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Existing construction vs. new construction, doorknobs on Dutch doors, courtyards

Healthcare Life Safety Compliance, September 1, 2018

This is an excerpt from a member only article. To read the article in its entirety, please login or subscribe to Healthcare Life Safety Compliance.

 Each month, Brad Keyes, CHSP, owner of Keyes Life Safety Compliance, answers your questions about life safety compliance. Our editorial advisory board also reviews the Q&A column. Follow Keyes’ blog on life safety at www.keyeslifesafety.com for up-to-date information.  

Existing vs. new construction

Q: How do we classify existing vs. new construction? Do we look at the date of adoption of the current Life Safety Code® (LSC) as the cutoff? Would anything constructed before that date be considered existing construction? The 2000 LSC required areas of major rehabilitation to be classified as new construction. The 2012 LSC appears to just require those areas be fully sprinklered. On our life safety plans, all areas of the hospital were constructed prior to the adoption of the 2012 LSC. Can the entire hospital now be considered existing, and can we remove all notes on the plans referring to new construction?

A: According to the CMS final rule on adopting the 2012 LSC, which was released in May 2016, they identified July 5, 2016, as the threshold date to differentiate between new construction and existing conditions. However, the 2012 LSC says in section 4.6.12.1 that whenever a feature of life safety is required for compliance, it must be maintained as such for the life of the building. 

Section 4.6.12.2 continues to say that features of life safety shall not be removed or reduced where such features are required for new construction. What this means is that you cannot downgrade a feature of life safety that was installed under new construction requirements to meet existing condition requirements now that it is no longer considered new construction. It is true that something built prior to July 5, 2016, is now considered existing conditions, but you still are not permitted to downgrade the feature to meet existing condition requirements.      

This is an excerpt from a member only article. To read the article in its entirety, please login or subscribe to Healthcare Life Safety Compliance.

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