Community Living
Arrangement (CLA)
JEFF YODER
GWINNETT COUNTY
FIRE & EMERGENCY SERVICES
COMMUNITY RISK REDUCTION
PREVENTION AND ENFORCEMENT
Community Living Arrangement (CLA)
Community Living Arrangement (CLA)
CLA Definition
 Chapter 120-3-3 Rules and Regulations for the State
Minimum Fire Safety Standards
 120-3-3-.03 (6)






Any residence
being operated for profit or not
subject to being licensed by the state
to provide or arrange for the provision of daily personal
services, support, care, or treatment
for two or more adults
not related to the owner or manager by blood or marriage, and
CLA Definition
 Chapter 120-3-3 Rules and Regulations for the State
Minimum Fire Safety Standards
 120-3-3-.03 (6)



Whose residential services
financially supported, in whole or in part,
by funds designated through the Department of
Human Services, Division of Mental Health,
Developmental Disabilities, and Addictive Diseases.
Why CLA Occupancy Classification?
 Why not just use
Residential Board and Care
Chapters?
 Political Issues…
 Main issue: they are usually
different!




Most Residents Incapable of
Self-Preservation.
Usually Three of Four
Completely Incapable.
Rely more on Protect in Place
Evacuation Methods.
Not in facilities designed to
Protect in Place.
Case Study
Residential Board and
Care
Gwinnett County
One Fatality
Rock Springs Fire
Who Inspects CLA’s?
 Do we treat them like Residential Board and Care?
 Does your jurisdiction inspect at seven clients? Like
the state (Title 25) for Personal Care Facilities?
 Does your jurisdiction inspect at four clients? Like
the Life Safety Code for Residential Board and Care?
 Does your jurisdiction inspect all CLA’s? Two or
more clients like 120-3-3?
Opinion: Because the clients are often dependent on Staff
Training, Drills, Construction, and Fire Protection
Systems, to survive a fire, all CLA’s should be inspected
by the AHJ, including very small facilities.
Who Inspects CLA’s?
 DCH requires fire
 DCH keeps a list of fire
inspections prior to
licensing CLA’s.
 Who inspects them if not
the AHJ?
inspectors who have
provided their credentials.
 Clients are to contact an
inspector from the list if
the AHJ does not inspect
the facility.
 Inspectors are Private
Contractors with the CLA.
Side Question: The same process
is used for Res. B&C under 7, or
under 4, depending on jurisdiction.
If less than 4 clients, what code is
used to perform the inspection?
CLA - Life Safety Code Application
 1-4 CLA Residents - LSC Chapter 24
 One and Two Family Dwellings/Community Living
Arrangements (as modified by 120-3-3)
 New and Existing Facilities
 New Section 24.4 Community Living Arrangements


Added by 120-3-3
Requirements in addition to Chapter 24 for CLA’s.
CLA - Life Safety Code Application
 New Facilities 5 or More Residents.
 LSC Chapter 32 (as modified by 120-3-3)
 5-6 CLA Residents – Section 32.2 Small Facilities
 7 or More Residents – Section 32.3 Large Facilities
 All Facilities – Sections 32.1, 32.4, & 32.7.
 All CLA’s (Small and Large) – New Section 32.5
 Added by 120-3-3
 Requirements in addition to Chapter 32 for CLA’s
 If Conflicts, Section 32.5 Prevails
Life Safety Code Application
 Existing Facilities 5 or More Residents.
 LSC Chapter 33 (as modified by 120-3-3)
 5-6 CLA Residents – Section 33.2 Small Facilities
 7 or More Residents – Section 33.3 Large Facilities
 All Facilities – Sections 33.1, 33.4, & 33.7.
 All CLA’s (Small and Large) – New Section 33.5
 Added by 120-3-3
 Requirements in addition to Chapter 33 for CLA’s
 If Conflicts, Section 33.5 Prevails
How Many Facilities?
 DCH Regulations Limit




CLA’s to 6 Clients
(Exceptions)
Most CLA’s have 4 or less
residents. (Chapter 24)
19 Licensed for 5 residents.
6 Licensed for 6 residents.
1 Licensed for 9 residents.
As of October 20, 2014
Future Code Modifications?
 Many similarities in Sections 24.4, 32.5 and 33.5.
 Some discussion, and a possibility of,
 Placing all CLA Requirements in Chapter 24.
 To simplify!
Possible 120-3-3
Change
NFPA 101, Chapter 24 (CLA)
 120-3-3 Modifications
 New Title: One and Two Family Dwellings/
Needed
120-3-3
Correction
Community Living Arrangements
 Add New 24.1.1.1.1: Establishes life safety requirements
for CLA’s for 1 through 4 individuals…
 Add New 24.1.1.5: New Subclass, CLA’s with 1-4*
residents, shall meet the requirements for 1&2 Family
Dwellings and,
 The additional requirements of (new) Section 24.4.
* CLA’s licensed for more, but currently with only 1 resident.
NFPA 101, Chapter 24
 24.2 Means of Escape
Requirements
 24.2.1 Chapter 7 Shall
Not apply…
 Means of Escape: … Does
not conform to the strict
definition of Means of
Egress but does provide
an alternate way out.
Means of Escape
Primary Means of Escape
 24.2.2.2
 Door, Stairway, or
Ramp
 Providing a means of
unobstructed travel
 To the outside,
 At street or finished
ground level.
Means of Escape
Secondary Means of Escape
 24.2.3.1 Door, Stairway,
Passage, or Hall,
 24.2.2.3.2 Through an
adjacent non-lockable
space,
 Independent and
remote of the Primary
 To street or ground level
Means of Escape
Secondary Means of Escape
 24.2.2.3.3 Outside
Window or Door
 Operable from the
inside without tools,
keys, or special effort.
 Meets dimensional and
other criteria.
NFPA 101, Chapter 24
 24.2.2.1.1 Sleeping
Rooms and Living areas
shall have at least one
primary and one
secondary Means of
Escape.
 120.3.3 Deletes
24.2.2.1.2(2)
 Allowed an exception to the
Secondary Means of Egress
in sprinklered buildings.
 Only remaining exception is
a door leading directly to
the outside at, or to ground
level.
NFPA 101, Chapter 24
 24.2.4.1.1 (new) Doors in
Means of Escape in
CLA’s must be 32” wide.
 24.2.4.4 Closet door
latches open from the
inside…
 24.2.4.5 Bathroom doors
open from the outside…
 No door in any means of
escape shall be locked
against egress when the
building is occupied.
NFPA 101, Chapter 24
 24.3.5 Sprinklers – All




New CLA’s are Required to
be Sprinklered per SFMO.
Not Modified by 120-3-3
24.3.5.1 All new one and
two family dwellings shall
be protected throughout
by an approved automatic
sprinkler system…
13R and 13D OK
Discussion about a Mod.
Specifying all CLA’s …
Possible
120-3-3
Change
NFPA 101, Sections 24.4, 32.5, & 33.5
 120-3-3 additions in each chapter, (24.4 and




32/33.5) specifically for CLA’s, are almost the same.
Refer to the Comparison Chart for details.
There are 26 CLA’s State Wide that fall into Chapters
32 & 33. (5 or more Clients)
One “Large Facility” under 32/33.3. (more than 6)
Most are 1-4 residents and covered in Chapter 24.
Sections 24.4, 32.5, & 33.5 Comparison
 General
 Requirements in 24.4 & 32/33.5 are in addition to
the applicable requirements in each Chapter.
 This section will prevail if conflicts.
Sections 24.4,
32.5, & 33.5
Comparison
Address Identification
Sections 24.4, 32.5, & 33.5 Comparison
 Number of Means of
 Requirements are the
Escape
 1 Primary, 1 Secondary
same as Chapter 24.
 Sections 24.2.2.1.1 &
24.2.2.1.2
 Modified in Sec. 32.5.3.1,
32.5.3.1.1 & Sec. 33.5.3.9
& 33.5.3.9.1.
Sections 24.4,
32.5, & 33.5
Comparison
Exits for Mobility Impaired
2 Remote Accessible Exits Required
Sections 24.4, 32.5, & 33.5 Comparison
 Bedrooms – Separation




Separated from halls,
Corridors, and other
rooms.
½ hour FireResistance Rating.
Sleeping Rooms 1 ¾
in. Solid-bonded
Wood Core Doors.
Vision Panels, Wired
Glass.
Sections 24.4, 32.5, & 33.5 Comparison
 Bedrooms Below Ground



Not more than ½
room height below
ground level.
Adequate natural light
and ventilation.
Two useful means of
egress. (Escape?)
Sections 24.4,
32.5, & 33.5
Comparison
Bedroom doors capable of closing.
Doors not less than 32 In. Wide
Sections 24.4, 32.5, & 33.5 Comparison
 Residents needing
assistance with
ambulation:


Bedrooms with access
to a ground level exit to
the outside, or,
Bedrooms above ground
level with access to exits
with ramps or lifts.
Sections 24.4, 32.5, & 33.5 Comparison
 Bedrooms may have
locks on doors provided:


Occupants and staff
have keys.
Double cylinder locks
(keys on both sides)
are prohibited.
 Exterior doors equipped
with locks that do not
require keys to open the
door from the inside.
 Gwinnett Rock Springs
Fire – May have made a
difference.
Sections 24.4, 32.5, & 33.5 Comparison
 24.4.4.1 A fire alarm
Meeting the minimum
requirements for Single
and Multiple Station
alarms and Household
fire alarm systems per
NFPA 72 shall be
installed.
Sections 24.4, 32.5, & 33.5 Comparison
 Chapter 29 in NFPA 72
 NFPA 72, 3.3.105.2
Household Fire Alarm
System:




System of Devices,
Including a Fire Alarm
Control Unit,
To produce an alarm
signal in the household,
To notify residents to
evacuate.
Sections 24.4, 32.5, & 33.5 Comparison
 Smoke alarms in
accordance with NFPA
101, 9.6.2.10.
 All levels, including
basements but excluding
crawl spaces and
unfinished attics.
 Additional smoke alarms
for living areas.
 Strobe alarms as needed.
Sections 24.4,
32.5, & 33.5
Comparison
CO Detectors: Natural Gas, LP Gas,
heating oil, or solid Fuel burning
fireplace.
Sections 24.4, 32.5, & 33.5 Comparison
 Portable Fire
Extinguishers in
accordance with 9.7.4.1
 At least on 2A rated ABC
extinguisher on each
occupied floor.
 Inspected and
Maintained Annually by
licensed company.
 Monthly inspection by
Staff.
Sections 24.4,
32.5, & 33.5
Comparison
Portable space heaters not allowed.
Fixed screens used with fireplaces,
stoves, and fixed heaters.
Sections 24.4,
32.5, & 33.5
Comparison
.
Water Temperature Monitor or
scald valve as needed. (120 Degrees)
Sections 24.4, 32.5, & 33.5 Comparison
 24.4.7.1 Staffing
 “The CLA shall have as
many qualified and trained
employees on duty as shall
be needed to safeguard
properly the health, safety,
and welfare of residents
and ensure the provision of
services the residents
require to be delivered in
the CLA.”
DCH Rules and Regulations
 290-9-37-.14 Staffing
 “The CLA shall have as many qualified and trained
employees on duty as shall be needed to safeguard
properly the health, safety, and welfare of residents
and ensure the provision of services the residents
require to be delivered in the CLA.”
 “The Community Living arrangement must maintain
a staffing ratio sufficient to ensure that all residents
can be evacuated from the residence within three
minutes.”
Sections 24.4, 32.5, & 33.5 Comparison
 24.4.7.1.1
 Staff Shall be Trained
 Show competence in Fire
Safety and Evacuation
Procedures.
 Residents shall not be
considered Staff.
 Training shall comply
with IFC Chapter 4 . (As
Modified)
 New in 120-3-3!
IFC Chapter 4 (120-3-3 Modifications)
 404.2 (9) Group R-3 care facilities where required by
the AHJ.
 406.2.1 Care Giver Training.






5 Hour Initial Fire Safety Training…
For all Administrators, Directors, Operators, and Staff…
… Community Living Arrangements …
Curriculum and instructors approved by SFMO…
Within 90 Days of Licensing…
5 Hour Initial Training, 2 Hour Refresher every 3 Years.
 Previously only applied to Day-Care Centers
Sections 24.4, & 33.5 Comparison
 Evacuation Capabilities
24.4.7.2 (1-4) and 33.5.7.2


All Facilities 1-4
Residents
Existing Facilities, 5-6
Residents
 CLA shall maintain a
staffing ratio to ensure that
all residents can meet a
prompt (3 minutes or
less) evacuation capability,
Sections 24.4, & 33.5 Comparison
 Residents who cannot …
shall be provided with a
minimum of one
dedicated employee
whose primary
responsibility is to
provide evacuation of the
resident…
 The dedicated employee
shall be in close
attendance at all times.
Sections 32.5 Comparison
32.5.7.2
Evacuation Capabilities.
 CLA shall maintain a
staffing ratio to ensure that
all residents can,
 successfully respond to a
fire or other emergency
 using self- preservation
or assisted preservation
measures.
 (Defined In 120-3-3-.03 (5))
New Facilities, 5 or More
“Prompt” or “Three
Minutes” Not Specified
Discussions to change 120-3-3
to match others since DCA
specifies three minutes for all
CLA’s.
Possible
120-3-3
Change
Sections 32.5 Comparison
 32.5.7.2 Evacuation Capabilities (New Facilities)
 Residents who cannot … shall be provided with a
minimum of one dedicated employee whose primary
responsibility is to provide evacuation of the
resident…
 The dedicated employee shall be in close attendance
at all times.
Sections 24.4, 32.5, & 33.5 Comparison
 Fire Drills
 Conducted Quarterly on
Each Shift
 Two per Year During
Sleeping Hours
 Documented – Including
Staff Involved.
 Per IFC Chapter 4 (As
modified by 120-3-3)
Sections 24.4, 32.5, & 33.5 Comparison
 Procedures. Established (written) Procedures For:
 Alerting and Caring for Residents in Emergencies
 Evacuating Residents to Safety
 Evacuation Plan with Clear Instructions
 Each Sleeping Room Shall Have a Secondary Exit
(should be) Means of Escape.
 May be a Door or Window.
 Per IFC Chapter 4 (As modified by 120-3-3)
Possible
120-3-3
Correction
Emergency Procedures
Domestic Hood Suppression
 32/33.2.3.2.6
 Require Hood
Suppression.
 Exceptions


Sprinklers /AHJ
Small Facilities
with Prompt
Evacuation.
 Modification to
Chapters.
Sprinklers in CLA’s 1-4 Residents
 24.3.5.1 (New) All new
one and two family
dwellings shall be
protected throughout by
an approved automatic
sprinkler system in
accordance with 24.3.5.2.
 (Effective after 1-30-14)
Sprinklers in CLA’s 1-4 Residents
 Existing CLA’s with 1-4 –
requirements at the time
of approval. Not required
in NFPA 101 (2000 ed.)
 SFMO Considering
modification to “All
CLA’s” or “All CLA’s
approved after 1-30-14”.
Possible
120-3-3
Change
Sprinklers in New CLA’s 5-6 Residents
 32.2.3.5.1 All facilities,
other than those meeting
the requirement of
32.2.3.5.2, shall be
protected throughout by
an approved automatic
sprinkler system,
installed in accordance
with 32.2.3.5.3, using
quick response or
residential sprinklers.
 32.2.3.5.2 In
conversions, sprinklers
shall not be required in
small board and care
homes serving six or
fewer residents, when all
occupants have the
 ability as a group to
move readily to a
 point of safety within
3 minutes.
Sprinklers in New CLA’s 7 or More
 32.3.3.5.1 All buildings
shall be protected
throughout by an approved
automatic sprinkler system
installed in accordance
with 9.7.1.1(1) and provided
with quick-response or
residential sprinklers
throughout .
 9.7.1.1(1) Full NFPA 13
system.
Sprinklers in Existing CLA’s 5-6 Residents
 33.2.3.5.3.7 (as modified by 120-3-3) All slow and
impractical evacuation capability facilities shall be
protected throughout by an approved, supervised,
automatic sprinkler system installed in accordance
with 33.2.3.5.3.
 33.2.5.3.7.1 Attics used for Living, Storage, or Fuel
Fired Equipment must be sprinklered.
 33.2.5.3.7.2 Other Attics: Heat Detection, or
Sprinklers, or Limited or Non-combustible
Construction, or Fire-Retardant-Treated Wood.
Sprinklers in Existing CLA’s 7 or More
 Most existing large facilities require sprinklers from
past SFMO rules and regulations. May depend on
dates.
 NFPA 101 (2000) required new large facilities to be
sprinklered.
 33.3.3.5.2 requires existing “Impractical” Facilities to
be sprinklered, however, an inadvertant SFMO
Modification may remove the requirement from
NFPA 101 (2012).
Possible
120-3-3
Correction
Additional Sprinkler Requirements
 Numerous related
requirements and
exceptions.
 Numerous requirements
for ITM of systems in Small
Facilities that are normally
found in NFPA 25.
 Hybrid coverage of attics,
bathrooms, and closets.
 Do very thoughtful plan
review for sprinkler
requirements.
Domestic Hood Suppression
 32/33.2.3.2.6
 Require Hood
Suppression.
 Exceptions


Sprinklers /AHJ
Small Facilities
with Prompt
Evacuation.
Summary
 New Occupancy Classification
 Code with modifications can be very confusing.
 May need to bolster sprinkler requirements with
local ordinance. (but…)
 The residents of CLA’s can be one of our most
vulnerable populations.
 Additional safeguards have been put in place by the
SFMO and DCH.
 CLA’s need the local AHJ to conduct legitimate
inspections.
Thanks To!
United Cerebral Palsy
Diane Wilush
Executive Director
United Cerebral Palsy of
Georgia
United Cerebral Palsy of
South Carolina
Thanks – Questions?