CMS Issues Clarification of Automatic Fire Sprinkler System Installation Requirements in Attic Spaces in Long-Term Care Facilities

PUBLISHED: Dec 29, 2016

On May 4, 2016, the Centers for Medicare & Medicaid Services (CMS) published the final rule Medicare and Medicaid Programs: Fire Safety Requirements for Certain Health Care Facilities (81 FR 26872). This regulation adopted the 2012 Life Safety Code (LSC), and the 2012 Health Care Facilities Code (HCFC) which requires all existing and newly constructed health care facilities, including long term care facilities, to be equipped with a supervised automatic sprinkler system. This regulation requires compliance with the 2010 edition of National Fire Protection Association (NFPA) 13, Installation of Sprinkler Systems.

CMS has received several requests for clarification concerning the installation of automatic fire sprinklers in concealed or attic spaces of health care facilities, specifically where Fire Retardant Treated Wood (FRTW) has been installed in attic spaces or used in the construction of roofs.

The NFPA Installation of Sprinkler Systems, NFPA 13, 2010 edition requires sprinkler protection in all areas of a building at Section 4.1.

  • The few exceptions that permit sprinklers to be omitted in certain areas and still consider a building to be completely sprinkler protected are found at Section 8.15.1.

Concealed Spaces

Concealed spaces are non-occupied spaces that can be created by construction of the building. These spaces may contain wiring, and piping for building service equipment such as HVAC equipment and may be void of any combustible material. Concealed spaces are not required to be sprinklered as long as the storage of combustible items is not permitted. Limited access to these areas by small access panels is allowed.

An attic can be a concealed space if it is constructed and used as a concealed space as outlined in of NFPA 13. Concealed spaces may be constructed of or contain noncombustible or limited combustible material such as FRTW and, spaces constructed of such material are not required to be protected by an automatic sprinkler system. FRTW is allowed to be used in both “new” and “existing” construction of an attic or concealed space by the LSC as referenced at,, and and section of NFPA 13.

Note: The use of FRTW is allowed to be installed in a facility in concealed or attic space without the installation of an automatic sprinkler system, provided that it meets certain conditions related to access, construction type, storage and fuel fired equipment. This is a change, because FRTW was not discussed clearly with regards to concealed spaces in the 2000 edition of the LSC or the 1999 edition of NFPA 13.

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