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Life Safety  Codes   Impacts & Solutions for Assisted Living  

 

Dan Purgiel - LRS Architects

Good News


Good News   Until recently, assisted living & building codes were like trying to eat soup with a fork…. Now we finally have a spoon to eat the soup!

Outline


Outline of  Presenta7on   1.  2.  3.  4.  5.  6. 

Code Issues Code Solutions Statewide Agency Approach Individual Project Approach Project Examples Design Examples How It  Affects  You  /  Background  


Background All of what you will hear is my opinion •  Local authority opinions will differ and vary •  Helped in states of HA, GA, OR, PA, VA deal with AL issues at non project State level and LRS has designed in about half the states •  Currently working for and with ALFA to create better and more consistent regulation Issue  Statement  


Finding Assisted Living Resident Type   State of Hawaii conducted national analysis of assisted living (AL) resident type in 2007 relative to life safety/ capability: •  Found that 59 of 89 categories serving 16 or more residents require assistance with evacuation •  Every state had at least one category of assisted living that would be considered as having residents that need assistance with evacuation

Building Code  Versus  Resident  Type


Part 1  -­‐  Issue  Statement   Licensing Regulations vs. Building Codes   So all State licensing allows persons needing assistance with evacuation   International Building Code (IBC) did not allow assistance with evacuation in AL unless in Nursing   Issue is that nursing occupancy has additional limits that may not be applicable to assisted living

Part 2  –  SoluFons  &  Issues


Parts 1  &  2  Solu7ons  &  Issues   2015 IBC is revised:

  Five year effort/ 2 code cycles / denied in 2009 cycle   Dan Purgiel, ALFA, key committee member for 2012 cycle •  1000 total proposals for all building/ types 1/3 approved •  Assisted living proposal is the “G31-12”

  G31-12 is about the largest approved change •  On International Code Council (ICC) website •  Under codes/ development/ current cycle/ proposed changes 3/12/12 2015 IBC  


Na7onal Solu7ons   2015 IBC   Code change G31-12 allows persons needing assistance with evacuation in assisted living (Group I-1(>16) and R-4(6-16)   Requires additional protection features •  3 story wood frame limits, smoke barriers, NFPA 13 sprinklers in over 16 person facilities •  NFPA 13R in 6-16 person facilities & attic smoke detection SFll  Have  NaFonal  Issues  


IBC Issues   IBC only deals with new construction   Existing buildings still face issues

2015 IBC will not be implemented in many states until 2015 -2018   Industry still faces issues in states until adoption   So far GA? NY?, OR, VA? May adopt the changes early within the next year Recommended OpFons  


IBC Issues   About half the states adopt a statewide building code   Half don’t though

Only some allow amendments that would be required for early implementation   ALFA will strategize options in these states

State Building  Code  OpFons  


State Building  Code  Op7ons   States that may allow state amendments for early adoption of the G31-12 WA OR

VT MN WI

NY

MI OH IN?

CA AR?

PA? CT VA NC SC

GA LA? FL

NFPA 101  SoluFons  

MA ?


NFPA 101  Solu7ons   NFPA 101 is also used by some State fire marshals and state licensing   2015 IBC and recent editions of NFPA 101 match in most requirements for NEW construction (purposely)

NFPA 101  New  Buildings  


NFPA 101  Solu7ons   NFPA 101 different than IBC   Stories for new construction do not match IBC: •  IBC I-1 allows 3 stories wood frame •  NFPA RB&C Large - allows 2 stories wood frame •  So Projects in states like NV, CO to comply with most stringent requirements

NFPA 101  New  Buildings  


NFPA 101  Solu7ons   NFPA 101 New Construction   NFPA 101 also allows corridor protection exceptions •  Less ratings and no closers

  2015 IBC requires relatively full corridor protection   Otherwise 2015 and 2003 and later editions of NFPA 101 are about a 95% match for NEW construction

NFPA 101  ExisFng  Buildings  


NFPA 101  Exis7ng  Buildings   NFPA 101 Existing Construction Chapter   Allows flexibility for existing buildings in exchange for requiring timing residents during evacuation drills   Allows 3 & 4 story wood frame   Allows NFPA 13R sprinklers in large buildings   Less stringent in other minor areas

NFPA 101 2003 and later editions are a great option for dealing with existing buildings Part 3  -­‐  Statewide  Approach  


Part 3  -­‐  Statewide  Approach   Coordinate and correlate   Assumption is at least one state licensing category of assisted living allows persons who may need assistance with evacuation during emergencies.   Resident type then causes other agencies (fire marshal and building code) to have more say and regulate more.

Three Statewide  Agency  Approach  


Statewide Approach   Integrated Approach = Best Approach   Requires cooperation and correlation between different state agencies and industry: •  State licensing agency •  State building code agency (in about half the states) •  State fire marshal office •  Working with industry and associations

Statewide CoordinaFon  


Statewide Approach   Coordinate and correlate   State regulation, rule making and statutes with   Licensing requirements with   State Fire marshal and state building code with   Resident type allowed with   Building physical plant life safety requirements

Every State is different

Limited Number  of  States  


Statewide Approach   Cannot be pursued in many states   5-10 states are fully coordinated   Over half of states don’t have statewide building code   Over half of states don’t have licensing or SFM life safety   Both lists don’t correlate   Once 2015 IBC adopted many problems go away for new construction

Stepped Statewide  Strategy  


Statewide Approach   Develop stepped strategy for coordination   Contact State agencies and determine how and to what extent statewide coordination is allowed   Work with ALFA and soon to be published ALFA White Paper on how to accomplish   Work with the three State agencies to determine path to coordination

Implement


Statewide Approach   Implement 2015 IBC (G31-12) for new construction Implement NFPA 101 Existing RB&C for existing construction Coordinate Licensing regulation with codes   Coordinate with State licensing, state fire marshal and building code division Takes  Commitment  


Statewide Approach   State strategy takes commitment   Must be committed at local ALFA or other association level (GA example)   May take one to three years   Can be accomplished with perseverance •  Licensing regulations are as varied as numbered of states •  May have to break down old stereotype assumptions with any of the three agencies •  It’s asking the government to change

Part 4  -­‐  Individual  Project  Approach  


Part 4  -­‐  Individual  Project  Approach   Pursue if no State Strategy Use if have persons needing assistance with evacuation Alternate Means   Provide equivalency for building code compliance

Inefficient


Individual Project  Approach   This approach is inefficient   Individual project negotiation has mixed results : •  Future % should be higher with approval of 2105 IBC G31-12

  Currently only way to achieve equivalent non nursing home I-2 compliance in most states

  Solutions may be complicated   Hire architect with this experience Use Alternate  Means  


Individual Project  Approach   Alternative Means Stepped approach   Determine state requirements, costs, and chance of approval   Then determine if to proceed only if local building department, fire marshal are open to idea

Alternate Means  Guide  Info  


Individual Project  Approach   IBC Alternative Means Guide   Request allowing persons needing assistance with evacuation in Group I-1 or R-4.   Note on the permit drawings •  Facility limited to be assisted living under state statutory language: Quote statutory language •  Residents will not be “bedridden” meaning they will be able to get out of bed with assistance in emergencies

Alternate Means  Language  


Individual Project  Approach   IBC Alternative Means Guide   Cite and substantiate State or national use of another national standard (2015 IBC and NFPA 101 – 2003 or later edition):   Cite CA, HA, NY, OR, WA as other states that have amended the IBC in similar means as the proposed

Alternate Means  Language  


Individual Project  Approach   IBC Alternative Means Guide   Cite the differences between occupant types in Nursing and AL as noted in upcoming ALFA White Paper   Briefly cite why AL should not be designated as I-2 as noted in future ALFA white paper

Alternate Means  Language  


Individual Project  Approach   IBC Alternative Means Guide   Cite other means how the specific building exceeds IBC prescriptive requirements, for example: •  Number of exits •  Separation of exits •  Shorter travel distances •  Smaller smoke compartments •  Horizontal exits combined with smoke barriers Part  5  -­‐  Example  Projects  


Part 5  –  Examples:  Colorado  New  60  AL   New construction project   60 resident assisted living (AL)   Want to allow residents who may need evacuation assistance   Want to build 2 stories wood

LRS

Colorado –  Licensing  /  NFPA  


Colorado New  60  AL  Example   Licensing allows assistance with evac. Licensing requires 2006 NFPA 101   Full NFPA 13 sprinklers (attic)   2 story wood   Smoke barriers

Colorado –  Building  Code  


Colorado New  60  AL  Example   State Bldg. Code uses 2009 IBC   I-1 doesn’t allow residents with evacuation assistance   Local plan review prefers I-2 (nursing) •  1 story wood •  smoke barriers •  NFPA 13 sprinklers

LRS

Colorado –  Alternate  Means  


Colorado New  60  AL  Example   Propose alternate means 2015 IBC   New G-31-12 I-1 allow residents with evacuation assistance: •  3 story wood (NFPA 101 – Sate licensing only allows 2) •  smoke barriers •  NFPA 13 sprinklers

  Cite both IBC and NFPA (CO licensing) through alternate means process: Wisconsin -­‐  Example  


Wisconsin AL  Addi7on  Example   Addition onto existing building   Add 30 resident assisted living (AL)   Want to allow residents who may need evacuation assistance   Want to build 2 stories wood

LRS

Wisconsin -­‐  Licensing  


Wisconsin AL  Addi7on  Example   Licensing allows assistance with evac. Licensing (CBRF) requires own life safety   I-2 one story wood if need mobility assistance devices or if in “confused” category   I-1 if mobile category (without devices) and not in “confused” memory care category but “alert”

LRS

Wisconsin -­‐  Example  


Wisconsin AL  Addi7on  Example   Local Bldg. Dept. requires 2009 IBC   I-1 doesn’t allow residents with any evacuation assistance   Plan review prefers I-2 (nursing) •  1 story wood •  smoke barriers •  NFPA 13 sprinklers

LRS

Wisconsin -­‐  Example  


Wisconsin AL  Addi7on  Example   Propose alternate means 2015 IBC   New G-31-12 I-1 allow residents with evacuation assistance: •  3 story wood (Proposing only 2 stories) •  smoke barriers •  NFPA 13 sprinklers

  Cite both IBC and NFPA (Co. licensing) through alternate means process: Oklahoma –  Example  


Oklahoma MC  Conversion  Example   Conversion of existing building wing   Converts 32 resident assisted living (AL) to memory care   Want to allow residents who may need evacuation assistance   In existing 1 story wood frame building

LRS

Oklahoma –  Licensing  /  Home  Rule  


Oklahoma MC  Conversion  Example   Licensing allows assistance with evac Home rule state – local fire and building officials enforce their own regulation Existing building:  No smoke barriers  NFPA 13R sprinklers (No attic coverage)

Oklahoma -­‐  Example  


Oklahoma MC  Conversion  Example Building official & fire marshal want 2009 IBC I-2 requiring   NFPA 13 sprinklers (cannot convert NFPA 13R to 13 easily)   1 story wood (OK)   smoke barriers (OK to add)   Some Metal Conduit (tough to convert) LRS

Oklahoma -­‐  Example  


Oklahoma MC  Conversion  Example Propose similar alternate means NFPA 101 for existing buildings   Newer NFPA 101 allow residents with evacuation assistance: •  3 story wood (Only need 1 story OK) •  smoke barriers ($10,000 to add 1) •  NFPA 13R sprinklers (OK already have)

•  Local officials want NFPA 13 – •  So show attic detection & partition, shorter travel, and additional first story exits allows for quicker emergency evacuation

Oklahoma -­‐  Example  


Oklahoma MC  Conversion  Example Also cite parallels to 2015 IBC New IBC G-31-12 I-1 allow residents with evacuation assistance:  NFPA 101 existing buildings enhanced)  NFPA 13 sprinklers (propose using  3 story wood  smoke barriers LRS

Oklahoma -­‐  Example  


Oklahoma MC  Conversion  Example Sprinkler system enhancement to gain alternate means   Add attic smoke detection ($5,000)   Add attic smoke partition ($10,000)

LRS

California -­‐  Example  


California MC  Conversion  Example   Conversion of existing building wing   Converts 2 story 48 resident assisted living (AL) to 36 memory care   Want to allow residents who may need evacuation assistance   In existing 2 story wood frame building

LRS

California –  Coordinated  State  


California MC  Conversion  Example   Licensing allows assistance with evac State & local fire and building officials enforce the CBC   CBC allows right resident type, NFPA 13, smoke barriers, and two story wood frame

Existing building:  Built in 1990’s has all current life safety features

Easy- Complies: Part 6  -­‐  Design  Examples  


Part 6  -­‐  Design  Examples-­‐Memory  Care

Memory Care  Design  


Design Example  -­‐  Memory  Care

Memory Care  Design  


New Design  Example  -­‐  Memory  Care

Assisted Living  Design  


Design Example  –  Assisted  Living

Nursing Household  Design  


Design Example  –  Household  Nursing

Independent Living  Design  


Design Example  –  Independent

Independent Living  Design  


Design Example  –  Independent

End


End

Questions? Daniel Purgiel LRS Architects Inc. Portland OR 503-221-1121 dpurgiel@lrsarchitects.com

Thank You  

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