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Frequently Asked Questions Concerning Life Safety Code

  1. I have heard the term "life safety code or (LSC)" used when referring to fire safety requirements in various health care facilities and settings. What exactly is a "life safety code" and how is it used to protect users of these facilities?
     

The LSC is a set of fire protection requirements designed to provide a reasonable degree of safety from fire. The standards found in the code cover construction, protection, and operational features designed to establish minimum requirements that will provide safety from fire, smoke, and panic. The LSC is a publication of the National Fire Protection Association (NFPA). Beyond such institutional settings as nursing facilities that are Medicaid or Medicare participating, the LSC is also applied to hospitals (42 CFR Part 482.41(b)), inpatient hospices (42 CFR Part 418.100(d)), ambulatory surgical centers (42 CFR Part 416.44(b)), and end stage renal disease facilities (42 CRF Part 405.2100).

  1. I understand that the national code keeps changing, but that the Ohio Department of Health relies on the 2000 version of the LSC. Why doesn’t the department update the standards under which they inspect? 
     

Although the LSC has been revised over the years, currently, the basic requirement for facilities participating in the Medicare and/or Medicaid programs is compliance with the 2000 Edition of NFPA 101 Life Safety Code.  Which code to apply is not a determination that the ODH can make on its own. As the state survey agency, the ODH is an "agent" of the federal government’s Centers for Medicare and Medicaid Services (CMS).  As such, ODH must follow the federal protocols, and those protocols still require the 2000 Edition of the LSC as noted above.

  1. Does this mean that new construction in Ohio has to follow the 2000 code rather than building to the specifications of the newer code?
     

No. CMS’ regulations/protocols allow a newer NFPA code to be used to design a building, but that, when surveyed under the Medicare regulations, a provider would have to request a waiver of the NFPA 101 2000 Edition requirements for those items permitted under the newer code, but contrary to the 2000 code. One provision of this exception, however, is that a provider opting for the newer code would have to meet all of the standards under that code and not "pick and choose" from among the older and newer standards.  Additionally, before granting a waiver CMS requires that the provider identify each code requirement that is different between the two editions of the codes.
 

Last Updated: 6/10/2009