Adequate exiting has been a fundamental principle in fire protection and life safety since the first fire codes and likely long before that. In modern times we have always maintained that an exit has three primary parts, the exit access, the exit, and the exit discharge. Regardless of the occupancy classification, building construction type, fire protection features, etc, these three elements were critical components to consider when designing, constructing, and maintaining a building for the appropriate level of fire and Life Safety.
Exit capability within healthcare occupancies is as important as in any other type of occupancy, and in some cases perhaps even more so. To that end The Joint Commission and Medicare/Medicaid have historically mandated compliance with National Fire Protection Association’s “Life Safety Code 101”. Currently, both of these agencies require compliance with the 2012 edition of NFPA 101 as they have for the roughly past 6 years or more. Prior to this both agencies referenced various editions of NFPA 101 Life Safety Code going back as far as the 1967 edition.
Within each edition of the Life Safety Code, there has always been a section on exits, and within each one of those sections it identified the same essential components (exit access, exit, and exit discharge).
Just recently, The Joint Commission published an online article addressing the fact that aisle widths in hospital suites, and critical access hospital suites must be maintained at a 36” minimum. Specifically, they said “Now in effect, Joint Commission Life Safety Code surveyors will cite noncompliance in suites that have less than 36 inches of clearance from side to side to facilitate egress. This requirement follows the National Fire Protection Association’s (NFPA) Life Safety Code (NFPA 1-1-2012). Section 7.3.4.1(2), in the core chapter on egress, which sets the minimum width of any means of egress at 36 inches in all facilities classified as health care occupancy. This requirement applies to Joint Commission accredited hospitals and critical access hospitals that use the suite provisions of the code and, depending on their occupancy classification, may apply to behavioral healthcare and human services organizations, facility-based hospice facilities, and nursing care centers.
The finding will be scored at Life Safety (LS) Standard LS.02.01.20, element of performance (EP) 42, which requires organizations to maintain the integrity of the means of egress in accordance with the Life Safety Code.”
The real question that arises is “Why is The Joint Commission highlighting the issue now, when it has been in the code for decades”? It would seem clear that they are putting us on alert that this is an area that will likely receive heightened attention in future surveys. We are therefore alerting clients that in the future surveyors will be looking not only as they have in the past at actual exit corridors, but also aisles in suites. Theoretically, in any suite where there is not a 36” wide, clear, and unobstructed aisle, you could be subject to a finding. Certainly, the surveyors will focus their attention on ICU’s, Operating Rooms, Nurseries and other common types of patient sleeping suites, but keep in mind the standards also apply to many other types of suites such as Radiology, Dialysis, Receiving Rooms, Large Pharmacies, Laboratories, or any other area where a suite configuration of rooms is used.
Keep in mind, this is not a new standard but rather a re-statement by The Joint Commission of their intent to re-focus surveyor’s attention toward this type of condition.