Fire and Life Safety Considerations for Converting Offices to Surgery Centers

In this latest edition of our ongoing series on converting former office spaces to ambulatory surgical centers (ASCs), we explore some fire and life safety related considerations that may impact design and construction. For reference, we will be utilizing the 2021 International Building Code (IBC) and the 2012 NFPA (National Fire Protection Association) 101, Life Safety Code (LSC), as required for facilities receiving reimbursements from the Centers for Medicaid & Medicare Services (CMS). Construction Type and ASC Location While there are many infrastructure considerations for locating an ASC within an existing building, the primary driver from the fire and life safety aspect is reviewing the existing building’s construction type, height, area and occupancy to determine if an ASC can be located within. It is fairly common for existing office buildings to have unprotected construction type (meaning no floor or structure carrying a fire rating), such as Type II-B under the International Building Code (IBC) or Type II (000) under NFPA codes and standards. If the existing building is Type II-B and also does not have sprinkler protection, a new ASC is not allowed above the first story of the building. If the existing building is provided with fire sprinkler protection, the ASC may be located above the first floor. Some state specific regulations may prohibit locating an ASC in an existing Type II-B building so be sure to confirm during due diligence calls/surveys. Another consideration/requirement for ASCs is to be separated from occupancies, entities, or tenants within the same building with a 1-hour fire rated separation. This requirement in NFPA 101 and IBC exceeds most other situations in which fire rated barriers are required when separating occupancies, not just by tenants or distinct entities. While designing/constructing a 1-hr separation between the new ASC and the existing building can be done at the renovation space, also confirming the 1-hr separation at the floor of the ASC (if located above grade level or above a basement) as well as above the ASC as well as any structure supporting the 1-hr separation.  If in an existing building of Type II-B construction, the floor and structure do not have an existing 1-hr fire rating and may require an upgrade through spray applied fire resistive materials (SFRM) or a UL assembly to be compliant. This is a critical item to review when performing a site investigation or due diligence survey before moving into design of the ASC as it can have major cost and schedule implications. Smoke Compartmentation Another important consideration in locating an ASC in an existing office building is the requirement for smoke compartments, a unique feature to institutional occupancies (hospitals, ASCs, and correctional occupancies) due to patients/occupants that are incapable of self-preservation. Smoke compartments allow for additional horizontal egress (exiting) time on a floor before egressing vertically and/or out of the building. They are limited to 22,500 SF and are required to be constructed as a 1-hr smoke barrier. This feature is not common in existing office buildings but may be required for ASCs unless the following apply:

• ASC does not exceed 5,000 SF and has full smoke detection.
• ASC does not exceed 10,000 SF and has full fire sprinkler protection.

If smoke compartments are required, it is important to pay attention of the refuge area requirements (and confirming required space needed). Additionally, some state specific regulations differ from NFPA 101/IBC/CMS requirements by requiring at least one exit from each smoke compartment discharging directly to the exterior or requiring two smoke compartments in an ASC regardless of size. Means of Egress Generally, means of egress for ASCs is similar to existing office buildings (business occupancies).  Two remote exits are typically required from the ASC unless travel distance, common path of travel, or occupant load require additional exits. Several state specific regulations require that all means of egress for the ASC are separated from other tenants by a 1-hr separation or do not interconnect with any means of egress for the rest of the building. Fire Sprinkler and Fire Alarm Systems If the existing building is not provided with sprinkler protection, sprinkler protection will be required throughout the floor of the ASC (not just the ASC space) as well as any floor between the ASC and the level of exit discharge. For example, an ASC located on the third floor with the exit discharge level at first floor and floors 3, 2 and 1 will require fire sprinkler protection. If the existing office building is sprinklered, the existing system will be modified for the new ASC space. If the existing office building is not provided with a manual fire alarm system, it will be required within the ASC space. If sprinkler protection is not required, smoke detection will be required within the ASC space as well as public spaces outside of the ASC including public corridors and elevator lobbies. Stay tuned for additional considerations coming soon. Henderson Knows Healthcare Henderson has been designing healthcare projects for more than 25 years and understands that each facility, campus, and project requires a unique approach. With that great responsibility comes the need to design solutions for patient safety, complex equipment, facility infrastructure, and patient experience. Our experts are on the frontlines helping healthcare providers navigate modern technology, complicated code requirements, and the emergence of neighborhood ASCs – all while taking patient care and safety as seriously as our clients do. To learn more about our Health Sector, click here. More from Henderson on converting offices to surgery centers:

• HVAC and Plumbing Considerations for Converting Offices to Surgery Centers