Question:  I have been told that the business occupancy portions of my health care facility must comply with the annual testing in NFPA 101, Section 8.3.3.1 as well as the additional testing requirements in Section 7.2.1.15.  Section 7.2.1.15 covers testing of special door hardware devices, such as doors utilizing panic hardware, door with hardware-release of electrically locked egress door assemblies, and doors equipped with special locking arrangements.  Is this true? 

Response:  If your facility is in a jurisdiction where a newer edition of the Life Safety Code is adopted, 2015 edition or later, then doors in most occupancies, other than health care and ambulatory health care, are required to meet the provisions in Section 7.2.1.15.  Note that the heath care related occupancy chapters, Chapters 18 through 22, still do not dictate compliance with Section 7.2.1.15.  Because the Centers for Medicare and Medicaid Services (CMS) adopted the 2012 edition of NFPA 101, Life Safety Code®, effective July 5, 2016, and this is the code enforced for accreditation, the requirement for business occupancies to meet the special testing requirements in Section 7.2.1.15 do not apply for accreditation or certification.  It would only be where the State or local jurisdiction has adopted a newer edition, that compliance with a newer edition of NFPA 101 in the non-health care occupancies of the facility would be appropriate.