Assisted Living facility interiorI know that many people think the code development process is as exciting as watching paint dry, but I spend many hours with the BHMA Codes, Government and Industry Affairs Committee proposing and monitoring code changes.  I am on the edge of my seat during the hearings where these proposals are discussed and voted on.

We are now in the code development cycle for the 2027 model codes – approved proposals will become part of the 2027 editions of the International Building Code (IBC), International Fire Code (IFC), NFPA 101 – Life Safety Code, etc.  One proposal caught my eye, and in truth, a little tear leaked out.  The proposal is called FS65-24, and you can read it here.

In the 2024 edition of the IBC (and prior editions), Section 716 – Opening Protectives, includes the requirements for fire door assemblies.  One of the most important requirements for a fire door is that the door is closed and latched during a fire – this helps to deter the spread of smoke and flames that could pass through an open door.  Currently, the IBC states: 716.2.6.1 Door closing.  Fire doors shall be latching and self- or automatic-closing in accordance with this section.  There are exceptions for communicating doors between hotel rooms, storm shelter doors, and one related to certain elevator hoistway doors.

Proposal FS65-24 would add another exception:  Fire doors located in corridors and serving sleeping rooms in Group I-1, Condition 2 shall be permitted without automatic- or self-closing devices.

In the I-Codes, Group I-1 includes alcohol and drug centers, assisted living facilities, congregate care facilities, group homes, halfway houses, residential board and care facilities and social rehabilitation facilities, and here’s how the code defines Group I-1, Condition 2:  This occupancy condition shall include buildings in which there are any persons receiving custodial care who require limited verbal or physical assistance while responding to an emergency situation to complete building evacuation.

The most common example of Group I-1, Condition 2 is an assisted living facility.  Although the types of living units and services may vary from one facility to the next, my grandmother lived in assisted living and I have visited assisted living apartments in other facilities as well.  The buildings I visited were basically multifamily apartment buildings for seniors, typically one-bedroom or studio apartments with kitchenettes.  Residents were able to request assistance from staff members for certain tasks – typically non-medical needs like bathing or getting dressed.

According to the IBC, residents of Group I-1, Condition 2 facilities are able to evacuate with limited assistance.  Although they may have some physical limitations, they are expected to get themselves out of the building during a fire.  For the most part, they are living independently, with some support when they need it.

Currently, the IBC requires doors serving residential dwelling and sleeping units, including assisted living units, to be self-closing, self-latching fire door assemblies.  These are typically 20-minute fire doors, which will help to deter the spread of smoke and flames for at least 20 minutes.  The proposed change would allow the closing devices to be omitted from assisted living unit entry doors, so the doors will be easier to open.  The doors could also be left open for prolonged periods of time, as a resident or staff member would have to close the door manually.

I understand the reason this change has been proposed.  Opening a fire door with a door closer can be difficult for someone with limited strength or who has a disability.  BUT – these residents need the protection provided by a closed and latched fire door.  In past apartment fires, unit entry doors and other fire doors that were open during the fire contributed to the fire’s spread, sometimes leading to fatalities.  A 2004 fire at the Rosepark Care Home in Uddington, Scotland resulted in the deaths of 14 elderly residents.  An inquiry found that door closers on many of the unit entry doors had been deactivated or removed at the request of the residents or their families.

As I shared in a 2022 Decoded article, the NFPA reported that in 2020 there were 86,000 apartment fires in the U.S. – an average of 236 apartment fires PER DAY.  This total applies to apartments of all types – not just to assisted living units.  But the most common causes of home fires reported by the NFPA could apply to assisted living apartments:  cooking, heating, electrical distribution and lighting equipment, intentional fire setting, and smoking materials.

Years ago, patient rooms in hospitals and nursing homes were required to have self-closing or automatic-closing doors.  This requirement was removed from the model codes with the addition of increased requirements for automatic sprinkler systems in health care occupancies and the expectation that staff would be trained to close patient room doors if a fire occurred.  The model codes no longer mandate 20-minute fire doors for these rooms in hospitals and nursing homes, but positive-latching hardware is required.

Although current codes require assisted living facilities to have sprinkler systems, the staffing levels in assisted living are much lower than in health care facilities.  Staffing levels, particularly at night, could impact the process of manually closing any open fire doors in an assisted living facility.  For example:

  • Health Care Facilities – Staff-to-Patient Ratio: A Critical KPI for Your Healthcare Practice:  The ideal staff-to-patient ratio will vary depending on the type of healthcare facility and the needs of the patients. However, in general, a ratio of 1:4 or better is considered to be a good benchmark.
  • Assisted Living – Staff to Resident Ratios for Assisted Living:  The US Department of Health and Human Services released a study that found that one-quarter of assisted living communities had a ratio of 1 PCA for each 23 or more residents.  (PCA=personal care assistant)

There are products available that will close the unit entry door to provide the necessary fire protection, while also meeting the needs of assisted living residents, and I will share those in a follow-up post.  But I sincerely hope that the ICC Technical Committee will see the potential dangers that would arise from dwelling unit entry doors (that are supposed to provide fire protection), standing open and allowing smoke and flames to spread, compromising the means of egress.

Thoughts??  Feel free to leave a comment!

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