NFPA Journal - May/June 2017 - 52

Perspectives
When the item came before the NFPA membership
three years ago, it was controversial. It was subject
to a very close vote, and ultimately, the Standards
Council determined a consensus had not been
reached and they did not increase the area of the
smoke compartments.
What's the reasoning behind increasing
the area?
The primary reason is that the Facility Guidelines
Institute (FGI), which develops guidelines for
building hospitals and other health care facilities, increased the area required in health care
facilities to perform certain services. Additionally,
more and more health care facilities are going
toward single-patient rooms-the committee was
presented with a study that indicated that about
the same number of patients and services would
be performed in a 40,000-square-foot area using
these new requirements as historically existed in a
22,500-square-foot area. So the change is really to
coordinate with other requirements that hospitals
have to meet where the newer FGI criteria has
been adopted.
Centers for Medicare & Medicaid Services
(CMS) recently adopted the 2012 edition of
NFPA 101. If the area of smoke compartments
is increased in the 2018 edition, what does that
mean for those facilities?
Assuming the proposal for a 40,000-square-foot
limit goes through, the only way those facilities
would be allowed to increase their smoke compartment size would be if CMS were to adopt the 2018
edition or were to adopt this portion of the 2018
edition. Prior to adopting the 2012 edition of the
Life Safety Code, CMS did allow facilities to comply
with portions of the 2012 edition of the code. I have
no idea what CMS is going to decide. They'll review
the document. But there is the opportunity for CMS
to stay with the 2012 edition of the code but issue
a notice that they would allow a categorical waiver
for a 40,000-square-foot smoke compartment that
complies with the 2018 edition criteria.

nfpa.org/
perspectives
READ the second
draft report for the
2018 edition of
NFPA 101.

How many notices of intent to make a motion,
or NITMAMs, have you received overall?
We received 43 NITMAMs. They have to be
reviewed and certified. After that, I'll have a better
feel for what the content of those certified amending motions is. In Boston, a major part of my
presentation will focus solely on those certified
amending motions because part of my intent is to
share with people the perspectives of the various
interested parties to help them prepare for voting
[at the NFPA Technical Meeting] later in the week.

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Is 43 a lot?
It's higher than what we might normally have for
this document. But I think what has happened
is there are some topics where more than one
motion is necessary to accomplish what the submitter is trying to do, and that's why we're seeing
the number that we have. For example, one of the

With the proposed
changes, the committees
are trying to balance the
need for additional security
to address our changing
environment, yet do it in a
manner where we're still
providing a reasonable
level of life safety.

issues deals with integrated testing of life safety
systems. Since this concept is dealt with throughout the code, 22 of the 43 NITMAMs deal with that
one subject. In other cases, I expect that several of
the NITMAMs cannot be certified due to the nature
of the changes that were being suggested.
What do you think the discussion on NFPA 101
at the Conference & Expo will center on?
Integrated testing provisions, door locking provisions for existing educational and day care
occupancies, occupant load factors for business
occupancies and the proposed increase on smoke
compartment size previously mentioned will
occupy most of the floor discussion during the
NFPA Conference & Expo in June when NFPA 101
is voted on.
What issues do you see coming up again as
future editions of NFPA 101 are developed?
I think the work that was done to address
unwanted entry into schools will continue to
evolve in the next edition. The incidents aren't
limited to education facilities. We know there's
been active shooter incidents in health care facilities, office buildings, and factories. We know of
at least two mass casualty events in a business
environment. We know there's been several in an
assembly occupancy-like the movie theater in
Colorado and the nightclub in Orlando. I think
the work that's been done in this cycle will be step
one of some work that's going to be ongoing for
the next cycle as well.

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