National Fire Protection Association (NFPA) 101 Life Safety Code and NFPA 99 Health Care Facilities Code are critical documents for fire prevention and hazard mitigation in healthcare facilities. That’s why healthcare safety professionals need to stay current with additions and changes to the NFPA codes.

Fire protection engineer Mike Crowley reviewed these changes with ASSP’s Healthcare and Fire Protection practice specialties. Crowley is operations manager and principal advisor for Coffman Engineers and a long-time member of the NFPA committees that write these codes. 

Here are the major items healthcare safety professionals should know.

NFPA 101: Impact on Healthcare

While the bulk of the NFPA code that is relevant to healthcare safety professions is found in Chapters 18 through 21, which covers new and existing healthcare and ambulatory healthcare occupancies, Crowley notes other areas that may impact healthcare facilities.

Alternate Care Sites

In Annex D, NFPA defines and offers guidance on alternate care sites (ACSs). ACH are temporary sites to provide healthcare services, such as hotels, arenas, barracks, dorms, tents and closed hospitals.

The annex includes recommendations for site assessments, planning and design, construction, operation, maintenance and decommissioning.

While compliance with NFPA 101 is still required for ACSs, an occupancy change for these buildings is not. For example, setting up an arena as an ACS does not mean redesigning it in accordance with the requirements for a new healthcare occupancy found in Chapter 18, Crowley says. 

“We’re not really mandating that,” he adds. “But we are trying to make sure we at least meet some level of compliance with 101.” 

Those implementing ACSs should also connect with local jurisdictions, local and state health departments and the Centers for Medicare and Medicaid Services. They should also use the appropriate interim life safety measures.

Modular Room and Sleep Pods Codified

A new addition, Chapter 10.7, covers requirements for modular rooms and sleep pods. Modular rooms are defined as occupiable, prefabricated structures consisting of walls and a ceiling such as a lactation pod, while sleep pods are similar constructions but designated specifically for sleep. “If you’re going to be introducing these types of pods in your facility, there is a whole section for that now,” Crowley says.

New Carbon Monoxide Detection Requirements

Carbon monoxide detection requirements were added to chapters 18.3 and 20.3. These only apply to new healthcare and ambulatory healthcare facilities where fuel-fired appliances like heaters are present. “That’s been trending in the marketplace,” Crowley says. “All residential occupancies already require it; healthcare is one of the last to include it.”

Changes in Requirements for High-Rise Buildings

High-rise hospitals are also subject to Chapter 11’s high-rise building requirements. Importantly, all high-rise buildings (including existing ones) must be fully sprinklered by July 2028. Additionally, NFPA dropped its requirement to have smoke-proof enclosures for exiting systems for fully sprinklered buildings.

Door Locking Requirements Revised

In previous versions of the code, “smoke compartments” in non-sprinklered facilities were required to have sprinklers to allow certain locking arrangements. Also, any area you travel through to get to a smoke compartment must now have sprinklers.

Additionally, manual fire alarm box activation is not required to release stairwell doors using delayed egress devices. In other words, manually pulling a fire alarm will not automatically release those doors, Crowley says. A smoke detector or sprinkler system activation must occur to release those doors.

Sterile Cores Now Exempt From Hazardous Area Requirements

Sterile cores are now exempt from hazardous area requirements. This change stemmed from “what we’re seeing in the actual world,” Crowley says. NFPA’s committee reviewed the hazard data of sterile cores and found there were not many documented fires, therefore they are no longer considered hazardous.

More Clarity Comes to Construction Requirements

While it’s long been required to separate construction areas from an operating hospital, those requirements have not always been clear, Crowley says. The “area of separation” requirements now reference NFPA 241, Standard for Safeguarding Construction, Alteration and Demolition Operations, and include recommendations on features to have in a construction zone.

Parking Structures Now Need Sprinklers

Two changes in Chapter 42 will impact healthcare parking structures. The common path of travel in a parking structure increased from 50 feet to 75 feet. Additionally, sprinklers are required in all new parking structures as new cars’ materials are more combustible and cause greater fire spread. Electric vehicle fires also pose new fire risks in parking structures.

NFPA 99: What Are the Big Changes?

The 2024 version of NFPA 99 eliminates many concerns that were introduced in 2012 when the NFPA shifted from an approach based on the type building involved (e.g., hospital, ambulatory care facility, doctor’s office) to an approach based on risk of procedures, Crowley says. Here are some key changes in the updated NFPA code.

Anesthetizing Locations Must Be Designated

According to Chapter 1, a healthcare facility’s governing body must designate all anesthetizing locations, which carry specific requirements. An anesthetizing location is an area where general anesthesia or moderate or deep sedation is intended to be administered.

The NFPA Code Sets Maximum Allowable Quantities on Medical Gas

The new code sets maximum allowable quantities for medical gas — a big change, Crowley says. “In the past, we didn’t have declared upper-end limits, and that drove the fire marshals crazy,” he notes, adding that the move was controversial in the committee and may end up being modified. Chapter 5 now contains a table that defines some limitations on oxygen and nitrous oxide in indoor areas.

Dental Gas Definitions and Sprinkler Requirements Change

While dental offices are not required to be sprinklered, any room where dental gas is stored must now be sprinklered. The updates in Chapter 15 also place dental gasses into three categories, “recognizing the fact that deep sedation is not going to be treated the same way it was years ago,” Crowley says.

Other Changes of Note in NFPA Code 99

In addition to the major changes, the revision has some minor or more highly specific changes, such as:

• Fully non-smoking facilities no longer must display “no smoking” signs everywhere.
• Changes in electrical terminology allow different types of systems to be used.
• Chapter 14 highlights changes that only apply to new hyperbaric facilities. Pressure release devices are required and there is new terminology for fire protection systems.
• A clarification in Chapter 16 reveals that voice notification of the fire alarm is not required, but a method to identify the fire location to responding staff is required. For example, remote annunciators or zone-coded systems can be used if you’re not using voice communications.

Who Must Comply With These Codes?

NFPA 101 and 99 have been effective since Sept. 2023. Any authority-having jurisdiction (AHJ) can adopt through a formal action, Crowley says.

Some organizations have already adopted one or both, including the Department of Defense, Veterans Administration, General Services Administration, United States Army Corps of Engineers and some limited local jurisdictions. Healthcare organizations working with these organizations must comply with the 2024 codes.

Centers for Medicare and Medicaid Services (CMS) has not yet formally adopted the codes, but Crowley says healthcare safety professionals should watch the Federal Register, where CMS will post that it is considering using the 2024 editions of NFPA 101 and 99, and asking for public response. After a period of typically 60 days, CMS will look at those responses, develop its own rules, ask for public response again, then issue final rules, Crowley says. This process can take between three and five years to complete, so the reality is that while healthcare safety professionals do not need to rush to comply with the 2024 code, they should move in that direction, Crowley advises.

“Is it an advantage to go to these codes? I think it’ll save you some headaches,” he says.

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