New vs. Existing Hazardous Rooms
by Brad Keyes, CHSP, on Dec 23, 2020 12:00:58 AM
Q: What Life Safety Code standard are you citing when you say a hazardous room created before March 11, 2003 must be sprinklered, and the walls must be one-hour fire rated and extend from the floor to the deck above, and the door must be ¾-hour fire rated, self-closing and positive latching? Also, what Life Safety Code standard are you citing if the hazardous room was originally constructed to ‘new conditions’ before the adoption of the 2012 Life Safety Code, but it now cannot be down-graded to ‘existing conditions’, but must be maintained as ‘new conditions’?
A: The 2000 edition of the Life Safety Code was adopted on March 11, 2003. For new construction applications, section 18.104.22.168 of the 2000 LSC says all hazardous rooms (i.e. storage rooms with combustible supplies larger than 100 square feet) must be protected with sprinklers, and the walls of the room must be 1-hour fire-rated, extend from the floor to the deck above, and all opening protectives (i.e. doors) must be ¾-hour fire rated, self-closing, and positive latching. Fast-forward to today, according to the 2012 Life Safety Code, this shell space could be considered by some AHJs to be existing conditions since it was created before July 5, 2016 (the date the 2012 LSC became effective), which means it could be either protected with sprinklers, or 1-hour fire barriers, but not required to be both.
But that means the shell space was not constructed properly when it was created. If for some reason it was not protected to new construction requirements when it was created, then the AHJ has the right to make you go back and meet these new construction requirements even though we are no longer on the 2000 Life Safety Code. This is an interpretation and while not all AHJs enforce this section this way, many of them do. Section 22.214.171.124. says no existing life safety feature shall be removed or reduced where such feature is a requirement for new construction.
This means, if your shall space is constructed to 1-hour fire rated barriers, ¾-hour fire rated door assemblies, and fully protected with sprinklers, you must maintain those features for the life of the building, or until new construction requirements allows you to remove one or more features of life safety. Section 126.96.36.199 also says whenever any feature of life safety is required by the Life Safety Code, it must remain and be continuously maintained.