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April 2018: The Risk-Based Approach of NFPA 99, Health Care Facilities Code

The 1961 Hartford Hospital fire sparked changes in hospital safety procedures and building codes that remain in place more than five decades later. On the afternoon of December 8th, a fire broke out in a trash chute in the basement of the Hartford, CT hospital, causing gases to collect in an upper portion of the chute, which then ignited. Fire exploded from the trash chute door on the ninth floor, igniting cane-fiber ceiling tiles in the hallway. Fire and heavy smoke quickly moved through the halls of the ninth floor. Firefighters brought the fire under control in a matter of minutes, but the blaze took 16 lives. Survivors were only found in rooms where the doors remained closed throughout the fire.

Just days after the fire, changes were underway to improve hospital fire safety. For example, Connecticut limited smoking in hospitals, banned combustible building materials, and mandated that trash and laundry chutes have fire-safe construction. Over the next few years, improvements to the Hartford Hospital included adding automatic sprinkler protection and replacing rolling door latches with latches that held doors more securely. All these changes were vital to improving hospital safety throughout the country.

Hospital fire safety and protection continue to evolve. The U.S. Centers for Medicare & Medicaid Services (CMS) recently updated the safety codes and standards for the facilities it oversees (hospitals, nursing homes, ambulatory surgical centers, and related facilities that accept federal Medicaid and Medicare reimbursement). Part of that update was requiring health care facilities across the country to comply with the 2012 editions of both NFPA 101®, Life Safety Code®, and NFPA 99, Health Care Facilities Code starting on July 5, 2016.

An increasingly decentralized health care system, a growing array of high-tech procedures, and new security demands spurred many of the changes made to NFPA 99. A major trend in health care delivery has been to move procedures and treatments from acute-care settings such as hospitals into buildings or spaces with flexible use, such as office buildings and ambulatory care facilities. The 2012 edition of NFPA 99 matches safety requirements to the risks posed to patients and caregivers by the procedures being provided rather than the building occupancy type where those procedures take place.

The standard adopted its new approach through added "risk categories" that determine the level of protection required to minimize the hazards of fire, explosion and electricity. Chapter 4 of NFPA 99 addresses the risk and requires a risk assessment for new construction and equipment. Existing construction and equipment will need to follow the inspection, testing, and maintenance (ITM) of the risk category associated with the existing system or equipment. Existing systems or equipment may need a Loss Prevention evaluation to determine the proper risk category. The risk assessment will evaluate systems or equipment and assign one of four risk categories:

A specific risk assessment method is not mandated in NFPA 99. Any method the provider is comfortable with is acceptable, but it must be a defined procedure and must be documented. Different systems or equipment serving the same area may have different risk categories assigned based on the risk assessment. CMS has indicated it will not require the submittal of risk assessments for review. However, if there is an issue or a question about construction features provided in the facility, the risk assessment will be a key document.

If you have any questions regarding changes to the NFPA 99 standard and how they affect your occupancy, please contact Risk Logic. We are happy to help.

Reference Articles:
"Defining Risk: What health care providers, facility designers, and enforcers need to know about the risk-based approach of NFPA 99," NFPA Journal
"Hospital Horror - The Hartford Hospital Fire of 1961," NFPA Journal