Converting a Patient Room into a Hazardous Storage Room by Dean Samet, CHSP, CJCS
Have you ever been looking for additional storage space and discovered that there was an existing patient sleeping room that was seldom if ever occupied and seemingly prime for confiscation? Have you wondered what it would take to convert that room into a code-complying hazardous storage room? There is specific language in the 2012 edition of the NFPA 101® Life Safety Code® that finally addresses this very issue. Once the various AHJs (authorities having jurisdiction) adopt the 2012 Life Safety Code, the opportunity will be available per the referenced Code.
Per Chapter 43 Building Rehabilitation, Section 43.7 Change of Use or Occupancy Classification, Section 43.7.1 Change of Use, and specifically Section 43.7.1.1 – A change of use that does not involve a change of occupancy classification shall comply with the requirements applicable to the new use in accordance with the applicable existing occupancy chapter, unless the change of use creates a hazardous contents area as addressed in 43.7.1.2.
43.7.1.2 A change of use that does not involve a change of occupancy classification but that creates a hazardous area shall comply with one of the following: (1) The change of use shall comply with the requirements applicable to the new use in accordance with the applicable occupancy chapter for new construction. (2) For existing health care occupancies protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1), where a change in use of a room or space not exceeding 250 ft2 (23.2 m2) results in a room or space that is described by 19.3.2.1.5(7), the requirements for new construction shall not apply, provided that the enclosure meets the requirements of 19.3.2.1.2 through 19.3.2.1.4.
43.7.1.3 Any repair, renovation, modification, or reconstruction work undertaken in connection with a change of use that does not involve a change of occupancy classification shall comply with the requirements of Sections 43.3, 43.4, 43.5, and 43.6, respectively. [43.3 Repairs; 43.4 Renovations; 43.5 Modifications; 43.6 Reconstruction].
To summarize, the “change of use” for converting that existing patientsleepingroom into a hazardous storage room must comply with either of the following: –New Health Care Occupancy chapter requirements (with automatic extinguishing system and a fire barrier having a 1-hour fire resistance rating) or – Existing Health Care Occupancy requirements where those occupancies are protected throughout by an approved supervised automatic sprinkler system; room is separated from other spaces by smoke partitions with self-closing, positive latching door(s);and room does not exceed 250 square feet.
Until your authorities having jurisdiction adopt the 2012 edition of the NFPA 101®Life Safety Code, you may want to apply for an equivalency and/or Life Safety Code waiver to see if those AHJs will accept the 2012 LSC edition requirements for converting that patient room into a hazardous storage room.