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Healthcare Proposals for ICC 2015 International Fire Code Hearings

 
 
                 
 
September 23, 2013
 
Dear Chapter President,
 
We are writing to bring to your attention some specific code change proposals submitted by the ICC Adhoc Committee on Healthcare (ICC AHC) for the upcoming 2015 International Fire Code (IFC) Group B Code Hearings in Atlantic City, NJ October 1-3, 2013.  It is our opinion that some of their proposals are a very serious threat to fire and life safety in Healthcare facilities. 
 
The hospital industry, through the ICC AHC, will introduce code change proposals to the IFC designed to simplify and streamline the constraints under which healthcare facilities operate.  We believe that most of them are very good and will assist code enforcement in healthcare facilities. Unfortunately, among those other worthwhile proposals, there are a few that would be quite contrary to the goals of a fire safe hospital environment. The attached Brochure titled "Move America's Healthcare Fire Safety Forward" summarizes some critical facts related to these proposals and the concerns they create.
 
New Threats to Hospital Fire Protection:
 
Hospitals are being mandated to provide sprinklers.  As a result, they are attempting to forego the maintenance of passive fire protection systems to reduce costs.  These hospitals are now required by CMS to have a life safety survey on a regular basis and hospitals are now required to be retrofit with a sprinkler system throughout.  Their position is that once this is accomplished, the hospital should be permitted to use all of the sprinkler trade-offs permitted by the IBC for new construction when it comes to maintaining rated walls, or altering walls, but without verifying how far or close the overall safety of the building will be as compared to an IBC-compliant building. To summarize, the changes being proposed to the IFC rely on the addition of sprinkler protection to eliminate almost all components of passive fire protection, even if significant other deficiencies could exist as compared to IBC requirements. 
 
Some examples of these code change proposals that would lower the presently provided levels of fires safety are as follows[VJ1] :
  • Cessation of maintenance of existing fire resistance rated construction after sprinkler retrofit, without specific review of whether overall fire safety would be decreased below IBC-allowable levels (e.g. due to inadequate means of egress)(IFC Section 1103, Code Change Proposal F212-13)
  • Eliminate all existing fire resistance rated corridor walls, even without sprinklers being retrofitted (Code Change Proposal F239-13, IFC article 1105.3.2,)
  • Allows 80 square inch unprotected hole in the wall between every patient room and the corridor, allowing unchecked fire or smoke spread (Code Change Proposal F239-13, IFC article 1105.3.4)
  • [VJ2] Allow any existing smoke barriers to be treated as hour fire rated, even if the original construction mandated 1-hr construction, thus eliminating the need for fire stopping and opening protectives (Code Change Proposal F241-13, IFC article 1105.5.2)
For further understanding of these and other code proposals please see the attached Healthcare Public Comments Summary.  If these code proposals were coupled with changes to the 2015 IBC, which have already reduced the fire safety that will be afforded to I-2 occupants, this would represent massive downward shifts in the level of fire and life safety protection afforded to patients. 
 
The link below is to a recent Article published in Fire Engineering Magazine titled "Should Healthcare Fire Safety Backtrack on 60 Years of Improvement", which highlights many of the concerns.
 
Should Healthcare and Fire Safety Backtrack on 60 Years of Improvement?
 
As Code Officials dedicated to safety of the Public, YOUR voice needs to be heard at the ICC IFC Hearings in Atlantic City October 1-3.  Your views could be instrumental in ensuring that the safety of patients and occupants is not compromised.  
 
If you wish to discuss these code changes, or have questions, please feel welcome to contact Tony Crimi, Code Consultant for the International Firestop Council, at (905) 508-7256 or email tcrimi@sympatico.ca
 
We thank you for your attention to this matter.
 
Regards,
 
 
Brice Miller
Executive Director
International Firestop Council
Office: (970)223-4985
Mobile: (970)430-9960
brice.miller@firestop.org
www.firestop.org
 
 

 
Attachments:
 
Move Americas Healthcare Fire Safety Forward
 
Healthcare Public Comments Summary