Rescue and Rehabilitation: It Works for Buildings, Too!

Application concept of NFPA 101Application concept of NFPA 101

As a youngster, I remember the somewhat still popular word game Mad Libs. The game involves a storyline with some key words, events and elements left out and participants would have to fill in the missing words to finalize the story—usually resulting in something that made no sense but that could be funny or ironic. With apologies to the creators of Mad Libs, I offer my own version:

The 1920s era (steel mill, shoe factory, textile mill) had seen better days. Employing more than (10,000; 350; 700) people at one time; producing more than (300 tons of steel; 250 pairs of shoes; 180 dresses) in a day; anchoring the old city in (Western Pennsylvania, the outskirts of Boston, the middle of North Carolina), the magnificent structures represented (a symbol of community economic prosperity, financial security for those who worked there, a landmark along the river). But now, the plant has been closed for over (30 years, 50 years, 60 years) and we turn to companies and brands in (Japan, Southeast Asia, South America) to obtain items that were once made, built and assembled in the U.S. Many of the buildings and structures that used to make our “stuff” are now reminders of (unemployment, economic downturn, urban blight) and are living on borrowed time. They await a bleak future—a (natural death from rust and corrosion, fire, wrecking ball). Designation as a brownfield site can’t be far behind.

This generalization of industries that were once prominent in the U.S.—and some of which are making a comeback—has one big difference to Mad Libs: There is nothing funny about it. It is similar because it is hard to make sense of how we got here and it is ironic that we could no longer find a new use or life for these purpose built structures. While recasting the buildings in a steel mill complex is challenging, it is not impossible as can be seen in the Arts Quest Center at SteelStacks in Bethlehem, Pa. The 4-, 5- and 6-story textile and shoe factories sprinkled throughout New England, the Midwest and Southern U.S. are more malleable. Converting these buildings to apartments, offices or artist-in-residence occupancies is pretty easy—given time and investment.

The regulatory restraints, however, on converting a mill building to some other use hasn’t always been a friend of these adaptive reuse projects. Typical code provisions might have had a general statement that required all work on an existing building to meet all of the requirements for new construction for the intended occupancy use. The U.S. Department of Housing and Urban Development (HUD) issued some guidelines on building rehabilitation in 1980 that could be applied to various occupancies. In 1997, HUD issued the Nationally Applicable Recommended Rehabilitation Provisions (NARRP). NARRP set the model for code organizations, like NFPA, to integrate rehabilitation criteria into the code itself.

The current 2012 edition of NFPA 101, Life Safety Code, is composed of 43 chapters that address life safety from fire and similar emergencies for new and existing buildings. NFPA 101 is a highly unique code in the world based on its applicability to existing buildings. The occupancy based format of the code also makes it easy to find the relevant requirements in short order. The Life Safety Code has its origins in 1911 following the Triangle Shirtwaist fire in New York City in which 143 occupants—mostly women and girls—died. The code content has matured and new subjects, such as a performance-based design options, has allowed NFPA 101 to stay current and, in some cases, ahead of the building design curve.

The inclusion of a new chapter for the 2006 edition of the code offered a set of provisions based on the NARRP and that looked at the in between needs of allowing a developer or designer to improve or even repurpose the building without having to necessarily satisfy all of the “new” construction requirements. Shown as Chapter 43, Building Rehabilitation, in the current (2012) edition of NFPA 101, the rehab provisions fall into seven distinct work categories that include:


The patching, restoration or painting of materials, elements, equipment or fixtures for the purpose of maintaining such materials, elements, equipment, or fixtures in good or sound condition.


The replacement in kind, strengthening, or upgrading of building elements, materials, equipment or fixtures that does not result in a reconfiguration of the building spaces within.


The reconfiguration of any space; the addition, relocation, or elimination of any door or window; the addition or elimination of load-bearing elements; the reconfiguration or extension of any system; or the installation of any additional equipment.


The reconfiguration of a space that affects an exit or a corridor shared by more than one occupant space or the reconfiguration of a space such that the rehabilitation work area is not permitted to be occupied because existing means of egress and fire-protection systems or their equivalent are not in place or continuously maintained.

Change of Use.

A change in the purpose or level of activity within a structure that involves a change in application of the requirements of the code.

Change of Occupancy Classification.

The change in the occupancy classification of a structure or portion of a structure.


An increase in the building area, aggregate floor area, building height or number of stories of a structure.

Since NFPA 101 offers a set of specific criteria for existing buildings, Chapter 43 sets a “floor” with regard to a minimum level of safety as part of the rehab provisions. This means compliance with the requirements for the appropriate, existing occupancy chapter of the code must always be satisfied as a starting point. Application of the concept based on the above categories is then segmented and the code lays out what the parameters are for each category. Some level of “minimum” safety must be present—at least what is required for the existing occupancy. In some cases, the bar is moved up to the companion rules for the new occupancy. The figure is a depiction NFPA uses to capture this concept.

Application concept of NFPA 101

Application concept of NFPA 101

The simplest work category, Repair, specifies the following:

    Use like materials, or materials permitted by the code.
    The work cannot make the building less conforming than before.
    – Can be reduced to “new”
    Shall not be less than provision for the existing occupancy rules.

The next category, Renovation, slightly increases the complexity over Repair, but provides the roadmap to bracket the appropriate requirements. These include:

    The work must comply with the rules for the appropriate existing occupancy chapter.
    The work cannot make building less conforming than before.
    – Minor reductions in door or window clear openings permitted
    Any newly installed interior finish has to meet the requirements for new construction.
    If the work involves reconfiguration or extension of any system or the installation of equipment, the next category, Modification, must be utilized.

The code details each of the other categories in a similar manner. For our now-vacant New England textile mill, transforming it into apartments brings in the Change of Occupancy Classification rules. In NFPA 101 parlance, the building is being reclassified from an industrial occupancy to a residential occupancy. The requirements of Chapter 30, New Apartment Buildings, and Chapter 31, Existing Apartment Buildings, will now be in play. A second piece of information needed by the designer is to compare the relative hazard (hazard category) of what the building was and what it is being updated to become. Chapter 43 provides a table to make this part a simple look up.

Hazard categories and classifications

Hazard categories and classifications (Click to view larger)

The mill building would be a general purpose industrial occupancy, category 3, and a residential occupancy is also a category 3. These represent the shaded selections in the table. The Change of Occupancy Classification rules then offer the following breakdown: So long as the change of occupancy is within or to a lesser hazard category, the designer can, for the most part, apply the provisions for existing apartment buildings (Chapter 31). Since the mill buildings previous life and its new life fall into hazard category 3, this approach holds true.

The caveat is three subjects based upon the provisions for new apartment buildings (Chapter 30) must be applied. Those involve automatic fire sprinkler systems, building fire alarm systems and protection of hazardous areas. Chapter 43 provides a clear trail to negotiate when the “new” versus “existing” rules apply.

Adapting, reusing, repurposing and rehabilitating some of the architectural marvels from the early 20th century era offers a cost effective, and sustainable option for these structures. Alternatives to deconstruction and demolition now exist.

Flexibility of codes, including carefully crafted language that defines and outlines the precise level of work being undertaken and the path to follow in the code gives new life to old buildings. Rescue and rehabilitation is a good thing for any number of topics—people, animals, old tractors and buildings.

About the Author

Robert Solomon, P.E.
Robert Solomon is the division manager for NFPA’s Building Fire Protection and Life Safety Department whose projects include the NFPA Fire Code, Life Safety Code and the Building Construction and Safety Code. Upon graduation from the University of Maryland, he worked with the Naval Facilities Engineering Command in Charleston, S.C. Since coming to NFPA in 1986, he has held several positions. He is an author, editor and technical reviewer for several NFPA publications and handbooks including the Automatic Sprinkler Systems Handbook, Fire and Life Safety Inspection Manual, the NFPA Fire Protection Handbook, Quick Compare Life Safety Code 2000 & 2012 for Health Care and The Joint Commission NFPA Life Safety Book for Health Care Organizations. He chairs the Healthcare Interpretations Task Force and is a member of the CTBUH Fire Safety Task Force.

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