NFPA Journal - January/February 2018 - 38

In Compliance
are often bundled in a manner similar
to other communications cables, and
as more power is introduced on these
cables, heat dissipation can become
an issue. The 2017 NEC includes limitations on how much power PoE
cables can carry before they need to be
treated as Class 2 or 3 circuits. Article
840 contains a new section in Part
VI that requires section 725.144 to be
followed when the power supplied to
equipment on communications cable
exceeds 60W. This requires that PoE
cables follow Parts I and III of Article
725 and that they are installed in the
same manner as any other Class 2 or
3 circuit. Power above 60W also calls
for adherence to the requirements of
300.11 or the general NEC requirement
for ensuring that cables and raceways
are secured in place and properly supported, potentially limiting PoE cable
over 60W from being installed in large
bundles where proper heat dissipation
can be an issue.
The Fire Protection Research Foundation has also joined the discussion
and has assembled a team that will
work to find answers and make recommendations on how to appropriately
regulate this growing industry. Rules
and regulations should effectively
minimize the hazards but also need
to allow innovation to drive us into
the future. Answering questions about
electrical shock hazards, fire ignition
issues, flame spread characteristics,
what the addition to a building's fuel
load might look like, and what products of combustion might be added
will help us effectively protect the
world from potential hazards, and be
done in a way that allows this technology to grow.
Who knows-maybe someday soon
PoE will make possible my dream of
a refrigerator that learns my cooking
habits and automates my grocery
buying so I never have to come up with
a list or brave another grocery store
line an hour before the big game. Hey,
a guy can hope.
Derek Vigstol is an NFPA technical lead, Electrical
Tech Services. NFPA members and AHJs can use the
Technical Questions tab to post queries on NFPA 70
at nfpa.org/70.

38 | NFPA JOURNAL * J A N U A R Y / F E B R U A R Y 2 0 1 8

NFPA 101

Life safety in new
and existing structures

NFPA 101, NFPA 101A,
and sprinkler requirements
for nursing homes
By Ron Coté

t has been more than 18
months since the Centers for Medicare and
Medicaid Services (CMS)
moved from enforcing
the provisions of the 2000 edition
NFPA 101®, Life Safety Code®, to the
2012 edition as a condition for participation in the Medicare and Medicaid
programs for health care occupancies.
Even so, health care providers continue
to recognize and evaluate the nuanced
effects imposed on their facilities by the
2012 edition of the code.
Currently, some nursing home operators are facing a dilemma related to
continued code compliance. Previously,
nursing homes were made compliant
with the 2000 edition of NFPA 101 via
an equivalency prepared using the
health care occupancies Fire Safety
Evaluation System (FSES) of NFPA
101A, Guide on Alternative Approaches
to Life Safety. The equivalency balanced
the presence of a nonrequired sprinkler
system against a noncompliant building construction type. For the most
part, the move to compliance with the
2012 edition of NFPA 101 has permitted
additional functional needs associated
with providing medical services, like
those intended to make a nursing
homes less institutional and more
homelike, to be met without conflicting
with code requirements. For example,
fixed furniture is now permitted within
egress corridors.
The problem has to do with sprinklers. The 2006 edition of NFPA 101
was the first to retroactively require
sprinklers in existing nursing homes,
and that requirement continues to
apply today in the form of the 2012

I

edition enforced by CMS. The NFPA
101A revision cycle lags that of NFPA
101 by one full year, however, to permit
the technical committee to know the
code text so it can calibrate the guide's
equivalency measurement systems.
Whereas the 2001 edition of NFPA
101A measures equivalency against
the requirements of the 2000 edition
of NFPA 101, it is the 2013 edition of
NFPA 101A that measures equivalency
against the requirements of the 2012
NFPA 101. Given that sprinkler systems
are required by the 2012 NFPA 101
for existing nursing homes, the FSES
of the 2013 NFPA 101A recognizes a
sprinkler system as something that is
necessary, is not a voluntarily provided
feature, and is not something that can
be traded off against a code deficiency.
In cases where a sprinklered existing
nursing home with a noncompliant
construction type achieved equivalency
with the requirements of the 2000
NFPA 101 by using the 2001 NFPA
101A, that same building today has two
problems: it is noncompliant with the
building construction requirements of
Chapter 19 of the 2012 NFPA 101 for
existing health care occupancies, and
it fails the equivalency analysis performed using the 2013 NFPA 101A.
The technical committee responsible
for NFPA 101A has completed its work
to produce the first- and second-draft
reports as part of the annual 2018 revision cycle that will produce the 2019
NFPA 101A. The committee was unable
to achieve consensus on changes to
the health care occupancies FSES to
permit a sprinklered existing nursing
home-one that was compliant via the
equivalency analysis using the 2001
NFPA 101A-to remain compliant via the
2019 NFPA 101A. To do so would stray
from the fundamental premise that
NFPA 101A must measure equivalency
against the requirements of a specific
edition of NFPA 101. In other words,
NFPA 101A is not the place to implement
leniencies that are not technically based.
Moving forward, existing nursing
home operators can request the authority having jurisdiction (AHJ) to modify
requirements of the 2012 NFPA 101 as
permitted by the duties it assigns to
http://www.nfpa.org/70
Table of Contents for the Digital Edition of NFPA Journal - January/February 2018
