Building and life safety code compliance in healthcare facilities is more than just following regulations — it’s about creating a safe and secure environment for patients, staff, and visitors.

Unlike most buildings, if a life safety emergency event such as a fire should occur in a hospital, it’s not safe or practical to expect patients to exit the building. The majority of hospital patients are incapable of self-preservation, meaning they can’t exit the building on their own. For this reason alone, it’s imperative that fire prevention systems and processes are in place, tested and maintained and that the building is capable of protecting patients, staff and other occupants who will need to remain in the building during a fire event.

The importance of hospitals being able to withstand other emergency events such as earthquakes, floods, hurricanes, tornados, and power outages is also necessary to consider and plan for. These disastrous events typically result in surges of people who need immediate medical care, and it’s critical that hospitals remain functional and structurally intact. The model building and life safety codes we’ll review in this article aim to provide the minimum requirements for maintaining a safe physical environment for the delivery of life-saving, accessible and uninterrupted care during and after emergency events.

Van Wert County Hospital – Emergency Department wayfinding signage Van Wert Hospital Patient Room
Van Wert County Hospital – Emergency Department wayfinding signage Van Wert Hospital Patient Room

Key Building and Life Safety Codes for Healthcare Facilities

In each of the United States, model building codes are adopted by law to establish the minimum requirements for all residential and commercial buildings. Most states have adopted the International Building Code (IBC) with their own specific amendments. The IBC provides regulations that establish minimum standards for the construction, design, and maintenance of buildings to ensure public safety, health, and welfare. It provides a comprehensive set of rules that govern various aspects of construction, including:

  1. Structural Integrity: Ensuring buildings can withstand environmental forces like wind, earthquakes, and snow loads.
  2. Fire Safety: Establishing fire prevention measures, fire-resistant materials, fire exits, and fire suppression systems.
  3. Accessibility: Promoting accessibility for individuals with disabilities by requiring features like ramps, elevators, and accessible restrooms.
  4. Building Systems: Regulating plumbing, electrical, mechanical, and energy systems to ensure efficiency and safety.
  5. Occupancy and Use: Defining how spaces can be used based on their occupancy type (e.g., residential, commercial, industrial) and the number of occupants.
  6. Hazard Mitigation: Addressing risks from natural disasters, hazardous materials, and other potential threats to occupants and first responders.

For hospitals, the IBC provides specific guidelines for designing and maintaining the facility to ensure safety and security for patients incapable of self-preservation. For example, each floor of a hospital must be divided into at least two “smoke compartments” of no more than 22,500 square feet each. Smoke compartments are established and divided with one-hour fire and smoke rated walls that extend full height vertically from the floor to the floor or roof deck above and horizontally from an exterior wall to another exterior wall or one-hour fire barrier wall. This configuration allows patients to be temporarily moved from a smoke compartment experiencing a fire event to an adjacent safe smoke compartment without leaving the building. This “defend-in-place” strategy is the solution recognized by the building and fire codes to address the hazard that fire and emergency events pose to hospital patients.

In addition to the building code adopted by each state, there are two other critical building codes that all hospitals and healthcare facilities receiving Medicare and Medicaid reimbursement must comply with. The Centers for Medicare and Medicaid Services (CMS) is the federal agency that provides health coverage to millions of U.S. citizens through Medicare, Medicaid, the Children’s Health Insurance Program, and the Health Insurance Marketplace. CMS has adopted by federal law the 2012 NFPA 101 Life Safety Code (LSC) and the 2012 NFPA 99 Health Care Facilities Code (HCFC).

NFPA 101 Life Safety Code (LSC)

The LSC focuses on preventing loss of life by reducing the risk of fire and other hazards to occupants. Its requirements include fire protection, evacuation procedures, and maintenance of emergency systems for new and existing structures. Some key provisions of the LSC that affect healthcare facilities include:

  • Focus on people safety over property protection, though property safety is indirectly considered.
  • Applies to both new and existing buildings to ensure ongoing safety.
  • Includes requirements for fire drills, emergency planning, and maintenance of safety systems.
Parkview ER nurses station and hallway
Parkview ER nurses station and hallway

NFPA 99 Health Care Facilities Code (HCFC)

The primary purpose of the HCFC is to provide minimum safety standards for health care facilities to ensure the protection of patients, staff, and visitors from potential hazards. Instead of applying uniform standards based on facility type like other building codes, the HCFC takes a risk-based approach, addressing critical systems that directly impact patient safety and care continuity. The HCFC categorizes systems and components (e.g., electrical, gas, and medical systems) by the level of risk they pose to patient care and safety as follows:

  • Category 1: Facility systems failure could result in major injury or death.
  • Category 2: Facility systems failure could result in minor injury.
  • Category 3: Facility systems failure could result in discomfort.
  • Category 4: Facility systems failure would have no impact on patient care.

The HCFC highlights key provisions for healthcare facility systems and components such as:

  • Electrical Systems: Ensuring reliability during power outages.
  • Medical Gas Systems: Proper storage and maintenance to avoid hazards.
  • HVAC Systems: Infection control and air system integrity.
  • Equipment: Requirements for anesthesia, sterile processing and critical care

The main benefit of the NFPA 99 risk-based approach is that it allows for a more flexible and tailored approach to healthcare facility safety, focusing resources on areas with higher risks while still meeting safety standards. By assessing and categorizing the level of risk associated with various systems and equipment, healthcare organizations can prioritize their efforts and allocate resources efficiently, improving patient safety without overburdening their infrastructure or budgets. This approach ensures that safety measures are proportionate to the potential risks, which can enhance both operational efficiency and patient care quality.

Common Compliance Issues in Healthcare Facilities

Even with strict regulations, some common compliance pitfalls can lead to deficiencies or “K-tag” citations during CMS and Accrediting Organization inspections. The K-tags are based on the requirements of the LSC and HCFC and in some cases both. Here are the most frequently cited systems and components that healthcare facilities should monitor closely:

#1 Sprinkler System – Maintenance and Testing (K353): Improperly inspected or maintained sprinkler systems can quickly lead to citations. Inspections should align with NFPA 25 requirements to ensure compliance.

#2 Electrical Systems, Essential Electrical System Maintenance and Testing (K918): This citation typically occurs because of non-compliance or inadequate maintenance and testing of essential electrical systems and emergency generators within a facility, which is crucial to ensure their proper functioning and reliability in emergencies. Proper upkeep is mandated to prevent system failures that could jeopardize safety and operational integrity.

#3 Hazardous Areas – Enclosures (K321): Citations are issued for non-compliance with regulations regarding the proper installation, maintenance, or inspection of fire rated walls and openings in hazardous rooms and areas, which are critical to prevent ignition sources and ensure safety in environments with flammable gases or vapors. Ensuring these enclosures meet safety standards is essential for reducing the risk of explosions or fires.

#4 Fire Alarm System – Testing & Maintenance (K345): This citation occurs when there is a failure to properly test, maintain, or inspect the fire alarm system as required by regulations, which can result in the system not functioning correctly during an emergency. Regular testing and maintenance are essential to ensure the fire alarm system is reliable and operational to protect lives and property.

#5 Fire Drills (K712): When fire drills are not conducted as required by regulations, or when the drills are not properly documented or carried out with the necessary frequency, this will result in a citation. Regular fire drills are essential for ensuring that staff and occupants are prepared to respond quickly and safely in the event of a fire emergency.

#6 Corridor – Doors (K363): This citation is given when corridor doors do not meet safety requirements, such as proper functionality, accessibility, or fire resistance. These doors are critical for ensuring safe egress during an emergency and preventing the spread of smoke or fire.

#7 Cooking Facilities (K324): Hospitals are cited when cooking facilities fail to meet safety standards, such as proper installation, maintenance, or operation of cooking equipment, ventilation systems, and fire suppression systems. Non-compliance may include issues like inadequate fire safety measures, improper clearance around cooking equipment, or failure to maintain equipment in good working condition. These measures are essential to prevent fire hazards and ensure a safe environment in facilities where cooking activities take place.

Regular observation and oversight of these systems and facility features is essential to avoid unnecessary risks. This will help to ensure that healthcare facilities continue to meet the applicable codes and to maintain compliance and reimbursement from CMS.

Fort Wayne Medical Oncology & Hematology patient chairs Van Wert County Hospital Imaging - Technology St. Rita's Medical Center - Emergency Department Nurse's Station Van Wert Health Surgery and Inpatient Center Surgery Expansion Medium Patient Room
Fort Wayne Medical Oncology & Hematology patient chairs Van Wert County Hospital Imaging - Technology St. Rita's Medical Center - Emergency Department Nurse's Station Van Wert Health Surgery and Inpatient Center Surgery Expansion Medium Patient Room

Strategies for Maintaining Compliance

The best way to address compliance is to stay proactive. Here are some strategies to help your facility stay ahead of potential issues:

  1. Regular Training and Education: Staff training is key to building a culture of compliance. Ensure all employees are familiar with current building codes and safety protocols. This can help prevent issues before they arise.
  2. Preventive Maintenance: Develop and maintain a schedule for critical systems like fire alarms, HVAC, and medical gas infrastructure. Regular inspections and servicing help maintain operational readiness and eliminate vulnerabilities.
  3. Use of Digital Tools: Leveraging digital compliance tools can simplify documentation, help track inspections, and identify gaps in compliance. These systems provide seamless visibility into facility operations and ensure nothing slips through the cracks.
  4. Collaboration with Experts: Work with architects, engineers, and code compliance professionals during design and operational phases. Their expertise ensures seamless code integration and adherence at every step.

By adopting these strategies, healthcare administrators can minimize risks, stay compliant, and create a secure environment for everyone within their facilities.

Building code compliance isn’t just about avoiding penalties — it’s about protecting lives and maintaining the trust of patients and staff. Understanding key codes like NFPA 101 and NFPA 99, preparing for common compliance challenges, and implementing proactive safety measures are the building blocks of a well-managed facility.

By fostering a culture of safety and education, healthcare facilities can go beyond checking boxes; they can ensure lasting compliance and peace of mind for everyone they serve.

Have questions about maintaining compliance in your facility? Reach out to our team of expert healthcare architects and engineers. Let’s work together to build safer, more efficient healthcare environments.

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