NFPA 101 life safety code: changes to 2024 edition impacting healthcare facilities

By Sam Dannaway, PE, FSFPE | Principal Advisor, Chief Fire Protection Engineer

A thorough understanding of the fire protection and life safety requirements of NFPA 101, Life Safety Code, is essential to architects and engineers involved in the design of healthcare facilities.

Background

Compliance with the current edition of NFPA 101, the 2024 edition, is mandatory for the design of all healthcare facilities for the Department of Defense and Department of Veterans Affairs, and other jurisdictions.

The Centers for Medicare and Medicaid Services (CMS) also requires all Medicare and/or Medicaid participating facilities to comply with NFPA 101. CMS has adopted the 2012 edition of NFPA 101. The Joint Commission, a group that provides accreditation of healthcare organizations, also requires compliance with the 2012 edition of NFPA 101. Experts predict that CMS will soon be adopting the 2024 edition of NFPA 101.

Many believe that the adoption of a new edition of a code means added requirements and added cost. However, in the case of healthcare facilities, the more current versions of NFPA 101 have introduced many provisions that have reduced restrictions and provided designers with increased flexibility. Here are a few of those changes.

Major changes between the 2012 and 2024 editions of NFPA 101 for healthcare facilities

  • The size of certain smoke compartments can be increased from 22,500 sf to 40,000 sf.
  • The size of patient sleeping suites, previously limited to a maximum of 5,000 sf, can be increased to either 7,500 sf or 10,000 sf depending on how the suite is arranged.
  • The size of nonsleeping patient care suites, previously limited to areas of either 7,500 to 10,000 sf, can be increased to either 12,500 or 15,000 sf depending on certain requirements.
  • Increased flexibility in door locking arrangements was added to address situations where patient needs require specialized protective measures.
  • In the case of fire alarm systems using private mode notification, the 2024 edition clarifies that both audible and visual notification appliances may be omitted from those areas where it is deemed that patient care is adversely affected.
  • The 2024 edition clarifies that the sterile cores supporting operating suites and anesthetizing areas that meet certain requirements are not considered hazardous areas.

Alternate Care Sites

The 2024 edition of NFPA 101 has introduced fire protection and life safety guidance for Alternate Care Sites, which are defined by NFPA 101 as:

Any building, structure, or portion thereof not currently being used for healthcare that is temporarily reoccupied, converted, constructed, or relocated for healthcare use during an urgent need in capacity to provide additional capability for an affected community.

The COVID-19 pandemic made authorities acutely aware of the importance of quickly creating temporary healthcare facilities during public emergencies. Hotels, dormitories, and arenas are examples of the types of facilities that were converted to temporary hospitals during the pandemic. NFPA 101’s guidance for these “alternate care sites” will allow jurisdictions to meet the emergency needs of communities while meeting minimum life safety requirements for temporary healthcare facilities.

This article addresses some of the changes in the current edition of NFPA, including major differences from the 2012 edition currently used by CMS and the Joint Commission. Understanding these changes will be a great benefit to healthcare facility designers.

For more information, contact Sam Dannaway, PE, FSFPE.

Sam is a principal member of the NFPA 101 Technical Committee on Healthcare Occupancies, as well as a principal member of the NFPA 101 Technical Committee on Educational and Day-Care Occupancies.