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COVID: Steps to Reopen Shuttered or Minimally Occupied Buildings

As the grip of the COVID pandemic eases, what do facility managers and building owners need to consider as they take steps to reopen shuttered or minimally occupied buildings? A building safety expert offers a few tips.

INTERVIEW CONDUCTED AND EDITED BY JESSE ROMAN

To this day, desk calendars in office buildings around the world are still eerily stuck on March 2020—the month when the COVID-19 pandemic prompted a global shutdown. In addition to offices, schools and universities sent students home; gyms, theaters, concert venues, and even hotels and airports either closed or dramatically reduced their capacity.

In recent months, however, many of the facilities that COVID shuttered have reopened. Others have yet to return to normal but are planning to later this year. It is a unique situation, maybe unprecedented, to have such a significant number of facilities all coming back to life at the same time after such a long hiatus, says Bill Koffel, a fire protection engineer and the president of Koffel Associates, a fire protection and life safety engineering, design, and consulting firm headquartered in Maryland.

“I think this mass reopening will create some significant challenges on the resources available to code officials and authorities having jurisdiction,” Koffel said in a recent interview. “This really is new territory for us, and we’ll have to learn as we go.”

In addition to AHJs, many building owners are grappling with how—and even if—to return their facilities to the way things were before COVID. This includes not only buildings that partially shut down, but also occupancies like grocery stores and health care facilities that never closed but made significant COVID-related alterations.

If anyone is qualified to comment on the uncertain present and long-term future of the code and fire safety implications of COVID, it’s Koffel. He is recognized as an expert in fire and life safety codes and standards, especially for health care facilities, and he’s active in the standards development process for a number of organizations, including NFPA, where he has sat on committees for NFPA 101®, Life Safety Code®NFPA 99, Health Care Facilities CodeNFPA 13, Standard for the Installation of Sprinkler Systems; and the proposed NFPA 915, Standard for Remote Inspections.

NFPA Journal caught up with Koffel to talk about what the reopening has looked like from a safety perspective, as well as the many ways that the coronavirus pandemic may permanently alter our safety standards and the built environment.

Do codes and standards include much guidance on a mass reopening type of situation, or is this uncharted territory?

I would have to say this is new territory. We have a 2021 edition of the Life Safety Code and of NFPA 1, Fire Code, but those documents were really completed in the beginning of 2020, right when this whole pandemic started, so there wasn’t time to address this.

You are president of a large code consulting firm. Have you been involved in helping facilities or buildings deal with this reopening?
We haven’t received a lot of inquiries, nor are we necessarily providing a lot of consulting services on the topic right now. A lot of our clients do a lot of health care work, and they were operating during this pandemic. But I do suspect from talking with people that, in many parts of the country, the reopening has not yet really started. In Boston, for example, a lot of the office buildings are still vacant. I think this is something that we’ll see develop over the next three to six months.

What are some of the larger types of occupancies that will go through this reopening process during the upcoming weeks or months?

I think we really have two categories: buildings that have basically been vacant and unused, and buildings that have been used to a degree but aren’t really fully operational. I know some office buildings will fall into that latter category, as well as university classrooms and some hotels. A lot of hotels tried to stay open during this situation, but their occupancy rates were very, very low. So they were being used at minimal capacity. Some of our airports have also been operating at reduced or minimal capacity.

Let’s start with buildings that were more or less unused, like office buildings where the vast majority of staff were working remotely. What safety issues do facilities managers and building owners need to be aware of?

One of the first questions the owner would have to ask is, has the building been secured during that period of vacancy? I presume the answer is yes, but if it hasn’t been secured during that period of vacancy then it is considered an unsafe structure, which imposes some significant code enforcement activity to reopen that building. If the building has been secure, the next question is, what has the owner been doing in that building in terms of maintaining the various systems? Have they been performing the inspection, testing, and maintenance activities as required by NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, or NFPA 72®, National Fire Alarm and Signaling Code®? If not, we know that anything that’s not used periodically can potentially fall into a state of disrepair.

What if that’s the case?

I know there are some building owners who will be hesitant to do this, but I would recommend they reach out to their local code official or AHJ and ask, ‘What procedures or requirements are you going to impose on this building to reopen?’ If you’re not comfortable reaching out to the code official, another alternative would be doing a risk analysis and determining what the potential associated risks are—for instance, what are the risks if the doors haven’t been used, or systems in the building haven’t been properly inspected, tested, and maintained? Then you should determine what you need to do to make sure that everything is functioning the way it should when you do start to invite your employees or public back into your buildings.

Obviously, new buildings are required to go through an inspection process and need to get a certificate of occupancy before opening. Have you seen AHJs impose anything like a recommissioning process to reopen buildings that have been mostly unused?

There’s not a whole lot in the regulatory environment because we never really anticipated this type of situation. NFPA 1 does have a provision in Chapter 10 that says if the fire protection systems have been out of service for more than 30 days, the AHJ can require an inspection and test of those systems. It doesn’t elaborate in any other way. Is this our normal commissioning or acceptance test, or is this just maybe the annual tests that are typically required for our fire protection systems?

Another document that exists but that wasn’t written with this in mind is NFPA 4, Standard for Integrated Fire Protection and Life Safety System Testing, which addresses the testing of integrated fire protection systems, including the commissioning of the system as a new system. But it does introduce this concept of recommissioning systems, and it indicates that there should be a plan as to what this frequency should be. If we don’t have a plan, the default is that the system should be recommissioned every five years. Depending on how actively you’ve been maintaining these systems during this last 12 to 14 months of the building not being occupied, I would offer that recommissioning and looking at NFPA 4 may be a good option. Is there a code that requires you to do that? Not unless the systems were totally out of service, and then NFPA 1 would give the AHJ the authority to require testing.

The second category of building you mentioned are those that weren’t closed during the pandemic but may have changed their layouts or occupancy loads during the shutdown. As these types of buildings return to something closer to normal, are there any code and safety considerations they need to take into account?

Some buildings, like grocery stores, have modified egress. In several instances, I’ve seen that exit signage has not been modified along with this new egress arrangement. So, we’re telling people to go to an exit only to find that they’re not supposed to use that exit. There are things like that that businesses should be doing now, even before they fully return to full capacity.

The other thing that I’ve been seeing inside buildings is the increased use of plastics. You see these plastic barriers between you and the cashier, between you and the person working the deli counter, and even in offices. Depending upon the extent of material being used, there are code requirements such as interior finish requirements. It’s something to consider because we may see these temporary barriers continue into the future. We need to make sure that we’re meeting the code requirements for plastic materials or interior finish materials.

Your firm focuses primarily on health care facilities, which were greatly impacted by the pandemic, maybe more than any other occupancy. Do you anticipate seeing some interesting code changes as a result of the pandemic in the health care space?

I do, and I’m already seeing some of these start their way through the process. The Facility Guidelines Institute, for example, has produced a white paper that addresses emergency conditions, including surge of patient care and alternate care sites. Part of that deals with using space in a hospital for patient care that wasn’t originally designed for patient care. During the height of the pandemic, for instance, we had all sorts of spaces in hospitals being converted to patient care areas, even hospital chapels.

There’s also a section in that white paper that talks about alternate care sites. I actually chaired that subcommittee. During the pandemic, we saw patients being treated in convention centers, hotel ballrooms, and many places that were never intended for health care. But we were using these spaces to house medical equipment, medical systems, electrical systems, and medical gas systems, as well as patients. I think a lot will be done over the next several additions of codes with regard to alternate care sites.


A temporary COVID-19 field hospital in a convention center in Washington, DC. Upcoming code changes could focus on adding more guidance for these makeshift heath care facilities, which were widely used during the pandemic. GETTY IMAGES


Do you envision changes to NFPA codes and standards related to health care?

Yes. As the chair of the Health Care Occupancies technical committee for NFPA 101, I plan on appointing a task group as we develop the 2024 edition of the Life Safety Code to look at whether we should be making changes to allow more flexibility for alternate care sites. For example, currently, if I convert a hotel into a hospital as an alternate care site, NFPA 101 says it has to meet the requirements for a new health care occupancy, which requires an eight-foot-wide corridor. There aren’t a whole lot of hotels with corridors that are eight-feet wide. I think there are solutions we should be looking at.

There are also new guidelines being developed around remote inspections and remote testing of fire systems, which I think could have an impact if something like this pandemic happens again. For a while, outside contractors weren’t allowed to come in to do inspecting and testing in health care facilities in order to protect patients or residents from outsiders who might be COVID-positive. I think you’ll see some increased code activity along those lines.

It seems like the effects of the pandemic will be felt for years in the codes and standards world. I’m sure there will be countless other code changes, large and small, that we haven’t even thought about yet.

Yes, and I’d like to add one thing to that. No matter what your role is—whether you’re a code official, AHJ, building owner, or occupant within a building—I would encourage you to give some thought to the lessons that you might have learned from the last 14 months. And I would also encourage you to please share that information with us and help out by participating in the code making process. The Life Safety Code and NFPA 5000, Building Construction and Safety Code, are both open for public input right now. As a committee member, we would welcome input from those of you who have learned something from this pandemic and can share those lessons with the committee and potentially improve our regulatory documents.

JESSE ROMAN is associate editor for NFPA Journal. Email him at jroman@nfpa.org. Photographs: GETTY IMAGES

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