Nikki James Zellner
CO detection requirements on daycare, school and college campuses in the United States
The big question: why are there no federally mandated carbon monoxide detection requirements in schools? The not so simple answer: different codes for different folks.
When it comes to campuses of any kind, we're (unfortunately) not saying "let's protect every human equally for all the things" – instead, what we're saying is: based on the type of building this is, what can we assume will happen here, and based on those assumptions, how should this building be constructed and prepared for emergencies?
Building code terms to understand
Occupancy Types: Buildings have two occupancy types: New Occupancies (new construction) and Existing Occupancies (existing structure). This means those in fancy new buildings will have different requirements than those in older, existing buildings.
Occupancy Classifications: Buildings are classified into categories (and sometimes subcategorized) based on their use. Different code organizations will use differing classifications, see Term 3.
Code Reference: There is no 'one code' used by every state. Instead, states can choose to use the code recommendations made by trusted organizations such as the International Code Council (responsible for International Fire Code (IFC) and International Building Code (IBC), or the National Fire Protection Association (NFPA); or they can choose to use *part* of those recommendations and create their own state building or fire code. In fact, counties or municipalities can create their own local codes, to go over and above the code required by their state.
Code Enforcement: Similar to the codes themselves, not all states use the same type of code enforcement. Some states have state-wide code enforcement officers to inspect all state buildings, and some only use local enforcement strategies (like the region's fire marshal).
Breaking down classification types
Above, we discussed the major classification categories for buildings, these are the primary ones found on US daycare, school and college campuses (using IBC classifications):
• Assembly (Group A)– the building, or a portion of it, is used for the gathering of people for purposes such as civic, social or religious functions; recreation; food or drink consumption; or awaiting transportation. It is broken into five subgroups A1 - A5. On campuses of any kind, this means Assembly occupancies would likely be in the form of: theaters or performance halls, cafeterias, museums or art galleries, chapels, libraries, and recreational centers (like gyms, courts and stadiums).
• Business (Group B) – the building, or a portion of it, is used for office, professional or transactions. Business occupancies will primarily be on college campuses and would include things like admin buildings, classrooms, labs and health facilities.
• Educational (Group E) – the building, or a portion of it, is used by 6 people or more at one time for educational purposes through the 12th grade, or daycare facilities with five or more children over 2.5 years old. This is where most public and private Pre-K through 12th grade school campuses would fall.
• Institutional (Group I) – the building, or a portion of it, is used for custodial care for people who are health or age-harbored (or whom live in a supervised environment). This would apply to things like adult day cares or child daycares caring for children under 2.5 years of age.
• Mercantile (Group M) - the building, or a portion of it, is used to display and sell merchandise (and involves stocking goods, wares, etc) to the public. This would apply to things like campus bookstores or gift shops.
• Residential (Group R) – the building or structure, or a portion of it, is used for sleeping purposes. Since there are four subcategories of this group, the one most likely to be on college campuses (or boarding schools) will be Group R2, which includes apartments, dormitories, fraternity and sorority houses.
• Utility/Misc (Group U) – the building or structure is accessory in nature and does not 'fit' into the major categories above. This would apply to things like sheds, barns, greenhouse, ag buildings, etc.
Again, these are based on International Building Code (IBC) classification types (and I didn't list all of them, only the ones most likely to occur on campuses). If your state uses a different code to pull from, you may see different classifications. Here's a good article on the differences between IBC and NFPA.
How to find your local carbon monoxide requirements
Unfortunately, as of today, there is no easy way to do this. No one organization has made this easy, and those boasting "statewide listings" haven't been updated in years. So here's step by step instructions on finding yours.
Start with the state you live in. See what Building/Fire Code they reference statewide (it would say something like International Fire Code, NFPA 72, or the [State's Name] Fire Code. Now find the edition (this is the year the code was "published" for use). Also check with your municipality to see if their fire/building codes are different than the state's. If so, use that code if your school campus is located in that city/county. Start with the Director of Building Codes (state) or Building Code office (municipal), they can help.
Next, identify the Occupancy Type of your school/campus. This will be either NEW (it's been built SINCE the year that code was published) or EXISTING (the structure/building in question was built BEFORE the year that code was published).
Now, identify the Classification Category it is sorted into (based on the Code Referenced, this is what the building is used for).
Then, identify how your code is enforced based on what code you're using (which determines who inspects the buildings, equipment and how often).
An example, using my child's commercial daycare at the time of their CO poisoning, the following requirements were in place at the time:
It was an Existing I-4 Occupancy using code pulled from IFC 2015 with statewide incorporation by reference and enforcement.
This is why I say that it's time to kick old code to the curb and understand when it comes to Carbon Monoxide that LIFE is LIFE, no matter when the building was built, or what it's used for.
Our hope with CO Safe Schools is to create a carbon monoxide regulation database that makes it EASY for everyday people (not just code-savvy folks) to see where and how they're protected – and quickly link them to key contacts. Stay tuned as we build that out!