The Fire Equipment Manufacturers' Association has released a whitepaper on mounting extinguishers in compliance with the ADA and NFPA 101.
(PDF of the whitepaper available here)
The following is the text of the whitepaper:
There is an important discussion currently underway about the manner in which portable fire extinguishers are installed, especially as it relates to the Americans with Disabilities Act (ADA) and health care occupancies required to comply with NFPA 101. It should be noted that ADA was adopted into law in 1990, and the wall projection criteria related to the mounting method of portable fire extinguishers hasn’t changed; therefore, it would be inaccurate to say that current practices are ADA violations. Most existing extinguishers are code compliant and new installations need to comply with the original intentions of all applicable regulations, including ADA and NFPA 101. This document is intended to clarify the requirements and dispel some misinformation that is circulating among the industry. The 2010 ADA Accessibility Guidelines (ADAAG) have two heights for installing protruding objects on walls. They relate to people with sight disabilities. The upper height is 80 inches above the walking surface to avoid a head injury from running into the object. The lower limit is 27 inches above the walking surface. This means that any protrusion that extends to a point 27 inches or less from the walking surface complies with the ADA rules regarding protrusions from walls. This rule is intended to accommodate the sight-impaired population.
A sight-impaired person with a cane can detect a protruding object mounted on a wall with a cane and walk around it. An extinguisher with the bottom at 27 inches or less off the floor can be detected with a cane. Installing the extinguisher hanger so that the bottom of the extinguisher is 27 inches or less from the finished floor is ADA compliant.
Extinguishers Installed on Hangers and in Surface Mounted Cabinets
Surface mounted extinguisher cabinets follow the same rules as extinguishers on hangers. Where the bottom of the extinguisher or the bottom of the surface mounted cabinet is 27 inches or less above the floor, the ADA 4-inch protrusion rule does not apply because ADA permits the extinguisher or cabinet to protrude any distance from the wall. Extinguishers that are not in the circulation path (a circulation path is a way of passage for pedestrian travel such as walks, hallways, ramps, stairways, landings, platform lifts and courtyards) are exempt from these ADA protrusion rules.
Extinguishers Installed in Semi-Recessed and Recessed Extinguisher Cabinets
One reason semi-recessed and recessed cabinets are selected is for aesthetics (they look nice). Another reason is where an extinguisher bottom needs to be higher than 27 inches from the floor. These cabinets are used because they comply with the ADA 4-inch protrusion rule.
NFPA 101 and Extinguishers
NFPA 101, Life Safety Code establishes rules for people to leave buildings safely during evacuations. The current rules establish a maximum protrusion limit of 4 ½ inches where extinguishers are normally installed in the path of egress (e. g. corridors). Extinguisher cabinets are commonly used for compliance. Some extinguishers installed on hangers are within the 4½inch limit, but they may pose unnecessary obstructions. Installing recessed and semi-recessed extinguisher cabinets in the path of egress achieves the desired result of removing obstructions from the egress route. These projection requirements pertain to all objects and fixtures, including extinguishers and extinguisher cabinets.
Some sales and marketing information relating to this issue may be misleading or not complete. We are providing this information to clarify the actual requirements. Your knowledge of these rules will support code compliant installations and potential savings for the end users.
Kidde has recalled fire extinguishers with plastic handles due to failure to discharge and nozzle detachment. One death has been reported.
The fire extinguishers can become clogged or require excessive force to discharge and can fail to activate during a fire emergency. In addition, the nozzle can detach with enough force to pose an impact hazard.
View the complete recall notice from the Consumer Product Safety Commission here.
The Unified Agenda of Regulatory and Deregulatory Actions was recently released and a long-in-development combustible dust rule (RIN: 1218-AC41) at OSHA was absent on the list of active actions. According to the Office of Information and Regulatory Affairs, “this Agenda represents the beginning of fundamental regulatory reform and a reorientation toward reducing unnecessary regulatory burden on the American people. By amending and eliminating regulations that are ineffective, duplicative, and obsolete, the Administration can promote economic growth and innovation and protect individual liberty.” According to Bloomburg BNA, business leaders in industries affected by the potential combustible dust rule, which would have offered additional protections for worker safety against a particularly troublesome hazard, cited it as too burdensome.
Sources: www.reginfo.gov/public/do/eAgendaMain, www.bna.com/trumps-osha-slashes-n73014462036/
In a memorandum released in July 2017, The Centers for Medicare & Medicaid Services (CMS) confirmed that in addition to the new requirements for fire and smoke door testing, they are extending the deadline for compliance to January 1, 2018. What follows is the text of the memorandum.
• In health care occupancies, fire door assemblies are required to be annually inspected and tested in accordance with the 2010 National Fire Protection Association (NFPA) 80.
• In health care occupancies, non-rated doors assemblies including corridor doors to patient care rooms and smoke barrier doors are not subject to the annual inspection and testing requirements of either NFPA 80 or NFPA 105.
• Non-rated doors should be routinely inspected as part of the facility maintenance program.
• Full compliance with the annual fire door assembly inspection and testing in accordance with 2010 NFPA 80 is required by January 1, 2018.
• Life Safety Code (LSC) deficiencies associated with the annual inspection and testing of fire doors should be cited under K211 – Means of Egress - General.
The Centers for Medicare & Medicaid Services (CMS) adopted the 2012 edition of the NFPA LSC, which includes requirements for the maintenance, inspection, and testing of fire doors and smoke doors in certain certified health care facilities.
The 2012 LSC added new provisions under Section 18.104.22.168 – Inspection of Door Openings for the annual inspection and testing of certain fire doors and smoke doors assemblies in accordance with the 2010 editions of NFPA 80 – Standard for Fire Doors and Other Opening Protectives, and NFPA 105 – Standard for Smoke Door Assemblies and Other Opening Protectives.
The new LSC provisions under sections 22.214.171.124.1 and 126.96.36.199.2 require certain fire door and smoke door assemblies to be inspected and tested annually in accordance with the NFPA 80 and NFPA 105. However, section 188.8.131.52.1 states that these requirements only apply where required by Chapters 11 through 43. Therefore, as the LSC health care occupancy chapters (i.e., Chapters 18, 19, 20, 21) do not directly reference section 184.108.40.206, these new annual inspection and testing requirement do not apply to health care occupancies.
It should be noted that the LSC chapters for assembly occupancies, education occupancies, day care occupancies, and residential board and care occupancies do directly reference 220.127.116.11. Therefore, if a health care occupancy contains a separated multiple occupancy, the 18.104.22.168 requirement for annual fire and smoke door inspection and testing would be applicable to these other occupancies.
Annual Inspection & Testing Requirements in Health Care Occupancies
Although the requirements under LSC section 22.214.171.124 are not applicable to health care occupancies, annual inspection and testing of fire doors assemblies in accordance with NFPA 80 are still required in health care occupancies by LSC section 126.96.36.199, which is applicable to all occupancy chapters.
In addition, with the exception of new doors in horizontal exits, the annual inspection and testing of smoke door assemblies in accordance with NFPA 105 is not required per LSC section 188.8.131.52 as doors in health care occupancies are not required to be smoke-leakage-rated.
In health care occupancies, annual inspection and testing in accordance with the 2010 NFPA 80 is required for all fire door assemblies. Non-rated doors, including corridor doors to patient care rooms and smoke barrier doors, are not subject to the annual inspection and testing requirements of either NFPA 80 or NFPA 105. But, non-rated doors should be routinely inspected as part of the facility maintenance program as all required life safety features and systems must be maintained in proper working order. LSC deficiencies associated with the annual inspection and testing of fire doors should be cited under K211 – Means of Egress - General.
Compliance Time Extension
CMS regulatory adoption of the 2012 LSC regulation was July 5, 2016, therefore the required annual door inspections and testing would be expected by July 6, 2017. However, considering the level of reported misunderstanding of this requirement, CMS has extended the compliance date for this requirement by six months. Full compliance with the annual fire door assembly inspection and testing in accordance with 2010 NFPA 80 is required by January 1, 2018.
Contact: If you have questions concerning this memorandum, please send them to SCG_LifeSafetyCode@cms.hhs.gov.