Residential Settings Frequently Asked Questions (FAQ)

  1. Is it required to have sprinklers only in hallways or does a site need to have sprinklers throughout the facility?

    If a residential board and care home is required by the Life Safety Code to be protected by automatic sprinklers, or if the facility desires to take advantage of any design options that are granted in the Life Safety Code as the result of the presence of an automatic sprinkler system, then the system must be installed throughout the occupancy and not just in hallways or selected areas.

  2. If a bedroom is in the basement and there is a window, is it required to have a secondary means of escape?

    The Life Safety Code makes a generalized requirement that all residential board and care occupancies be provided with a secondary means of escape. The LSC then allows exceptions to this requirement if the occupancy is either protected throughout by an automatic sprinkler system or if the sleeping room has a door leading directly to the outside of the building with access to grade or to a stairway that meets the Code's requirements for outside stairs. Therefore, unless the building is protected throughout by automatic sprinklers or a sleeping room has such a direct route to the outside of the building, a secondary means of escape would be required. A window may serve as the secondary means of escape from a residential board and care home if it meets all of the parameters prescribed in the Life Safety Code (i.e., minimum width and height, minimum sill height off of the floor, etc.).

  3. Where does ownership of condos or townhouses apply in the code?

    The Life Safety Code does not differentiate between occupancy classifications based upon the form of ownership. A condominium is normally classified as an "apartment building" under the Life Safety Code, and a town home, depending upon the number of units, may be classified as a single- or two-family dwelling, or an apartment building. When clients who received personal care services reside in any of these occupancy classifications, then the residential board and care occupancy chapter of the Life Safety Code applies.

  4. Is it possible to conduct a FSES (Fire Safety Evaluation System) internally?

    Yes. There are no requirements stipulating who can conduct an FSES. Once submitted, the OSFM will have a fire prevention inspector verify the conditions that are credited on the FSES as well as check that the document is properly filled out and calculated. The OSFM does not fill out the FSES documentation for a facility. Although it is not required, the OSFM recommends that occupancy owners use professionals who are familiar with the National Fire Protection Association's FSES process to ensure accuracy. (This usually means a professional engineer or architect who has experience with the FSES process).

  5. Pertaining to the height of window from the ground, what is acceptable to the SFM?

    The Life Safety Code permits the use of a window as the secondary means of escape if the window is within 20 ft. of grade, or leads to an outside balcony, or if the window is accessible to the local fire department. The OSFM will assist owners of residential board and care facilities in determining if secondary escape windows are accessible to local fire departments.

  6. Pertaining to the Federal Fair Housing Act which includes persons who have mental illness and who have no restrictions on their ability to evacuate - the standards as written by the OSFM will have an adverse impact on the availability of housing stock. How should this be handled?

    The OSFM is familiar with the Federal Fair Housing Act. First, it should be realized that the OSFM adopts the Life Safety Code as published by the National Fire Protection Association. The OSFM does not "write" the content and requirements of the Life Safety Code. Also, the OSFM follows the classifications identified by the state licensing agency that requests the OSFM inspection. It is suggested that you address your questions regarding the FFHA in writing to the OSFM, or more appropriately, to DHS.

  7. What will happen if there is a sleeping accommodation that only has a partial wall?

    Sleeping rooms are required to be separated from corridors by walls. These walls are required to have a fire protection rating, or in some cases be reduced to only resist the passage of smoke. However, in both cases, the walls are required to be of solid material, without openings (e.g., air transfer grills, louvers, open transoms, etc.). Therefore, if client sleeping rooms are constructed of only "partial" walls that do not fully separate the sleeping room from the corridor, the arrangement would not be compliant with Life Safety Code requirements. It should be noted that this pertains to "client" sleeping rooms. Sleeping rooms for staff are allowed to be open to corridors.

  8. Are locks permissible?

    This depends upon the location and type of lock in question. Closets must have door hardware that allows someone to open the door from within the closet (to ensure that someone could not be locked in the closet by someone outside the closet). Bathroom door locks must be designed to allow opening of the door from outside the bathroom (to ensure that someone could not lock themselves in the bathroom). Rooms, or paths through rooms, that serve to lead an occupant to a primary or secondary means of escape cannot be locked in a manner that would prohibit use of the escape path. Exit doors from occupancies may be locked, but only two motions are allowable to open the door (e.g., turning of a door knob and unlatching a chain). It is not permissible to have locks on doors in the escape path that require an occupant to retrieve a key for use in the lock or any other form of special tool to unlock the door. Any door may be locked against entry from the outside of the building (the Life Safety Code is not concerned with people attempting to enter the facility, only escape from within the building to the outside).

  9. Some cities require that an exit door, with a window in close proximity, must be locked with a key. Feedback?

    The need to locate or obtain a key from another location to open the lock on a door that is in the escape path of occupants is not compliant with Life Safety Code requirements.

  10. How would the SFM rate residential settings which are studios or SRO apartments within a common living space?

    It is assumed that this question is meant to address individual apartments or single-room occupancies within larger apartment or SRO buildings. In such cases, the Life Safety Code prescribes that the apartment where residential board and care clients (those who receive personal care services) reside must comply with the "small residential board and care occupancy" requirements and that the common areas of the building (corridors, stairways, outside paths, etc.) must comply with the apartment building occupancy requirements of the Life Safety Code.

  11. What is the name of the administrator whom we should contact with questions?

    For northern counties in Illinois the regional administrator in Chicago is:
    Larry Matkaitis
    100 W. Randolph St.
    Suite 4-600
    Chicago, IL 60601
    Phone: (312) 814-2693

  12. Pertaining to enclosed stairwells - the focus has been on stairwells that are the primary means of egress. How would the OSFM view a duplex which has a shared unenclosed stairwell, but each floor has its direct exits to the outside? Would the stairwell need to be enclosed?

    The Life Safety Code requires that the primary means of escape not be exposed to a vertical opening. Therefore, if the clients who occupy each side of the duplex were provided with primary escape paths (direct exits to the outside) that do not expose them to the unenclosed stairway that is shard by the two units, then the common stairway could remain unenclosed.

  13. If a window leads to a patio or balcony, do we need to enclose the stairwell?

    Windows can only be used as the "secondary" means of escape and not the "primary" means of escape. The presence of, or arrangement of, windows, does not have an effect on whether an interior stairway would need to be enclosed. If the interior stairway serves as the primary means of escape, or exposes the primary means of escape, it must be enclosed unless the building is protected throughout by an automatic sprinklers system regardless of where the windows lead.

  14. Does a lower level roof count as a secondary means of escape?

    If the roof can be accessed by clients and they can stand on the roof (meaning it is flat) just as they would be able to stand on an outside balcony, and the roof is either within 20 ft. of ground level or accessible to the fire department, it is acceptable as a secondary means of escape (not as a primary means of escape).

  15. Do 6 fire drills yearly (of which 2 must be conducted during sleeping hours) apply to all sites, including SROs?


  16. What if there is no staff on the night shift?

    Drills must still be conducted during all shifts, including during sleeping hours. The evacuation capability rating of the facility must be based upon the slowest egress times. If no staff is present on the night shift to assist with evacuation, this may indeed present the slowest evacuation time that will be experienced.

  17. Is there a specific hour in the code that constitutes sleeping?

    No, the Life Safety Code does not define specific time periods as "sleeping time" or "sleeping hours".

  18. If looking for companies to install sprinklers, what would you recommend?

    The OSFM recommends a sprinkler company that is licensed by the OSFM. Although the applicable state statute does not require that installers of smaller sprinkler systems such as those installed in one- and two-family dwellings be licensed, by picking a licensed sprinkler contractor you are assured that there is licensed professional engineer on their staff. For sprinkler contractors that only work on smaller sprinkler systems, and therefore, are not required to be state licensed, the OSFM recommends checking with local better business bureaus or local fire authorities to determine if they are familiar with the work of the contractor and/or any complaints about their work.

  19. If a site exceeds 16 residents, what section of the code will apply?

    The "Large Residential Board and Care" occupancy chapters of the Life Safety Code would be applicable.

  20. Transitional Living Facility - does it have a section/standards under the code?

    Transitional Living Facilities are classified a residential board and care homes by the Life Safety Code. In accordance with LSC definitions, if more then 16 clients are present, the facility is subclassified as a "large" residential board and care home. If the facility serves between 4 and 16 clients, then it is subclassified as a "small" residential board and care home. If the facility serves three or less clients, then it would be classified as a single- and two-family dwelling. If located within an apartment building, the apartment where the clients reside would be classified as residential board and care and the common areas of the building would need to comply with the Life Safety Code's apartment building chapter