by Brad Keyes, CHSP, on Jun 8, 2021 1:00:00 AM
Q: We have an MRI trailer attached to one of our hospital buildings. It is physically connected with waiting areas and vestibules. The issue is when it was constructed, the MRI trailer came with sprinklers but were never connected to the hospital and the waiting area and vestibule were not sprinklered either. There is a 2-hour separation between the hospital building and the MRI and that is why they never sprinklered the space. Here are my questions:
- There are 1 – 2 inpatients in the MRI every month, but only one at a time. Would you classify this as a Business Occupancy or as an Ambulatory Health Care Occupancy?
- With the space not being sprinklered, would we need a fire watch if it is classified as an Ambulatory Health Care Occupancy?
We are planning to move with adding sprinklers to the space but we will be surveyed before that is complete.
A: So, you say inpatients use this MRI facility? Does your medical staff ensure that the inpatients who use this MRI trailer are capable of self-preservation in the event of a emergency? Take a look at section 126.96.36.199.2 of the 2012 Life Safety Code. It says ambulatory care facilities, medical clinics, and similar facilities that are contiguous to health care occupancies shall be permitted to be used for diagnostic and treatment services of inpatients who are capable of self-preservation. This means if you wanted to classify the MRI trailer as an ambulatory health care occupancy, only inpatients who are capable of getting up off of the gurney/table and walking out of the building under their own power without the assistance from others, would be permitted in the MRI trailer. Check this out with the diagnostic technicians. Often times I find that the medical staff fails to comply with this requirement, usually due to lack of knowledge and training.
But, for the time being, let’s presume only inpatients who are capable of self-preservation are in the MRI trailer, and the trailer is classified as ambulatory health care occupancy. You have the requisite 2-hour fire-rated barrier to separate the AHCO from the health care occupancy. According to table 188.8.131.52, you can use any construction type you want for an unsprinklered 1-story facility used for ambulatory health care occupancies. (Same thing for Business Occupancy if you classified it was a BO). So, based on what you described, the MRI trailer would not have to be sprinklered as long as: 1) It is classified as AHCO or BO; 2) You maintain the 2-hour fire-rated occupancy separation barrier; 3) And the vestibule area/waiting area is not used as a means of egress from the health care occupancy. However, you do have a serious problem with sprinklers that are installed, but not connected to an approved water source. Section 184.108.40.206 says existing life safety features obvious to the public, if not required by the LSC, shall be either maintained or removed. Sprinkler heads would be obvious to the public, even if they were the concealer-type. So, you need to either remove the sprinkler heads or get them connected to the approved water source. You say you plan on connecting them to a water source in the near future, but probably not in time for an upcoming survey. Then get an ILSM risk assessment conducted and do a fire-watch, remembering a fire watch is now required to be continuous (24 hours/day, 7 days/week) by a trained, designated individual who has no other responsibilities, who stays in the impaired area continuously until the fire watch is discontinued, or they are relieved by another designated individual. They cannot leave the impaired area to use the restroom or to take a break unless they are relieved by another designated individual. When you forecast the cost of a fire watch (3 people/day, 5 people/week, $25/hour calculating in benefits, that’s over $4,000/week), you will find this is very expensive. It may likely be cheaper to just expedite the water connection as soon as possible. A good surveyor will still cite you for not having the sprinklers connected, but at least they cannot cite you for not conducting an ILSM assessment.
Okay, now let’s assume the inpatients brought into the MRI trailer are NOT always capable of self-preservation. That is a serious problem as the structure then is required to meet health care occupancy requirements. Looking at Table 220.127.116.11 for Construction Types for new construction (I believe you would have to meet new construction requirements since it was required to meet new construction requirements when it was originally installed). Construction Type V (000) is not permitted for healthcare occupancies, sprinklered or unsprinklered. My presumption here is the MRI trailer is Construction Type V (000); if you have evidence that it is something else, then that may be helpful. But the bottom line is, no new-construction health care occupancies are permitted to be non-sprinklered. This is the point where we stop and ask ourselves, how in the world did this ever get built this way? This may explain it: Under previous editions of the Life Safety Code, the verbiage in section 18.104.22.168.2 was not included. Taking inpatients into an adjoining facility for diagnostic or treatment purposes was being done without much input from the LSC. Many authorities did not really know how to interpret this concept until the NFPA technical committee clarified this issue (rather well) in the 2012 edition. What was once common practice of taking inpatients into an MRI trailer for diagnostic purposes, may now be prohibited due to a clarification of the 2012 edition of the LSC. It all boils down to whether or not the inpatients are capable of self-preservation. My guess is, they are not, because most inpatients in a hospital are not. But you still have the issue of the installed sprinklers obvious to the public that are not maintained.
If you maintain the MRI trailer is an health care occupancy, then you need to make the case it qualifies as an existing health care occupancy rather than a new construction health care occupancy. I personally would not accept that because it had to meet new construction requirements when it was first installed, but some other surveyor may. If it is classified as existing, then you are permitted to have Type V (000) construction type facility that is fully protected with approved automatic sprinklers, and it could remain in use. Keep in mind section 11.6.1 says trailers that are immobile, and fixed to the building must meet the requirements of the LSC that are appropriate to the building. So, one interpretation is the MRI trailer is required to meet the requirements of the health care occupancy. But you still have section 22.214.171.124.2 that allows you to take inpatients into a contiguous facility that is not classified as health care occupancy as long as the inpatients are capable of self-preservation.
We haven’t discussed other issues involving MRIs, such as sedation. I personally know that many people cannot have an MRI without the use of a sedative. That affects how you utilize the trailer and whether or not you have battery-powered emergency lights in the MRI. I’ve given you a couple of options to consider. This whole issue of taking inpatients into contiguous facilities that are not health care occupancies, is now being interpreted and enforced differently than it was 5 years ago. With the addition of section 126.96.36.199.2 in the 2012 edition of the LSC, it changes how many hospitals utilize trailers for diagnostic or treatment purposes.