Patient Smoking Shelter
by Brad Keyes, CHSP, on Jul 9, 2021 1:00:00 AM
Q: My hospital has an enclosed smoking shelter for patients on an outdoor patio that is separate from the building. I am unsure of the materials it was built with as it was in place prior to my arrival and no one seems to be able to find any paperwork. It is 15 feet from the hospital. We had a fire a month ago and one of our doctors stated the sliding door in the shelter did not have a handle for her to grip. It took her multiple trials to close the door to prevent the black smoke bellowing out where she was standing. She then cited the following NFPA Code:
Horizontal-sliding doors permitted by 126.96.36.199 that are not automatic-closing are limited to a single leaf and shall have a latch or other mechanism to ensure the door will not rebound. Horizontal-sliding doors serving an occupant load fewer than 10 shall be permitted, providing all of the following criteria are met:
- Area served by the door has no hazards
- Door is operable from either side without special knowledge or effort
- Force required to operate the door in the direction of travel is = 30 lbs to set the door in motion and = 15 lbs to close or open to the required width
- Assembly is appropriately fire rated, and where rated is self-or automatic-closing by smoke detection per 188.8.131.52, and installed per NFPA 80
- Where required to latch, the door has a latch or other mechanism to ensure the door will not rebound. 184.108.40.206.11, 220.127.116.11.11
I am familiar with the codes but I don’t see where the above applies to outside detached smoking shelters. Are there any NFPA or related requirements such as doors, etc.?
A: Well, all buildings associated with the operation of a healthcare facility are subject to survey and must comply with the respective occupancy chapters of the 2012 Life Safety Code and the 2012 edition of NFPA 99. But let’s look at each issue that you presented:
First, section 18.104.22.168 in the 2012 LSC is referencing the Won-Door type of horizontal-sliding door. Look at sub-section (2), which says, “The force, that when applied to the operating device in the direction of egress, is required to operate the door leaf is not more than 15 lbf.” That describes a Won-Door that is an automatic horizontal-sliding door. Look at page 196 in the 2012 Life Safety Code Handbook (if you don’t have one, buy one. It is full of useful information) as it explains why section 22.214.171.124 is all about the Won-Door better than I can explain it. So, section 126.96.36.199 is not the appropriate code paragraph to cite this particular issue.
Second, are healthcare workers using the same smoke hut as patients and visitors? If so, I suggest that stops right away. That is a dangerous potential HIPAA rule issue and those people should never share space like that. Loose lips sink ships.
Third, since it is 15 feet away from the hospital, then it can be any construction type you want and not have to be compliant with healthcare occupancy construction type. So, if the smoking hut is business occupancy or industrial occupancy, you could use combustible wood-frame and you would not be required to have a 2-hour barrier to separate it from the hospital. Also, it does not require a 2-hour fire-rated barrier to act as an occupancy separation either since it is separated from the hospital by at least 10 feet.
Fourth, that paragraph that you quoted, saying “Horizontal-sliding doors serving an occupant load fewer than 10 shall be permitted…” is from section 188.8.131.52.1(4)(c) of the 2012 LSC which is in a core chapter that serves all of the different occupancy chapters. It starts with the verbiage “Unless prohibited by Chapters 11 through 43…”. This means it can be prohibited by the occupancy chapter that applies to your smoking shelter. It’s not prohibited by the healthcare occupancy chapters, and in fact is repeated under section 184.108.40.206.10.2, and it is not prohibited by the business occupancy chapters either. So, you could classify your smoking shelter a business occupancy.
So, technically, the sliding door is legal depending on the classification of occupancy for the smoking shelter. But, my advice is, take your medicine and install a side-hinge, swinging type door in the smoking hut. Or, better yet, get rid of that smoking hut for good.