Life Safety Code Issues to Consider when Converting Spaces for ICU and Overflow COVID-19 Patients

In converting non-healthcare spaces to house intensive care and overflow emergency patients afflicted with COVID-19, there are multiple life safety factors that need to be addressed and reviewed. One major to be sure not to overlook is the treatment of essential electrical systems. Although spaces may be equipped with a generator, it may not meet the important requirements of NFPA 99 and NFPA 110 and should not be relied on for critical patient care. In these situations, an additional temporary generator and essential infrastructure should be installed to meet these requirements.


For healthcare occupancies NFPA 99 requires classification an area in the event of power failure based upon risk of injury to patients, staff, and visitors. Based upon this risk assessment, a facility is classified as Category 1, 2, 3, or 4. COVID-19 treatment / recovery areas should be classified as Category 1 or 2 as described below.



Essential infrastructure required to support COVID-19 patients should include the following to ensure a fully functioning electrical system:

  • Emergency Power Generator (sized to handle the anticipated load)

  • Automatic transfer switch(es) to switch between the utility and generator power

  • Power distribution wiring and branch distribution panelboards

In converting non-healthcare spaces to a healthcare use, the layout of those spaces often needs to be revised as well. To ensure proper support for emergency egress, emergency lighting and exit signage should be reviewed against the new layout. Specifically, emergency egress lighting is required to provide a minimum average of 1 foot-candle along the entire path of egress. This light level requirement may require the installation of additional egress lighting. Egress lighting is also required to turn on within 10 seconds of loss of power; emergency start can be accomplished either by battery backup or direct power from a life safety generator. The capacity and occupant load of all converted spaces should be also be re-calculated to ensure code compliance of doorways and corridor widths.


Critical healthcare occupancy groups, like Use Group I-2, have a number of specific additional requirements for egress and construction. These code requirements can make the difference between life and death for patients incapable of self-preservation. Consider the services of a professional code consultant to help with any of your non-healthcare conversion spaces.


Written by:

Kori Terray, PE Steven Southard, PE, LEED AP Vernon Woodworth, FAIA, Electrical Group Leader Fire Protection Group Leader LEED AP

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