The SPD as A Hazardous Area
Q: I am an architect and I have a hospital wanting to be compliant. They have several doors and frames in 1-hour walls that are not labeled. It is a fully sprinkled building built well before 2003. Since the life safety drawings show the walls to an SPD area as being 1-hour, do they need to be 3/4 hour rated? I ask because others have told the facility that they are fine. I assume they told them this based on it being an existing building and only needing to be protected with smoke-resistant construction with self-closing and latching hardware, which it is. Even if it's true, I would prefer they have the life safety drawings changed to show "Smoke Resistant" before I sign off on them being acceptable. During a survey, does an inspector go off of their knowledge or the life safety drawings? This facility also has some frames that need field labeled. Some are "mop frames" where the stop doesn't continue to the floor. Can these be rated?
A: Assuming SPD means sterile processing department, and assuming the SPD is in a healthcare occupancy, I would not be able to say for sure that the SPD is required to be protected with 1-hour fire-rated construction. If the SPD had combustible supplies (such as those blue colored cloth coverings over sterile instruments) then the room would be considered a storage room containing combustible supplies and would have to be treated as a hazardous area. Hazardous areas in healthcare occupancies are required to be protected with 1-hour fire-rated construction or be protected with sprinklers if they qualify as being ‘existing conditions.
However, hazardous areas in new construction in healthcare occupancies are required to be protected with 1-hour fire-rated construction and be protected with sprinklers.
But does your SPD qualify as new construction or existing conditions? That depends on when the SPD was built or last renovated. If the SPD was built or last renovated prior to adoption of the 2012 LSC (which was July 5, 2016), then it is considered ‘existing conditions’ by most AHJs. But some AHJs will expect compliance with the edition of the LSC at the time of the SPD was built or last renovated.
For example: If the SPD was built or last renovated in 1995 (and is considered a hazardous area due to the combustible supplies in storage), the edition of the Life Safety Code that was in effect at that time (the 1985 edition) required new construction rooms containing combustible supplies to be both 1-hour fire rated and protected with sprinklers. So that means, if the SPD failed to be constructed to those requirements at that time, then the AHJ can cite them for not being constructed properly and the SPD cannot qualify today for existing conditions. It was required in 1995 to be 1-hour fire-rated and sprinklered and therefore it must be both 1-hour fire-rated and sprinklered today.
Some surveyors will simply accept the explanation from the organization that it qualifies as existing conditions, and some surveyors will dig deeper and expect it to comply with the edition of the LSC enforced at the time it was constructed. During a survey, most surveyors will use the Life Safety drawings provided by the healthcare organization, as the ‘gospel’ truth, and assess the building based on those drawings. There are exceptions, though. If there is an obvious error on the LS drawings, the surveyor will most likely go by what he sees rather than what the drawings say.
According to information from sources that know more about fire-rated door assemblies than I do, the ‘mop’ frames as you refer to them are acceptable for fire-rated openings.
