Q: NFPA 101-2012; 19.2.3.4(2) allows "non-continuous projections not more than six inches from the corridor wall, above the handrail height", but the ADA-2010 Standard [§204] only allows projections of four inches or less. Are deemed status Hospitals subject to the ADA?
A: Yes, they are according to the CMS Final Rule to adopt the 2012 Life Safety Code published May 4, 2016. All CMS-certified healthcare providers cannot have a wall-mounted projection of more than 4 inches. This is measured from 27 inches above the floor to 80 inches above the floor according to the ANSI standard A117.1-2009, section 307.2, which is referenced in the ADA standard. But this also allows for wall-mounted items (i.e. clocks, signs, monitors) to extend more than 4-inches into the corridor as long as they are at least 80 inches above the floor.
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.