OK…based on a recent code interpretation, I am livid! Even though I am not a big government regulations guy…and I promise to keep politics out of this discussion, I seem to be fully immersed in them…regulations, that is. In addition to my responsibilities with SAGE, I serve on the national AHCA Life Safety Committee (American Health Care Association). During a recent conference call, the AHCA Life Safety Consultant reviewed recent interpretations from the Health Interpretation Task Force (HITF). A key voting member of this task force is CMS (Centers for Medicare and Medicaid). Unfortunately, I am not finished with acronyms, so please bear with me!
So…back to the interpretation. Here is the question that was submitted tothe HITF. “Is non-fixed furniture allowed to be placed in the corridors of skilled nursing homes where the corridors are wider than the required 8 feet, so long as, the non-fixed furniture does not encroach into the required 8 foot corridor width?” The Pioneer Network, The Rothschild Foundation and SAGE were influential in getting this culture change initiative into the 2012 Life Safety Code, which allows for furniture to be placed in corridors. The HITF answer: “No, non-fixed furniture is not allowed. Provisions of NFPA 18/220.127.116.11(5) do not apply to non-fixed furniture. This provision is not intended to restrict non-fixed furniture in spaces permitted to be open to the corridor. (18/18.104.22.168)”
This is, in my opinion, ridiculous! This was never the intent of the culture change team that lobbied for this very resident centered approach. In simplified terms, the regulations allow for furniture to be placed in an 8-foot wide corridor as long as the furniture is fixed to the floor or wall and it does not reduce the width of the corridor to less than 6 feet. I get that. Regardless of the corridor width over 8 feet, any furniture in that corridor has to be fixed to the wall or floor. I don’t get that!
At this point, our only solution as architects, designers and providers is to designate the excess corridor width over 8 feet as a “space open to the corridor”. That approach seems manipulative, at best, but is supported by the HITF interpretation. It is my hope that the SAGE Regulatory Impact Committee can have some influence in these type of code interpretations. For now, I will pursue some personal therapy by visiting one of our amazing care communities, grabbing a cup of coffee and strapping myself into one of our fixed chairs in the hallway!Are you pulling your hair out over code interpretations? SAGE's recent "CodeBusters" webinar may help! We chewed on obstacles we face with senior-housing codes and shared insights on turning these obstacles into opportunities. SAGE national code representatives Amy Carpenter and John Shoesmith started the conversation with a re-cap of SAGE code initiatives at a national level. They will then dove into a conversation with case studies revolving around real code issues SAGE members face in their own communities and projects. SAGE members can access the recording of the webinar via the Members Only page.