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NFPA 101 Code Changes for Aviation Facilities

The new editions of any code or standard often bring significant changes. The 2018 edition of NFPA 101, Life Safety Code has several changes to life safety at aviation facilities. Though there were multiple text deletions and revisions, there were several instance in which new material was added. Listed below, are the most significant revisions that may require action or operational changes.



  • Terminology changed from “air traffic control tower” to “airport traffic control tower” (11.3.4)
  • Language changed to clarify permissible uses of tower accessory levels. Language now clearly states, “uses that support tower operations”. (11.3.4.2)
  • Added two additional requirements for allowance of a single exit (11.3.4.4.1):
    • Fire alarm system is required in accordance with 9.6
    • Smokeproof enclosures are to be provided in accordance with 7.2.3
  • New requirement has been added for the provision of an emergency command center (11.3.4.8).
    • Only applies to towers having an occupiable story 75’ above the lowest level of fire department access
    • Provides a list of items and control functions that are to be located within and controllable from the emergency command center
  • New requirement has been added for the development and provision of an Emergency Action Plan.
    • The EAP should be developed and written in accordance with the guidance of NFPA 101:4.8.
    • Annual fire drills for tower employees are required.
    • Tower employees are to receive annual training on the emergency action plan

Two other sections of the Life Safety Code specifically apply to aircraft storage and servicing areas.  These are Chapter 40, Industrial Occupancies and Chapter 42, Storage Occupancies.  While their are no changes to the aviation specific sections of these chapters the chapters, as a whole, do have a few changes that should be observed.

  • During construction, alteration, or demolition operations the requirements of NFPA 241 must be met. Sections 101:40.1.1.6 and 101:42.1.1.4 provide a directional pointer to this standard as referenced in NFPA 101:4.6.10.2.
  • If hazardous materials are used the additional egress requirements of NFPA 101:7.12.2 must be met. (40.2.11.3; 42.2.11.3)
  • Integrated testing is required in accordance with NFPA 101:9.11.4, which points to NFPA 4. (40.7.4; 42.9.4)

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