By Brad Keyes / Special to Healthcare Facilities Today

Q: Do occupational therapy kitchens need to meet NFPA 96 standards? This unit will be a new build and will fall under business occupancy requirements, but the Life Safety Code for new business occupancies refers me back to 9.2.3, which refers me to NFPA 96.

A: Is the cooking equipment really ‘commercial cooking equipment’? For an occupational therapy kitchen, you would be using residential cooking equipment, would you not? Also, is the cooking equipment that is used for occupational therapy ever turned on…? Do they ever actually cook or bake anything on the stove?

If it were a healthcare occupancy, the answer is a no-brainer, since section 19.3.2.5.2 specifically says residential cooking equipment that is used for food warming or limited cooking does not have to meet the requirements of 9.2.3. While that section may have been written for food warming equipment in staff lounges, one could apply it towards occupational therapy kitchens as well.

But you may have a good case with sections 38/39.3.2.3 (3), which says something similar and exempts cooking equipment used only for food warming from having to meet section 9.2.3. There are a few other points that would prevent you from having to meet NFPA 96 requirements. According to NFPA 96-2011, section 1.1, it says the following regarding residential equipment:

• 1.1.2 This standard shall apply to residential cooking equipment used for commercial cooking operations.

(You’re not using this residential cooking equipment for commercial cooking operations, so therefore, NFPA 96 does not apply).

• 1.1.4* This standard shall not apply to facilities where all of the following are met:

(1) Only residential equipment is being used.

(2) Fire extinguishers are located in all kitchen areas in accordance with NFPA 10, Standard for Portable Fire Extinguishers.

(3) The facility is not an assembly occupancy.

(4) The authority having jurisdiction has approved the installation.

(Make sure you comply with the above four items and you do not have to comply with NFPA 96.)

So, I think you have enough to go on to convince an AHJ that a NFPA 96 exhaust hood is not required for occupational therapy residential cooking equipment in business occupancies.

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.