Smoke detectors in on-call physician sleeping rooms

OSHA Healthcare Connection, November 6, 2012

Q: We recently had an inspection where we were cited for not having a smoke detector in the on-call sleeping room for physicians, which is located on our labor & delivery nursing unit. We thought since the sleeping room is located in the healthcare occupancy, a smoke detector would not be required. The inspector didn't see it this way and wrote us up. Was he correct in doing so?

A: This is one of those "it depends" answers. Since the on-call physician sleeping room is located on the nursing unit, the inspector probably assumed that you have a mixture of two different occupancies: Healthcare, and Hotels & Dormitories. When there is a mixture of occupancies that are not separated by two-hour fire-rated barriers, section of the 2000 edition of the Life Safety Code® (LSC) requires the most restrictive life safety requirements be included for each occupancy. It appears the on-call physician sleeping room qualifies as a Hotel & Dormitory occupancy, and single-station smoke alarms are required in all sleeping rooms, according to section of the LSC. However--and this is where it gets tricky--there is an exception to section concerning incidental use. The incidental use of the Hotel & Dormitory occupancy is allowed within the larger, predominant Healthcare occupancy, without having to meet the requirements of the Hotel & Dormitory occupancy. The question is, what constitutes "incidental" use? That is up to the authority having jurisdiction (AHJ), and since the average hospital has five or more AHJs, it is likely that any one of those AHJs will require a smoke detector in the on-call sleeping room. A smoke detector that is connected to the building fire alarm system, which transmits alarms through notification appliances to the staff in the building, should be considered equivalent to a single-station smoke alarm. The LSC does not prohibit the use of devices of equivalent or superior safety.

Source: Excerpted from Healthcare Life Safety Compliance, November 2012.

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