Navigating the NFPA code-revision process

As many are still getting used to the Centers for Medicare & Medicaid Services (CMS) adoption of the 2012 edition of the National Fire Protection Association’s NFPA 99, Health Care Facilities Code, and NFPA 101, Life Safety Code®, the consensus code process keeps moving and this summer marks the beginning of the revision process for the 2021 edition of each of these codes.

The NFPA process provides opportunities to take part in the future of codes and standards. While health care is often held to older editions of codes, it is vital to pay attention to where they are going. Opportunities include:

• Public input. The entire code is open to suggestions at this point. If something is seen as overly burdensome, confusing or inappropriate, you can submit a proposal for improving the code along with your reasoning. A first draft report will include all changes made to the code based on public input and technical committee revisions along with a statement on how public inputs were acted upon. The closing date for input is June 27.
• Public comment. This is the chance to provide feedback on anything in the first draft. At this stage, you can comment on how a proposed change should be modified or reversed and you can also resubmit support of any input that may not have been accepted. A second draft report is published with a complete version of the current draft of the code and committee responses to public comments. The public comment closing date will be May 8, 2019.
• Notice of intent to make a motion/NFPA technical session. Another opportunity to make your case is at the NFPA annual conference. If someone has argued a position through the earlier stages of the revision process, he or she can make a case to the NFPA members in attendance at the technical session, which is part of the conference. The American Society for Healthcare Engineering strongly encourages participation at these meetings. The technical session will be on June 17, 2020.

Facilities professionals should visit www.nfpa.org/99next or www.nfpa.org/101 next to submit input and keep track of the process.

Jonathan R. Hart, PE, principal engineer, National Fire Protection Association