NFPA Journal - May/June 2020 - 37

Sprinklers, Burlingame conceded,
weren't going to be a feasible protection measure in every new health care
occupancy the state might have to
create to address the pandemic, such as
field hospitals. In those cases, however,
other fire safety measures were being
explored. "Maybe in the most severe
situations we will have staff doing
fire watches or even have a firefighter
detail issued," he said.
As regulatory exceptions like this
were being implemented across the US,
NFPA released a white paper and a fact
sheet in early April to help facility managers, designers, and AHJs navigate
the situation. Both documents indicate,
for instance, that portions of NFPA
codes and standards can still be used to
enhance safety at health care facilities
without those facilities meeting the
codes in their entirety.
"With the peak of [COVID-19] cases
expected within weeks in some locations, it will be impossible to modify or
construct spaces in strict compliance
with fire and life safety codes," the fact
sheet reads. "In these extraordinary
times, however, we can still look to the
intent of these documents and use portions, such as the equivalency clauses,
goals, and objectives of NFPA 101 or
the risk-based approach of NFPA 99, in
order to guide these difficult decisions."
Guidance came from state and
federal levels as well. On April 5, for
example, the Massachusetts Office of
the State Fire Marshal and Division of
Professional Licensure issued a joint
memorandum outlining considerations
for achieving safety in repurposed and
temporary structures during the coronavirus pandemic. Temporary hospitals
were already being built in the state's
largest cities, Boston and Worcester,
as the number of coronavirus cases in
Massachusetts approached 20,000, the
fifth highest in the country.
"Building inspectors must work
closely with local and state building
and fire officials to expedite proposal
reviews, permitting, and safe occupancy of these tent structures and
temporary uses of existing buildings,"
the memorandum said. It provided
a number of measures these officials
could take to reach an adequate level of

Oxygen control valves at a
temporary COVID-19 hospital
under construction at the
national tennis center, located
in the Borough of Queens in
New York City. GETTY IMAGES

safety in these structures without necessarily being in compliance with local
codes for that occupancy type, such
as keeping tents at least 20 feet apart
from one another, ensuring emergency
vehicle accessibility, and including fire

"IT WILL BE IMPOSSIBLE
TO MODIFY OR CONSTRUCT
SPACES IN STRICT
COMPLIANCE WITH FIRE
AND LIFE SAFETY CODES.
IN THESE EXTRAORDINARY
TIMES, HOWEVER, WE CAN
STILL LOOK TO THE INTENT
OF THESE DOCUMENTS
AND USE PORTIONS."
alarm and carbon monoxide detection
systems-even if it's simply the use of
battery-operated smoke alarms.
In New York City, the US Army Corps
of Engineers, working on behalf of
the Federal Emergency Management
Agency, was brought in to assist with
much of the city's temporary hospital
planning and design. As in Rhode
Island, the use of existing buildings
that already met some level of codes
became key to their efforts.

"When we were first asked to come
in three and a half weeks ago ... they
wanted us to build a hotel," Lt. General
Todd Semonite, chief of engineers and
commanding general of the Corps, told
NPR. "You can't build a hotel in three
weeks. So what we said was let's go
into an existing facility-a large field
house, a convention center, a hotel-
that already has code [compliance for
fire and electrical safety] ... and then
build an ICU-like capability inside." The
Corps took similar approaches to establishing temporary health care facilities
in other large cities like Detroit, Chicago, and Miami, Semonite said.
Not everyone has been eager to jump
on board with relaxing regulations or
pausing the inspection, testing, and
maintenance (ITM) of fire and life
safety systems in health care facilities
in the face of the pandemic. In Little
Rock, Arkansas, fire protection engineer and hospital facility manager
Joshua Brackett had only put one thing
on hold as of April 10-any ITM that
required shutting down air-handling
units in his facilities, part of Baptist
Health, Arkansas's largest health care
system.
"You have to be careful," Bracket said.
"You can't think just because CMS has
suspended survey inspections that you
can relax your own ITM procedures
and that it's right. You still need to do,
at a minimum, the risk assessments
associated with whatever actions you're
contemplating. We have codes in place
for a reason."
N F PA . O R G / J O U R N A L * NFPA JOURNAL

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NFPA Journal - May/June 2020

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