Culture Change in the Code: Fireplaces

Culture Change Comes to the Life Safety Code:

Several years ago, Pioneer Network led an effort to identify code requirements that hinder the ability of nursing and assisted living facilities to implement culture change (person-centered and person-directed care) in their facilities. This effort was particularly timely, as the Centers for Medicare and Medicaid Services (CMS) has indicated they hope to move from the 2000 edition to the 2012 edition of the Life Safety Code next year. CMS has advocated for culture change for some time and, at a conference in July, 2010, strongly encouraged the National Fire Protection Association (NFPA) to remove impediments to culture change in the codes. As a result of the combined efforts of SAGE, Pioneer Network, AAHSA, AHCA, and others, four areas were identified and proposals submitted to change NFPA 101 Life Safety Code, one of the key codes mandated by CMS. The four areas identified relate to seating in corridors, residential kitchens, fireplaces, and flammable artwork. Following is the third in a series of four articles addressing the proposals.

Fireplaces are emblematic of home for many people. There are few quicker ways of creating a home-like environment than providing a furniture grouping of sofa and chairs in front of a fireplace, and a real fire is part and parcel of the "I'm at home” atmosphere. Because nursing homes are so much larger in scale than one's home, intimate settings such as an arrangement around a fireplace are particularly important to efforts to create a home-like environment for aging residents and thereby improving their quality of life.

The Life Safety Code, however, places several critical restrictions on the use of fireplaces. All fireplaces, regardless of type, must be separated from sleeping areas by one-hour rated construction. A living room that is open to the corridor, as most are, and which contains a fireplace would have to be in a separate smoke compartment from sleeping rooms. A home-like environment with sleeping rooms arranged around a living/dining/kitchen area with a fireplace to remind one of home – a central design concept of culture change – would be impossible under this code restriction.

The Pioneer Network submitted a proposal for the 2012 edition of the Life Safety Code that would allow fireplaces in areas near sleeping rooms in both new and existing nursing homes, provided that several restrictions are observed. This proposal was initially rejected by the NFPA Technical Committee on Health Care Occupancies that reviewed it, but a year later the committee voted to approve a modified version of the proposal. The final language includes several provisions specific to direct vent gas fireplaces:

• They must comply with the National Fuel Gas Code (we code aficionados know it as NFPA 54), including taking combustion from outside, not the building interior
• The gas fireplaces are allowed in smoke compartments that contain sleeping rooms but not in the sleeping rooms themselves
• The entire smoke compartment must be protected with a fire sprinkler system that has quick response sprinkler heads (which is required for new nursing home construction already)
• The fireplace must have a sealed glass front with a wire mesh panel or screen to prevent one from touching the hot glass surface
• The room containing the fireplace must have a carbon monoxide detector that is tied to the fire alarm system
• The controls of the gas fireplace must be locked or located in a restricted location, such as at the nurse station.

Solid fueling burning fireplaces (such as wood burning fireplaces) are also allowed, but with all of the restrictions that formerly applied to every type of fireplace, including the requirement for one-hour separation from sleeping areas. In addition, a carbon monoxide detector tied to the fire alarm system is now required.

The code language approved by the NFPA Technical Committee went before the general membership at the annual NFPA Technical Session in June, 2011 and was approved for inclusion in the 2012 edition of NFPA 101 Life Safety Code. This code change will not go into effect in new and existing nursing homes until CMS moves to adopt this latest edition. If CMS does move forward, the adoption process will likely take a year or more. There is also the possibility that CMS may move more quickly and adopt only the four culture change provisions that were approved, with adoption possibly occurring as soon as this Fall. Hopefully, another tool for implementing culture change is close at hand.

John Rickard, AIA, PE is a licensed architect and engineer in the State of Texas and a member of the NFPA 101 Technical Committees on Health Care Occupancies and Board and Care Facilities.