By Brad Keyes / Special to Healthcare Facilities Today

Q: I have a procedure room in our Cath Lab that Administration wants to convert to a storage room. The building is fully sprinkled and as I look at NFPA 18.3.2.1 of the 2012 LSC, it refers me to section 8.7. It would seem that I could use this room for hazardous storage (combustibles) as long as I have a smoke barrier and a self-closing 20-minute door, because that is what section 8.7 permits. The room is over 100 square feet. Other storage rooms in this building are protected with a 1-hour fire rated wall system, that includes a 45-minute fire rated door assembly… so, can I or can't I use non-rated smoke partitions for this new storage room?

A: Well… not quite. You have the right idea, but section 18.3.2.1 of the 2012 LSC over-rides section 8.7. Take a look at 18.3.2.1 which says any hazardous area shall be protected in accordance with section 8.7, and the areas described in Table 18.3.2.1 shall be protected as indicated. Table 18.3.2.1 says storage rooms larger than 100 square feet and storing combustible material requires 1-hour fire rated barriers. You state your former Cath lab procedure room is more than 100 square feet, so by the looks of things, this is the governing statement on new hazardous rooms.

However, there may be an exception that might apply to your situation. There is a new chapter in the 2012 LSC that was not in the 2000 edition: Chapter 43, which is on building rehabilitation. Take a look at 43.7.1.1 which says 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.

Looking at 43.7.1.2 (2), it says for existing healthcare 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 square feet 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.

Okay… what this is saying is the change in use of the Cath lab procedure room to a storage room that is a hazardous room, does not have to meet new construction requirements for hazardous rooms (i.e. 1-hour fire rated barriers and ¾ hour fire rated door assembly), but may comply with existing construction requirements for hazardous rooms (i.e. smoke partitions and non-rated self-closing door), PROVIDED:

• The room does not exceed 250 square feet

• The entire building is protected with sprinklers

Measure the area of the old Cath lab procedure room. If it does not exceed 250 square feet, then you do not have to meet 1-hour fire rated barrier requirements. However, if it does exceed 250 square feet, then I’m sorry to say, you do have to meet 1-hour fire rated barrier requirements, with a ¾ hour fire rated door assembly.

Brad Keyes, CHSP, is the owner of KEYES Life Safety Compliance, and his expertise is in the management of the Life Safety Program, including the Environment of Care and Emergency Management programs.