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The Academy of Architecture for Health (AAH) provides knowledge which supports the design of healthy environments by creating education and networking opportunities for members of – and those touched by – the healthcare architectural profession.

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CMS 2-hour B-Occupancy Separations

  • 1.  CMS 2-hour B-Occupancy Separations

    Posted 03-16-2017 18:42
    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?

    Mark Paone AIA
    MJPaia, Inc
    Orange CA

  • 2.  RE: CMS 2-hour B-Occupancy Separations

    Posted 03-20-2017 09:59
    Per (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  Section 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 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 (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.

    Todd Wyatt AIA
    Architect (Code Specialist)
    Flad Architects
    Madison WI

  • 3.  RE: CMS 2-hour B-Occupancy Separations

    Posted 03-21-2017 17:49

    Good information. I would agree with the last post. I would also note however that in my experience we have often gone to Occupancy Separation and B Occ for a Pharmacy, particularly larger facilities, and thus have greater flexibility with layout and flow than in an I-2 condition which has much greater restrictions on travel distance, suite requirements, and egress through multiple rooms, etc. It's a trade off with respect to a 2-HR perimeter, but mostly a matter of what is the best fit project to project.


    I've not seen JCAHO or CMS dictate 2-HR separation at for simple Pharmacy sake.


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  • 4.  RE: CMS 2-hour B-Occupancy Separations

    Posted 03-22-2017 20:25
    Typically, the code allows for tertiary occupancy less than 10% to remain with the primary occupancy without separations. If your occupancy fits this criteria you may be exempt.
    In the advent of new Board of Pharmacy requirements for hazardous material compounding and separation of ISO atmospheres, we have to be careful of horizontal exits through adjoining spaces.
    Because of these new requirements California is looking at an interpretive modification of the exiting specific to pharmacies. This has not been published as yet.

    Brad Henderson AIA
    JLL/San Joaquin Community Hospital

    Brad Henderson AIA, CDS
    Project Manager
    Jones Lang-LaSalle
    Bakersfield CA

  • 5.  RE: CMS 2-hour B-Occupancy Separations

    Posted 03-21-2017 18:11

    The occupancy of the space must be well described within the facility.

    Is it a Pharmacy, where the general public at large could queue, shop and purchase medications or other products?

    Is the Pharmacy an area or space where persons using are capable of self-preservation in emergency conditions?

    Are any medical treatments or examinations being conducted in the space?

    Would the space, on its own merit, require OSHPD or state licensing to operate?

    If so, it may likely be a B Occupancy – even under JACHO and CMS.


    Or, is the space or area one of the many types of medication handling spaces within the hospital (including pharmacies) primarily used by staff and clinicians for and in spaces providing patient care (i.e.: ICU)? 


    In the case of retail pharmacies, the OSHPD CAN will most likely also require minimum fire protections to assurance containment without exception as a part of the hospital function and design.


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