Joint Commission’s New Requirement for Business Occupancies
Q: I need a clarification. We're working on evaluating our business occupancies and a question came up: What is required for existing storage areas in business occupancy? If an area is identified as storage, Joint Commission has the following new standard under LS 05.01.30, EP 1: Hazardous areas are protected from other areas by a 1-hour fire resistance–rated barrier (45-minute opening protectives) or a smoke resistive barrier and automatic sprinklers. Doors must be self-closing or automatic closing with latching hardware. (For full text, refer to NFPA 101-2012: 38/39. 3.2). Is Joint Commission requiring over and above what the code requires? I'm not seeing the door closure or latching requirement in NFPA for business occupancy, only being sprinkled.
A: Yes, the Joint Commission is requiring above and beyond what CMS and NFPA require regarding hazardous areas for business occupancies.
According to section 39.3.2.1 of the 2012 Life Safety Code, hazardous areas including, but not limited to, areas used for general storage, boiler or furnace rooms, and maintenance shops that include woodworking and painting areas shall be protected in accordance with section 8.7. Section 8.7.1.1 says protection from any area having a degree of hazard greater than that normal to the general occupancy of the building or structure shall be provided by one of the following means:
Enclosing the area with a fire barrier without windows that has a 1-hour fire resistance rating in accordance with section 8.3
Protecting the area with automatic extinguishing systems in accordance with section 9.7
Applying both 1 and 2 where the hazard is severe or where otherwise specified by chapters 11 through 43.
Nowhere in section 8.7.1.1 does it say that if you choose #2 by protecting the area with sprinklers that you need smoke resistive barriers, and a door that self-closes and positively latches. As you pointed out, Joint Commission has started requiring hazardous areas (i.e. storage rooms) in business occupancies that are fully protected with sprinklers to have smoke resistive barriers and a door that self-closes and positively latches. This new requirement was effective July 1, 2021. This new requirement by Joint Commission could cost healthcare organizations thousands of dollars to make improvements that are not required by NFPA or CMS.
Why does Joint Commission require something that is above and beyond what CMS and NFPA requires? Hard to say, but it could be that they feel it is important enough to require an extra higher level of safety. Or it could be that they goofed again, and didn’t really read the standards very well before making a decision. But be assured, it is well within their right as an Authority Having Jurisdiction (AHJ) to require their clients to meet whatever standards and interpretation they set. But, if you don’t like the Joint Commission standards, you could always go to the competition, such as DNV, HFAP, or CIHQ, as they do not require anything above or beyond what CMS and NFPA says on this particular subject.
I suggest every reader who is accredited by Joint Commission who objects to this new requirement above and beyond what CMS and NFPA require regarding hazardous areas in business occupancies write an email to Herman McKenzie, Director of the Department of Engineering, Standards Interpretation Group at hmckenzie@jointcommission.org. State your objection to the smoke resistive barriers and doors that are self-closing and positive latching required by LS.05.01.30, EP 1 for hazardous areas in business occupancies that are protected with automatic sprinklers.
It may work. They changed their recent requirement for six (6) spare sprinkler heads of each type and temperature rating installed due to the volume of complaints they received from their clients.
