an emergency situation. The scope statement was added because NFPA 101 now addresses the need in certain occupancies for risk analysis to determine the need for a mass notification system. Prior to these new provisions, the requirements for a risk analysis for mass notification systems were contained in Chapter 24 of NFPA 72: National Fire Alarm and Signaling Code. However, the concern was that if the owner or designer did not intend to install a mass notification system, the NFPA 72 requirement would not apply. The risk analysis is used to determine the need for mass notification systems as well as the functionality of such systems. By adding the requirement for a risk analysis in NFPA 101, where required by an occupancy chapter, the risk analysis to determine the need for a mass notification system is required whenever a new fire alarm system is designed. For example, when a new assembly occupancy with an occupant load of 500 or more is being designed, a risk analysis to determine the need for a mass notification system is required (see NFPA 101; Paragraph The threshold for when a risk analysis is required, if required at all, varies depending on the occupancy and, in some cases, the use of the building within the occupancy classification.

Figure 1:  While not the only integrated fire protection system, a smoke-control system is a good example of an integrated fire protection system addressed by NFPA 4. All graphics courtesy: Koffel Associates

Integrated fire protection systems

A change that will impact many consulting engineers is a new requirement that certain systems be tested in accordance with NFPA 4: Standard for Integrated Fire Protection and Life Safety System Testing. The core chapter (see NFPA 101:  Paragraph 9.11.4) states that, where required by an occupancy chapter, compliance with NFPA 4 testing is also required—meaning that when two or more fire protection or life safety systems are integrated, the systems shall be tested in accordance with NFPA 4 (NFPA 101; Paragraph 9.11.4). This applies to both new systems (during acceptance testing and commissioning) and the periodic testing of such systems. It should be noted that an arrangement that uses waterflow switches for an automatic sprinkler system serving only as an initiating device for a fire alarm system is not considered an integrated fire protection system. However, where waterflow switches or automatic smoke detection are used to actuate a smoke-control system, such an arrangement is considered an integrated fire protection system.

The requirement to test integrated fire protection systems in accordance with NFPA 4 is found in the high-rise building requirements (NFPA 101; Paragraph 11.8.9), in Chapter 9 for smoke-control systems (NFAP 101; Paragraph, and in certain occupancy chapters. For example, integrated fire protection systems in new business occupancies and existing high-rise business occupancies are to be tested in accordance with NFPA 4 (NFPA 101; Paragraphs 38.7.8 and 39.7.8). It should be noted that the provisions related to testing integrated fire protection systems were revised by a series of Tentative Interim Amendments (TIA) (see TIA’s 18-2 through 18-11).

A Tentative Interim Amendment is an amendment to an NFPA standard processed in accordance with Section 5 of the Regulations Governing the Development of NFPA Standards. It has not gone through the entire standards development process of being published in a First Draft Report and Second Draft Report for review and comment. TIAs are effective only between editions of the standard. A TIA automatically becomes a public input for the next edition of the standard, and as such it is then subject to all procedures of the standards-development process. TIAs are published in NFPA News, National Fire Codes Subscription Services, and any further distribution of the standard after being issued by the Standards Council.

Figure 2:  Wall marking: An example of how fire barriers should be marked to help facilities maintain the integrity of the fire barrier.

The consulting engineer and NFPA 101

Many say that NFPA 101 impacts architects more than engineers. While there may be some truth to that, since NFPA 101 addresses issues such as means of egress, compartmentation, and interior finish, the document also addresses requirements for fire protection systems—and some of the decisions made by architects will impact the consulting engineers on the project. The following are a few areas in which consulting engineers are impacted by the decisions made by architects and NFPA 101 code compliance.

Horizontal exits

Horizontal exits are not required by NFPA 101but rather, they are a design alternative that allows one to reduce the number of exit stairs and doors to the exterior. As such, horizontal exits can assist in addressing security considerations. In addition, horizontal exits are often used in health care occupancies to allow patients to be moved horizontally to another fire compartment and in correctional occupancies to allow occupants to be moved horizontally to a secure fire compartment. From an engineering perspective, some items that are often overlooked regarding horizontal exits include the need for manual fire alarm boxes and standpipe hose connections on both sides of the horizontal-exit fire barrier. In addition, where two opposite swinging doors are provided at horizontal exits, exit signs shall be provided on both sides of the horizontal exit, and the signs shall indicate the door that swings in the direction of egress travel. This is typically accomplished by not locating the signs in the center of the corridor.

Video monitoring of stairs in high-rise buildings

New high-rise buildings having an occupant load of 4,000 or more are required to be provided with video monitoring of the stairs (NFPA 101; Paragraph 11.8.8). The video monitoring is to be provided at the level at which the stair doors discharge and shall be arranged to capture people discharging from, entering, or passing through the discharge level. Additional video-monitoring equipment is required at intervals not exceeding 5 stories so that the descent, ascent, and the entry landings can be monitored remotely. The video cameras may also be used for video-image smoke detection, provided the requirements of NFPA 72 are met. It is recognized that installing the video-monitoring equipment in the stairs may result in additional penetrations in the exit enclosure, which is now specifically permitted and includes all security and communication systems serving the exit enclosure (see NFPA 101; Paragraph (10).

Wall marking

Fire-barrier, smoke-barrier, and smoke-partition markings are now required in the 2018 edition of NFPA 101 for new construction where there is an accessible floor, floor/ceiling, or attic space. While such marking has been required by the International Building Code (IBC), it was not required by previous editions of NFPA 101. Although this requirement may be more architectural or interior design in nature, it should help maintain the integrity of such walls, especially as the integrity is impacted by penetrating items.

Smoke compartments

The maximum area of smoke compartments in hospitals containing single-bed patient rooms and in ambulatory care facilities has been increased from 22,500 sq ft to 40,000. As will be noted in the case study, the consulting engineer needs to be aware of the smoke compartmentation in such facilities since the emergency plan often relies on smoke compartments and indicates that the response by staff is depending on whether they are in the smoke compartment of fire origin or in another smoke compartment. As such, the zoning of the occupant-notification appliances and sprinkler systems should coordinate with the compartmentation designed by the architect.

Figure 3:  A risk analysis to determine the need for a mass notification system would now be required.

Future changes for the 2021 edition of NFPA 101

The cycle has already begun for the development of the 2021 edition of NFPA 101. The technical committees have completed their first-draft meetings. The balloting of the technical committees along with the correlating committee meeting is yet to be held in 2018. Once balloting is complete, the First Draft Report will be issued and the document will be open for public comment until May 8, 2019. Some of the key changes that have been discussed by the committees include the following.

Tall timber buildings

A package of code-change proposals has been processed through the IBC process and was voted on in October. The approach taken in the IBC was to create two new construction types within the Type 4 construction classification. A similar package of changes has been proposed for NFPA 5000: Building Construction and Safety Code. The approach, however, is different. Instead of creating one or two new types of construction within the existing Type IV construction, there are provisions to provide additional protection of the mass-timber structural elements. When such protection is provided, the height and area of the buildings have been increased depending on the occupancy classification. Within NFPA 101, companion changes have been proposed for the occupancy classifications in which the building height is regulated, such as health care occupancies.

Fire alarm systems in health care occupancies

During the first-draft meeting, the Life Safety Technical Committee on Health Care Occupancies discussed potential changes to the fire alarm requirements for health care occupancies. Some of the changes were to coordinate with NFPA 99: Health Care Facilities Code with respect to zoning occupant-notification appliances to be consistent with the smoke compartments or the facility’s emergency plan (see the case study). The committee also discussed the possibility of mandating private operating-mode signaling for new fire alarm systems in health care occupancies. While there are some proposed revisions to further recognize private operating mode, the committee has not yet recommended that private operating mode be the minimum standard for all new systems.

Generator sets in high-rise buildings

A new requirement has been proposed to protect fuel lines supplying generator sets in new high-rise buildings. If approved, the fuel lines will need to be protected with a fire-resistance-rated assembly or a listed fire-resistant pipe-protection system. The change is similar to one that has been approved for the 2021 edition of the International Fire Code.

As with most codes, NFPA 101 is an ever-evolving document with new editions published every 3 years. While the consulting engineer needs to determine the edition of NFPA 101 that is applicable to the project, it is also important to be familiar with changes in more recent editions of the code. Designing a project to meet the minimum requirements adopted by a jurisdiction is essential, but may not always be what the judicial system considers to be the standard of care to be applied by a design professional.

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William E. Koffel, PE, FSFPE, Koffel Associates, Columbia, Md.
Author Bio: William E. Koffel is president of Koffel Associates. He is chair of the NFPA Correlating Committee on Life Safety and a member of several NFPA technical committees. He is a member of the Consulting-Specifying Engineer editorial advisory board.