Per 18.1.3.3 (2012 101 NFPA Life Safety Code) "...
sections of health care facilities shall be permitted to be classified as other occupancies, provided that they ... are separated from areas of health care occupancies by construction having a minimum 2-hour fire resistance rating."
This separation is only required if you are designating the building as a "
separated occupancy" per 6.1.14.4. Section 18.1.3.3 states it "
shall be permitted" so
The decision to designate a building as a "
mixed occupancy" or as a "
separated occupancy" per Chapter 6 is up to the designer. If the exit access traverses other occupancies, the multiple occupancy must be treated as a "
mixed occupancy" (e.g. non-separated). Designers (and some AHJs) misinterpret "Table 6.1.14.4.1(a) Required Separation of Occupancies" as a requirement for all multiple occupancy conditions instead of just for separated occupancies.
Pharmacies are not one of the "Hazardous Areas" per Table 18.4.3.5 (although laboratories are) although they may be required to be separated from adjacent spaces depending on their storage of combustible materials.
Lastly, CMS has a S&C letter (
S&C-1-05-LSC) that outlines the occupancy classifications of hospitals.
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Todd Wyatt AIA
Architect (Code Specialist)
Flad Architects
Madison WI
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Original Message:
Sent: 03-16-2017 18:42
From: Mark Paone
Subject: CMS 2-hour B-Occupancy Separations
Has anyone run across JCAHO, CMS or a local jurisdiction requiring a Pharmacy in an acute care setting to be separated out by 2-hour construction to create a B-Occupancy? OSHPD in California is coming out with a Code Application Notice (CAN) indicating that the 2-hour occupancy separation is not required.
That being said, my client is concerned that JCAHO or CMS will still require it based on NFPA 101. I have looked at NFPA 101 and frankly can read it both ways.
Does anyone have any experience with this issue?
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Mark Paone AIA
Principal
MJPaia, Inc
Orange CA
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