Smoke Detectors in On-call Rooms
Recently there has been a discussion regarding "single station" smoke detectors per the requirements of LS.02.01.34 EP-4 and the NFPA Life Safety Code. LS.02.01.34 EP-4 is a catch-all phrase directing you to the Life Safety Code; i.e. “The organization meets all other Life Safety Code (LSC) fire alarm requirements related to NFPA 101-2000: 18/19.3.4 and is a C scored item.” Looking at LSC reference 19.3.4 Detection, Alarm, and Communications Systems section 19.3.4.2 *Initiation section discusses initiation by manual or detection devices, manual pull boxes in patient sleeping areas, and commercial cooking protection. There is an appendix statement in 19.3.4.2 which states “It is not the intent of this Code to require single station smoke-detectors, which might be required by local codes, to be connected to initiate the building fire alarm system.” This statement could then be translated to mean unsupervised sleeping areas require battery powered single station smoke-detectors. Looking at section 19.3.4.3 Notification section talks about automatic notification and discusses audible and visual alarms in critical care areas, and visual alarms in patient sleeping areas approved by the AHJ.
LSC Section 6.1.14.1 requires multiple occupancies in a building to meet the requirements of either mixed occupancies or separated occupancies. Assuming on-call rooms are considered a mixed occupancy, LSC Section 6.1.14.3 requires each portion of the building to comply with the most restrictive life safety requirements. The use of an on-call sleeping room may be classified as a Lodging or Rooming occupancy (16 of fewer sleep rooms) or a Hotel and Dormitory occupancy (17 or more sleeping rooms). Both occupancies require single station smoke alarms in every sleeping room.
The person in the on-call room is not a patient. Therefore, on-call rooms could be classified as a Lodging or Rooming House occupancy which is defined in the LSC 2000 edition as follows:
3.3.147 Lodging or Rooming House. A building or portion thereof that does not qualify as a one- or two-family dwelling, that provides sleeping accommodations for a total of 16 or fewer people on a transient or permanent basis, without personal care services, with or without meals, but without separate cooking facilities for individual occupants.
LSC Chapter 26 Lodging or Rooming House, section 26.3.4.5 discusses the smoke alarm, section 26.3.4.5.1 ties in the smoke alarm requirement for every sleeping room; section 26.3.4.5.3 states, “Existing battery powered smoke alarms, rather than house electric powered smoke alarms, shall be permitted where the facility has demonstrated to the authority having jurisdiction that the testing, maintenance, and battery replacement programs will ensure reliability of power to the smoke alarms. LSC Chapter 29 Hotels and Dormitories contains similar statements found herein chapter 26.
The testing requirement for single station smoke alarms can be found in NFPA 72 1999 Edition Section 7-3.2.1. It does require smoke alarms which are not in one-and-two family dwelling to be tested for sensitivity within one year after installation and every two years after.
In summary, an unassuming statement at the end of Joint Commission section has weaved its way through the codes to lead to an innocuous requirement that requires immediate attention. In the end, LSC Chapter 26 Lodging or Rooming House, section 26.3.4.5.1 requires approved single station smoke alarms be installed in every sleeping room, and 26.3.4.5.3 requires that Facility Managers need to have a policy on reliability of power to the smoke alarms and performing sensitivity testing. Check with your local fire department for a written recommendation to replace the battery.
Daniel J. Campbell CHFM, FASHE
3525 Germantown Avenue
Philadelphia PA 19040
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