Culture Change Comes to the Life Safety Code:
Residential Kitchens
John Rickard, AIA, PE
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 last summer, 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 second of a series of four articles addressing the proposals.
In a person-centered care setting, residents are encouraged to get out of their rooms and socialize. In the home, a key area where socialization occurs is the kitchen. The kitchen is a place where nursing residents would be able to participate in activities they've been doing for most of their lives while visiting with other residents. At the same time, cooking odors can be a powerful stimulant for memories, helping aging residents stay connected to and engaged in their environment. This can result in a significantly higher quality of life.
The Life Safety Code, however, considers kitchens in nursing homes to be hazardous areas. Although they are not required to be enclosed in fire-rated construction, they are required to be separated from corridors by walls and doors. Nevertheless, there is little fire safety data to suggest that kitchens are particularly hazardous, primarily because they have such effective fire suppression systems.
The Pioneer Network submitted a proposal for the 2012 edition of the Life Safety Code that would allow kitchens to be open to corridors 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 the following provisions:
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Kitchens open to the corridor may be used to prepare meals for no more than 30 persons (this is the number of persons for whom meals are routinely prepared and does not include staff and feeding assistants)
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The smoke compartment in which the kitchen is located must contain no more than 30 beds
- The hood over the cooktop must be at least as wide as the cooktop, exhaust at least 500 cfm, and have a charcoal filter if the hood recirculates the air (rather than exhausting it to the exterior)
- Deep fat frying and cooking with solid fuel (i.e., wood-burning stoves) are prohibited
- The cooktop must have a fire suppression system that complies with UL 300 or UL 300A, together with a manual release and an interlock that turns off all fuel or electrical power to the cooktop or range when the system is activated
- There must be a switch for staff use (one that is locked or in a locked location in the kitchen) that will shut off the cooktop or range and which is on a timer (120 minutes maximum) to shut off the cooktop or range when unattended
- Two smoke detectors that are not connected to the fire alarm system (providing local notification only) must serve the kitchen and be located not closer than 20 feet from the cooktop or range (to prevent nuisance alarms and calling the fire department every time someone burns a piece of toast)
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.