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The interpretation process is used when a Code or
Standard is unclear
of its intent. Once an interpretation has been made, it applies to all
licensed facilities. The interpretations of the Building Codes and
Standards listed on this page are the official position of the Department of
Health. Facilities regulated by the Department of Health are often regulated
by multiple jurisdictions. In cases where there are two different
interpretations between jurisdictions, the most stringent interpretation
shall apply.
Interpretations for NFPA standards
Interpretations for Uniform Building Code
Interpretations for Uniform Mechanical Code
NFPA
NFPA 13
Q. Do the supporting rails and structure of patient lift systems constitute a sprinkler obstruction per NFPA 13?
A. Yes patient lift systems may create unwanted sprinkler obstructions. 8.6.5.2.1.4 exempts nonstructural elements in light and ordinary hazard occupancies from the "Three Times Rule". The "Beam Rule" (8.6.5.1.2) and the "Wide Obstruction Rule" (8.6.5.3.3) still apply. In most patient lift scenarios, the supporting rails of the patient lift systems would be considered a "solid continuous obstruction" (8.6.5.2.1.2) and would have to meet the "Beam Rules" found in 8.6.5.1.2.
Background
Section 8.6.5.2.1.3 calls out: "Unless the requirements of 8.6.5.2.1.4 through 8.6.5.2.1.10 are met, sprinklers shall be positioned away from obstructions a minimum distance of three times the maximum dimension of the obstruction (e.g., structural members, pipe, columns, and fixtures). The maximum clear distance required shall be 24-inches in accordance with Figure 8.6.5.2.1.3."
Section 8.6.5.2.1.4 that "For light and ordinary hazard occupancies, structural members only shall be considered when applying the requirements of 8.6.5.2.1.3.
A.8.6.5.2.1.4 It is the intent of this section to exempt nonstructural elements in light and ordinary hazard occupancies from the obstruction criteria commonly called the “Three Times Rule.” However, the other obstruction rules including the “Beam Rule” ( 8.6.5.1.2) and the “Wide Obstruction Rule” ( 8.6.5.3.3) still apply. If an obstruction is so close to a sprinkler that water cannot spray on both sides, it is effectively a continuous obstruction as far as the sprinkler is concerned and the Beam Rule should be applied.
It is not the intent of this section to permit the use of fixtures and architectural features or treatments to conceal, obscure, or otherwise obstruct sprinkler discharge. The exception should be applied in accordance with the performance objectives in 8.6.5.1
NFPA 13R, Section 2-6
Q. Do exterior exit alcoves in LC occupancies need to be sprinklered in new construction when a 13R system is installed?
A. Yes, if the exterior exit alcove is in the path of egress it is required to be sprinklered.
Rationale
Commonly buildings are designed with exterior alcoves at the exits to protect building occupants from the weather. The alcoves are sometimes furnished and designated as the smoking areas for the facility. The Department believes that it is imperative to the building occupants that some level of protection to these exits be provided when they are part of the egress system based on the Uniform Building Code which defines the egress system as an undiminished path of egress to the public way. The Department recognizes that in situations where the occupants are not required to use the alcove for egress routes that automatic fire suppression would not be required in 13R systems per NFPA 13, Section 2-6 Exception No. 3.
Some level of protection equal to that of the corridor must be provided to complete the undiminished path of egress to the public way.
NFPA 99, 5.1.4.8.7
Q. Are individual
medical gas shut off valves required to be located outside each emergency
patient room or intensive care patient room?
A. No, provided
that these rooms are not designated anesthetizing locations.
Rationale
In
Washington State, the 2002 version of NFPA 99 is adopted by reference
through the 2003 Uniform Plumbing Code. The Department of Health also
enforces the 1999 version of NFPA 99 as a condition of the federal
requirements for participation in Medicaid/Medicare.
In both versions, the
requirement for shut off valve locations is based on the specific function
of the area that the valve serves. Patient care areas within healthcare
facilities are classified as either general or critical. A subset of the
critical areas is anesthetizing locations. All anesthetizing locations are
critical areas, however, not all critical care areas are anesthetizing
locations.
The 2002 version of NFPA
99, section 5.1.4.8.7 requires "A zone valve shall be located immediately
outside each vital life-support, critical care, and anesthetizing location
in each medical gas and/or vacuum line." The Department applies this
requirement to both critical care areas and anesthetizing locations as they
are defined. The 2002 version of NFPA 99 lists the following definitions:
3.3.135.2
Critical Care Areas.
Those special care units, intensive care units, coronary care units,
angiography laboratories, cardiac catheterization laboratories, delivery
rooms, operating rooms, postanesthesia recovery rooms, emergency
departments, and similar areas in which patients are intended to be
subjected to invasive procedures and connected to line-operated,
patient-care-related electrical appliances.
3.3.9
Anesthetizing Location.
Any area of a facility that has been designated to be used for the
administration of nonflammable inhalation anesthetic agents in the course of
examination or treatment, including the use of such agents for relative
analgesia.
The critical care areas definition specifically differentiates between
specific individual rooms (angiography laboratories, cardiac catheterization
laboratories, delivery rooms, operating rooms, and postanesthesia recovery
rooms) and specific units (special care units, intensive care units,
coronary care units, and emergency departments). The “rooms” listed are
where anesthetizing is typically performed. An anesthetizing location is
one that has been designated, by the facility, to be used for the
administration of nonflammable inhalation anesthetics.
Therefore, an individual shut off is required outside each individual room
that designated as an anesthetizing location, or, each individual room
specifically listed as a “room” or a “laboratory” under the definition of
critical care area. Critical care areas listed as "units" or "departments"
require a zone valve for each area, implying that a number of outlets can be
served by one zone valve.
The distinct difference
between critical care areas and anesthetizing locations is also shown by the
location of the alarms and sensors as shown in the following figure:
Figure A.5.1.4. , NFPA 99, 2002
version
Reprinted with permission from NFPA
99, Health Care Facilities, Copyright ©
2002 National Fire Protection Association, Quincy MA 02169. This
reprinted material is not the complete and official position of the
National Fire Protection Association on the referenced subject which
is represented only by the standard in its entirety.
This concept is more
clearly illustrated by the following figure from the 1999 version:
Figure
4-3.1.2, NFPA 99, 1999 version
Reprinted with permission from NFPA
99, Health Care Facilities, Copyright ©
1999 National Fire Protection Association, Quincy MA 02169. This
reprinted material is not the complete and official position of the
National Fire Protection Association on the referenced subject which
is represented only by the standard in its entirety.
Using this logic, the
Department does not require individual room shut off valves outside of each
emergency room or each critical care room. These areas are covered by one
zone shut-off valves that serve that area.
Uniform Building Code
Section 313.8.2.1 Uniform Building Code
Q.Is a NFPA 13d system an appropriate system for use in board and care facilities?
A. No, NFPA 13D systems are only appropriate for use in one- and two family dwellings. NFPA 13D, 1-1 states that NFPA 13D systems cover “design and installation of automatic sprinkler systems for protection against the fire hazards in one- and two family dwellings and manufactured homes” A board and care facility is a congregate residence which does not fall under either of those definitions.
Rationale
The commentaries and interpretations for NFPA 13-D and 13-R discuss the merits and limitations of these systems. While the UBC-Washington State Amendment excepts the use of a 13-D system for an existing building that is being changed in use to a use that would be classified as an LC occupancy when under 16 clients are to be served, the sprinkler standard itself states it is not an acceptable system for a board and care facility. It is the Department of Health’s opinion, as well as the opinion of the Office of the State Fire Marshal and leading industry experts, that it is not appropriate to allow a system in this type of licensed health care facility that only supplies water based on a two head calculation and has no means to supplement it because there is no fire department connection.
Evacuation capabilities of Occupants
People age 65 and over have a fire death rate twice the national average, 75 and over three times and 85 and over four and a half times twice the national average . The average age of boarding home residents in the state of Washington is 79. Many of the residents in board and care facilities cannot walk with out some form of assistance. Many facilities that provide care initially accept residents that are capable of self-preservation, however many of the facilities market and promote “aging in place”, or growing older without having to move. The effects of aging often lessen ones mobility capabilities. Disabled subjects travel an un-obstructed path at 2.62 feet per second, where non-disabled subjects travel nearly twice the speed at 4.10 feet per second.
Sprinkler System Capabilities
Life Safety is the primary goal of a NFPA 13D system, with property protection a secondary goal. The system design should be such that a fire could be controlled for sufficient time to enable people to escape – that is, a 10-minute stored water supply with an adequate local audible alarm. A 10-minute goal is not enough time for disabled occupants to exit a multistory board and care facility. Buildings that contain more than two dwelling units, or when it is anticipated that multiple persons with disabilities will be occupying the building shall be protected with an NFPA 13R or NFPA 13 system.
There has never been a multiple death fire in a building that is adequately protected by an approved automatic fire suppression system. When the systems are installed per the NFPA standards it has come to be expected that a nationally recognized level of safety has been achieved.
Conclusion
Based on the primary goal for life safety of all residents and staff, we believe the commentary and directives for a NFPA 13d system
supersedes the exception listed in this section of the state amendments to the Uniform Building Code.
Uniform Mechanical Code
UMC 404.1
Q. Please clarify the Department's position on the requirements of return air being obtained from corridors in Group I occupancies under the 1997 Uniform Building Code and 1997 Uniform Mechanical Code.
specifically Section 404.1 Uniform Mechanical Code which states that return air may not be obtained from
a corridor, exit passageway or exit enclosure required by the Building Code to be of fire resistive construction.
A. The Washington State Department of Health's interpretation of Section 404.1 requirement #8 of the 1997 UMC, is as follows: in Group I occupancies, with corridors constructed per Section 1007.5 of the Uniform Building Code, this provision applies only to exit passageways and exit enclosures.
Rationale
The restriction of return air conflicts with WAC 51-42, Washington State amendment to the 1997 Uniform Mechanical Code, Section 601.1.1, exception 2. This exception allows corridors conforming to Section 1007.5 UBC, in Group I occupancies to be used as a supply or return plenum. Additionally, return air is not prohibited by the 1994 Uniform Mechanical Code or nationally recognized standards published by ASHRAE or the AIA Guidelines for Design and Construction of Hospitals and Health Care Facilities. Furthermore, the Technical Advisory Group (TAG) has recognized this over sight in the 97 Uniform Building Code and have specifically exempted corridors in “I” occupancies from this requirement. It is acceptable to allow exit access corridors to serve as supply, return, exhaust, relief or ventilation air ducts in the International Mechanical Code. Therefore, all "corridors" in I occupancies meet the intent of UMC 601.1.1. Exit enclosures and passageways are constructed differently; therefore do not meet the intent of 601.1.1.
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