Consider height, depth when placing portable fire extinguishers in path of egress
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April 1, 2018
Review the placement of portable fire extinguishers to ensure they meet both requirements from the NFPA and Americans with Disabilities Act (ADA), especially if you are making renovations. CMS, accrediting organizations (AO), and other authorities having jurisdiction (AHJ) will require compliance with the 2010 edition of NFPA 10, “Standard for Portable Fire Extinguishers.”
That standard “provides all the guidance you need, from deciding which extinguisher to use for a given fire type to proper extinguisher use, inspection, and maintenance,” notes Brad Keyes, CHSP, owner and senior consultant for Keyes Life Safety Compliance, in HCPro’s just updated edition of Analyzing the Hospital Life Safety Survey.
But note also that CMS, in adopting the 2012 editions of NFPA 101 Life Safety Code® (LSC) and NFPA 99 Health Care Facilities Code, also is requiring that hospitals abide by the ADA requirement that restricts wall protrusions in the path of egress to 4 inches or less.
That is 2 inches less than the 6-inch protrusions allowed by the LSC. CMS made that exception when it said it was allowing alcohol-based hand rub dispensers (ABHR) in the final rule largely adopting the 2012 editions, but also said it expected health care facilities to abide by ADA requirements.
Protrusions limit aids sight-restricted
The restriction on wall protrusions is aimed to help those who are blind or have low vision to navigate hallways without coming up against objects that are too high to be detected by a cane, ADA experts have said. The ADA has the same 4-inch standard for any object that extends out of a wall and is higher than 27 inches from the floor and below 80 inches.
But there are also height restrictions on accessibility of operable parts, such as a light switch or a fire extinguisher cabinet. So while a fire cabinet may be recessed into a wall and meet the protrusion requirements, it may not meet the ADA’s height requirements.
The operable area of the fire extinguisher cabinet must be at a minimum height of 15 inches and maximum height of 48 inches, and there must be enough clearance for someone in a wheelchair or otherwise disabled to reach the cabinet’s operable parts — the door handle in this case — from a forward or side approach, says Dave Yanchulis, a spokesman for the U.S. Access Board.
The Access Board is an independent federal agency that “promotes equality for people with disabilities through leadership in accessible design and the development of accessibility guidelines and standards.” The board’s website also has a comprehensive guide to the ADA requirements, including illustrations.
ADA can impact renovations
With all those requirements, there are a couple of caveats, notes Yanchulis. The ADA standards apply only to new construction or alterations to buildings since the standards were adopted in the early 1990s. Also, there is an exception to the protrusion requirement for objects that can be removed, and so may not apply to portable fire extinguishers not enclosed by a cabinet, depending on how it is affixed to the wall. However, there is no exception to the operable parts requirements, meaning the extinguisher would still have to be at a height to be accessible to someone with a disability.
The placement of portable fire extinguishers may prove tricky, depending on how CMS requires AOs to enforce the ADA pronouncement, notes Keyes.
So far, more than a year into implementation of those updated fire codes, it does not appear state agencies surveying on behalf of CMS and or other AOs are enforcing the ADA height requirements, notes Keyes. What is being enforced is the height provision of NFPA 10-2010, 18.104.22.168.3, which requires the extinguisher to be mounted at least 4 inches above the floor and no more than 60 inches above the floor, he says.
Some wall mounts problematic
“CMS is also enforcing the ADA requirement whereby no corridor projections extend more than 4 inches into the corridor,” warns Keyes. “This applies in all certified healthcare facilities, not just hospitals. But it does not apply to projections in suites and rooms, because there are no corridors in suites or rooms.”
He notes that healthcare facilities often mount extinguishers on the wall, “and for the most part they do not meet the 4-inch maximum projections into the corridor rule.”
There is at least one company, Oval Brand Fire Products, that offers an oval-shaped extinguisher that does not protrude more than 4 inches, notes Keyes, “so there is some relief.” Several other companies offer fire extinguisher cabinets that meet ADA requirements.
When considering the placement of fire extinguishers, consider also the weight. Height of a fire extinguisher placement is “is limited to no more than 5 feet from the floor for an extinguisher not weighing more than 40 pounds, per NFPA 10,” says Ernest E. Allen, a patient safety account executive with The Doctors Company in Columbus, Ohio.
Note these restrictions
Here are other restrictions on portable fire extinguishers, in an excerpt from HCPro’s Analyzing the Hospital Life Safety Survey, by Keyes:
“All portable fire extinguishers, other than wheeled extinguishers, must be mounted on a hanger or bracket, or placed in a fire extinguisher cabinet. Extinguishers must be mounted in such a way that they are not damaged by other objects striking or dislodging them.
“For extinguishers that weigh no more than 40 pounds, the top of the extinguisher cannot be more than 60 inches above the floor. For extinguishers that weigh more than 40 pounds, the top of the extinguisher cannot be more than 42 inches above the floor.
“The bottom of any extinguisher cannot be less than 4 inches from the floor, meaning extinguishers are not allowed to sit on the floor. Fire extinguishers must be conspicuously located where they are readily accessible and immediately available in the event of fire.
“Fire extinguishers are required to be mounted along normal paths of travel, including exits from areas. In large rooms and certain locations where visual obstructions cannot be completely avoided, means shall be provided to indicate the extinguisher location.
“In previous editions of NFPA 10, there used to be a requirement to mark all extinguisher cabinets in some fashion. The 2010 edition changed that, and marking extinguisher cabinets is only required when the cabinet itself is obscured or cannot be seen.”