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Answers on areas of refuge, natural gas generators and receptacles


September 1, 2019

By Brad Keyes, CHSP (www.keyeslifesafety.com)

Area of refuge in a hospital

Q: We ask staff this question when we do environmental rounding: "Can you identify the closest area of refuge?" The answer we have used is "shelter in place," but I believe this may be misleading. Can you please provide a more accurate answer?

A: According to section 3.3.22 of the 2012 Life Safety Code® (LSC), an area of refuge is one of the following two things:

  • An area that is a story in a building where the building is protected throughout by an approved, supervised automatic sprinkler system and has at least two accessible rooms or spaces separated from each other by smoke-resistant partitions (i.e., corridor walls)
  • A space located in the path of travel leading to a public way that is protected from the effects of a fire, either by means of separation from other spaces in the same building or by virtue of location, thereby permitting a delay in egress travel from any level

In the past, most hospitals have relied on item #1 above to meet the area of refuge requirement. Rooms and spaces could be found on most stories of hospitals that were separated from each other by corridor walls. Each smoke compartment could easily qualify as an area of refuge simply by having two accessible rooms separated by corridor walls. There has been no requirement by any of the accreditation organizations (AO) to mark the life safety drawings with the areas of refuge.

But many hospitals are not fully protected with sprinklers, so they automatically do not qualify for option #1.
In healthcare occupancies, section requires compliance with section 7.2.12 for areas of refuge used as part of a required accessible means of egress. That means if a hospital cannot meet the requirements for item #1 above (accessible rooms separated by corridors in a fully sprinklered building), then it has to comply with the more rigid section 7.2.12, which has the following requirements:

  • Each elevator landing must be provided with a two-way communication system for communication with the fire command center or a central control point approved by the authority having jurisdiction (AHJ)
  • Directions on use of the two-way communication system, instructions for summoning help, and written identification of the location must be posted
  • Audible and visual signals must be included in the two-way communication system
  • Accessibility requirements regarding exits and elevator access
  • Illuminated signs identifying area of refuge
  • Two-way communication system at the area of refuge

The problem is, this does not seem to fit the mold of healthcare occupancy, where there is adequate staff to attend to the needs of the patients. Most patients cannot egress on their own, let alone travel to the area of refuge.

I don’t recall ever seeing a finding from an accreditation survey or a CMS state agency survey involving the area of refuge in a healthcare occupancy. In a business occupancy? Yes, but that is an entirely different animal because the expectation is the occupants can egress themselves and there may not be anyone around to assist them.

Personally, I would suggest you stop using the words “area of refuge” in your rounding, and just encourage your staff to egress into the adjoining smoke compartment.  

Natural gas generators

Q: In looking over NFPA 110, edition 2010, it does not make any distinction to the emergency generator prime mover being anything but diesel powered. Because the equipment section in the Definitions identifies any equipment used in connection with the supply of emergency power is in fact part of the emergency power system (EPS), we have a natural gas-powered EPS. Is it required to perform in the same manner as diesel-powered equipment and be tested and maintained in the same fashion per NFPA 110?

A: No. I believe section of NFPA 110-2010 is the answer you’re looking for. It mentions spark-ignition generators are to be tested monthly with available load for 30 minutes or until the water temperatures become normal and the oil pressures stabilize. You are correct, though, in saying there are other sections of NFPA 110-2010 that specifically reference diesel-powered generators.

For your circumstances, you may ignore those sections that are specific to diesel-powered generators, but all other sections would apply. This means you are exempt from having to do annual load bank tests if you do not meet the 30% rule, but you are required to conduct the three-year, four-hour load test.

Electrical receptacle testing

Q: What is the regulation for testing the retention force on electrical outlets?

A: According to section of NFPA 99-2012, the retention force of the grounding blade of each receptacle shall be not less than 115 g (4 oz). Other annual testing requirements that must be included are:

  • The physical integrity must be confirmed by a visual inspection
  • Verification must be made of the continuity of the grounding circuit
  • The correct polarity of the hot and neutral connections of each receptacle must be confirmed

However, the above annual testing requirements only apply to receptacles not listed as hospital grade that are in patient bed locations and in locations where deep sedation or general anesthesia is administered.
If you have hospital-grade receptacles at those locations, you would have to do an initial test after the receptacle is installed, and then additional testing at intervals defined by documented performance data. This means the hospital-grade receptacles in bed locations and in deep sedation or general anesthesia areas must be tested at intervals defined by historical information.

So, if these receptacles show no deficiencies after a few years of annual tests, then this data may be considered sufficient reason to extend the tests to once every two or once every three years. Retain this data to show surveyors your decision process. 

Editor’s note: Each month, Brad Keyes, CHSP, owner of Keyes Life Safety Compliance, answers your questions about life safety compliance. Follow Keyes’ blog on life safety at www.keyeslifesafety.com for up-to-date information.  


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