Creating Compliant Storage Rooms in Health Care Facilities

Nursing homes struggling to find storage space may resort to keeping supplies in unoccupied resident rooms or other areas of the facility not typically meant for storage. The problem with storage in areas not designated for that purpose is the facility may have created a hazardous area which could be cited under K 321. 

The issue arises because NFPA 101 (2012) 19.3.2.1.5 (7) defines one example of a hazardous area as: “Rooms or spaces larger than 50 ft2 (4.6 m2), including repair shops, used for storage of combustible supplies and equipment in quantities deemed hazardous by the authority having jurisdiction.”

When facilities begin putting storage into rooms larger than 50 sq. ft. they are creating hazardous areas, and this change of use is not allowed. 

However, Chapter 43 of NFPA 101 (2012) does have an allowance for health care facilities to create storage rooms in a compliant manner. NFPA 101 (2012) 43.7.1.2 (2) says: 

For existing health care occupancies protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1), where a change in use of a room or space not exceeding 250 ft2 (23.2 m2) results in a room or space that is described by 19.3.2.1.5(7), the requirements for new construction shall not apply, provided that the enclosure meets the requirements of 19.3.2.1.2 through 19.3.2.1.4.

Facilities who choose to use rooms not meant for storage need to select rooms that are less than 250 sq. ft., but they also need to abide by 19.3.2.1.2 through 19.3.2.1.4. This means ensuring the door to the new storage location is self-closing, and the room is separated from other areas by smoke partitions.