# NFPA 101 Business Occupancy storage room protection



## PatrickGSR94 (Nov 16, 2021)

I have an existing renovated outpatient care facility where an independent code consultant is stating that all storage rooms must be rated with closers on doors.  The building is Business occupancy per the IBC, ambulatory care with fewer than 4 incapable of self-preservation, no general anesthesia used, and the building is nonsprinkled.  They are citing NFPA 38.3.2.1 for New Business Occupancies (even though it's an existing building), which seems to indicate that ALL storage rooms must be rated or protected, regardless of size.  But in 18.3.2.1 and 19.3.2.1 for new and existing health care facilities, the protected storage room requirement is only for 100 SF and larger.

So which one would apply here?  The Business storage room protection requirements in the NFPA appear to be much more stringent than the IBC (no rated protection required for accessory storage under 100 SF), but for health care facilities they're pretty much aligned.

Despite the building falling under Business occupancy in the IBC, would this also be considered a health care facility in the NFPA?


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## classicT (Nov 16, 2021)

Under the IBC, ambulatory care facilities are listed as a Group-B occupancy (IBC 304.1). They are also listed in IBC Ch. 4 as a special occupancy with detailed requirements; see _IBC Section 422_.

The IBC does have a similar requirement for compartmentalization of ambulatory care storage and laundry rooms via 1-hr construction, which is found in _IBC Table 509_.

Sorry, but not familiar with NFPA, as in my home state, the Dept. of Health does that review.


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## PatrickGSR94 (Nov 16, 2021)

We are well below all those requirements.  The building is only ~2,500 SF.

The report actually says, with reference to NFPA 101 38.3.2.1: "Doors to rooms storing flammable, combustible, toxic, noxious, or corrosive materials (except routine office supplies) are self-closing or automatic closing and positively latch." And then it lists nearly every door in the building, including the procedure rooms, work rooms, storage rooms, exterior doors and so on.

I cannot find any such requirement in the NFPA containing any such text.  The report makes it sound like every room with a piece of paper must have a closer on its door, which I'm pretty sure is not the case.


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## Paul Sweet (Nov 17, 2021)

As you mentioned chapter 38 is for new business occupancies so it shouldn't apply to you.

2021 NFPA 101 par. 38.3.2.1 says:
"Hazardous area including, but not limited to, areas used for general storage, boiler or furnace rooms, and maintenance shops that include woodworking and painting areas shall be protected in accordance with section 8.7."

A38.3.2.1 says:
"It is not the intent of this provision that rooms inside individual tenant spaces that are used to store routine office supplies for that tenant be required to be either separated or sprinklered."

Link to NFPA free code viewer:


			List of NFPA Codes and Standards


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## PatrickGSR94 (Nov 17, 2021)

I just find it odd that 37[38].3.2.1 both do not list a size threshold for a storage requiring protection, as other sections do including Healthcare.  It still seems that NFPA's intent is for all storage rooms in Business occupancies, regardless of size, to be protected.


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## Paul Sweet (Nov 19, 2021)

I think your consultant s being overzealous with his interpretation of "hazardous".


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## JSimma (Nov 19, 2021)

From 38.3.2.1 go to to 8.7 and with a fully sprinkled building to 8.7.1.2 ... storage rooms in Business Occ are required to be protected with smoke partitions and a door closer per 8.4.3.5. This should satisfy CMS or the TJC as they conduct walk throughs in to Business Occs adjacent to Healthcare or freestanding. Our firm has been doing this to outpatient clinics for several years.


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## PatrickGSR94 (Nov 19, 2021)

Paul Sweet said:


> I think your consultant s being overzealous with his interpretation of "hazardous".


Oh I'm sure of that, I just have to convince them.


JSimma said:


> From 38.3.2.1 go to to 8.7 and with a fully sprinkled building to 8.7.1.2 ... storage rooms in Business Occ are required to be protected with smoke partitions and a door closer per 8.4.3.5. This should satisfy CMS or the TJC as they conduct walk throughs in to Business Occs adjacent to Healthcare or freestanding. Our firm has been doing this to outpatient clinics for several years.


Building is not sprinkled, only 2,500 SF.  No rated walls are required from what I can tell from the IBC.  Corridors serve under 30 occupants, no storage rooms over 100 SF.


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## Reed Mattila (Nov 29, 2021)

PatrickGSR94 said:


> We are well below all those requirements.  The building is only ~2,500 SF.
> The report actually says, with reference to NFPA 101 38.3.2.1: "Doors to rooms storing flammable, combustible, toxic, noxious, or corrosive materials (except routine office supplies) are self-closing or automatic closing and positively latch." And then it lists nearly every door in the building, including the procedure rooms, work rooms, storage rooms, exterior doors and so on.
> I cannot find any such requirement in the NFPA containing any such text.  The report makes it sound like every room with a piece of paper must have a closer on its door, which I'm pretty sure is not the case.


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