Review Process for Child Care Centers
When performing work that is considered construction, remodeling, or an addition to a State-regulated Child Care Center, plans and specifications must be submitted to the State of Michigan Bureau of Fire Services (MBFS) in accordance with this guideline.
The guideline is intended to outline basic requirements and to show how the plan review and inspection process is handled at the University, including interaction between the University and MBFS. The guideline is NOT intended to provide specific requirements for construction of buildings or installation of required life safety systems or equipment. All work must be performed in accordance with the State of Michigan Department of Human Services Licensing Rules for Child Care Centers, the Codes and Standards that are referenced by the Licensing Rules, and any other applicable law, rule, code, or standard.
Plan review submittals to MBFS for Child Care Centers located in General Fund buildings must be coordinated through Ms. Jacquline Jeffery in AEC. Plan review submittals to MBFS for Child Care Centers located in buildings operated by the University of Michigan Hospitals and Health Centers must be coordinated through Ms. Heather Lewis in UMHS FP&D. Copies of all plans and specifications that are sent to MBFS by either AEC or FP&D must also be sent to OSEH Fire Safety Services for review.
- Determine Applicability
- Plan Submittal
AEC maintains a list of buildings which contain Child Care Centers. The list can be found at the end of the "Codes and Regulatory Agencies" document published on the AEC website. For University of Michigan Hospitals and Health Centers facilities, there is also a "Supplemental Codes and Regulatory Agencies" document published on the FP&D website. If the project involves the construction of a new Child Care Center, or the introduction of a Child Care Center into an existing building, AEC and/or FP&D, as well as OSEH Fire Safety Services must be consulted prior to beginning the design process.
If it is determined that a building or space contains an MBFS-regulated Child Care Center, it must then be determined if the scope of work will require a plan review submittal. MBFS requires that plans and specifications be submitted for any project involving construction, remodeling, or an addition to the building. Plans and specifications must also be submitted if an existing building is converted to use for a Child Care Center. Submittals are NOT required for work that is limited to maintenance functions or cosmetic remodeling.
The Licensing Rules for Child Care Centers do not define the terms "remodeling," "cosmetic remodeling," or "maintenance." However, MBFS recognizes the following definitions of these terms:
"Remodeling" is defined as an alteration or change of a fire-rated assembly, or the installation of new equipment required by the Licensing Rules for Child Care Centers.
"Cosmetic Remodeling" is defined as surface changes solely to the wall, floor, and ceiling that do not decrease the fire rating of the wall, floor, or ceiling, including the replacement of windows and doors.
"Maintenance" is defined as repair required to keep a building and its component parts in an operative condition at all times, including the replacement of its component parts when, for any reason, the component parts are no longer dependable. "Maintenance" does not include remodeling.
Note: If you have determined that the scope of work for your project involves ONLY "cosmetic remodeling" or "maintenance," a submittal to MBFS is not required. However, a submittal to OSEH Fire Safety Services may still be required, in accordance with the Fire Safety Review Process for Non-Regulated Facilities and Projects Outside the Scope of MBFS Review.
If you have determined that the scope of work for your project involves construction, remodeling, or an addition, plans and specifications must be submitted to MBFS. Plan review submittals must contain ALL of the following, if they are applicable to the scope of work being performed:
- A project description, including the architect’s or engineer’s project number, the square footage of the new building, addition, or remodeled area, the square footage of an existing building, and a written summary of the project scope.
- Plans must be drawn accurately and to scale.
- Exterior dimensions, interior dimensions, exit locations, and room usage must be designated.
- The type of building materials which are to be used for construction, i.e., masonry or frame.
- The structures total number of floors, including the basement.
- The interior finish of the walls and ceilings, i.e., drywall, paint, paneling.
- Door size, type, and direction of swing, type of door hardware, i.e., metal, wood, labeled, etc.
- Type of furnace and water heating equipment, i.e., fuel fired, electric.
- Fire detection or suppression system to be provided, if any.
- Fire extinguisher type and location.
- Areas of the building to be used for child care.
- Approved design numbers for all fire related assemblies.
Note: Plans for work involving the practice of architecture or engineering must be sealed by a registered architect or engineer, if the contemplated total expenditure for the project exceeds $15,000. If the contemplated total expenditure is less than $15,000, plans and specifications must still be submitted for review, but they are not required to be sealed.
Special rules apply to construction, renovation, and additions that affect fire alarm systems, fire suppression systems, boilers and other fuel-fired equipment, and installation or modification of electrical equipment or wiring. More information regarding these rules, and required submittals, are below.
- Construction barriers and means of egress during construction:
The Licensing Rules for Child Care Centers do not contain any specific provisions regarding construction barriers or other safety requirements during construction or renovation. However, the Child Care Center is responsible for maintaining a safe facility at all times, and for developing and implementing fire and other emergency procedures. In general, MBFS will expect that a minimum 1-hour fire rated barrier be maintained between any occupied area of the building and any area undergoing construction or remodeling. MBFS will also expect that all exits from the occupied portion of the building be maintained free and clear of obstructions, and available for immediate use at all times. MBFS must be consulted prior to beginning any work that will affect the means of egress from a Child Care Center. If requested, OSEH Fire Safety Services will coordinate an on-site review with a representative from the MBFS.
- Separation of occupancies:
The Licensing Rules for Child Care Centers provide for the following:
R 400.5835 Multiple occupancy.
Rule 835. (1) Multiple occupancy of a building may qualify for licensure if the entire building does not present a life safety hazard. A center currently licensed in such a building may continue as long as such occupancies do not change in character.
(2) A building, part of which is used for hazardous operations or for occupancy that is unpredictable, such as taverns, garages, repair shops, and industrial operations, shall not be permitted for center use. However, an exception may be made for a vocational education center approved by the department of labor and economic growth.
In some cases, a construction or remodeling project will affect only a portion of a building that is separated from the Child Care Center. If it has been confirmed that the construction area is not going to be used for child care purposes, and is completely separated from the child care area of the building, submission of architectural plans and specifications to MBFS may not be required. Such projects should be reviewed with AEC and/or FP&D, along with OSEH Fire Safety Services, prior to the beginning of design. In some cases, a pre-design review meeting will be scheduled with a representative from the MBFS in order to assure that all parties share the same interpretation regarding the use of the building and the separation of occupancies.
Also, if the project involves any modification to a building’s fire alarm or fire suppression system, and the fire alarm or suppression system serves both the child care and non-child care compartments of the building, MBFS review will be required for these systems. MBFS will generally NOT review the submittal for compliance with code in the non-child care compartment, but WILL require that the certified firm responsible for the fire alarm or suppression system installation complete an FS-12A form, documenting that the installation in the non-child care areas will not adversely affect the normal required operation of the system serving the child care areas.
If a project involves a building containing two different MBFS regulated occupancies, such as Child Care and Dormitory or Child Care and Classroom space regulated by the Administrative Rules for New and Existing School, College and University Fire Safety, MBFS will review the project in accordance with the most restrictive requirements of the appropriate Administrative Rule and the Life Safety Code, as applicable. However, if the occupancies are separated with 2-hour or greater fire-resistance-rated construction, MBFS may choose to apply the Administrative Rules separately in each compartment. Projects involving these types of occupancies are obviously complex, and should always involve discussions with AEC and/or FP&D, OSEH Fire Safety Services, and MBFS as early in the design process as possible.
When a project involves renovations to a non-child care, separated compartment of a child care building, and MBFS has agreed that they will not conduct an architectural plan review, the plans and specifications must be submitted to OSEH Fire Safety Services in accordance with the Fire Safety Review Process for Non-Regulated Facilities and Projects Outside the Scope of MBFS Review.
- Projects involving fire alarm systems and/or fire suppression systems:
When a project involves installation of new fire alarm devices, installation of new fire suppression system(s), or modifications to existing fire alarm or suppression systems, complete shop drawings for the affected system(s) must be submitted to MBFS. MBFS requires that these drawings be prepared by a certified firm, in accordance with the requirements of the State of Michigan Fire Prevention Code. The University of Michigan Plant Department Fire Protection Shop is a State-certified firm, and can prepare the necessary drawings. If outside contractors are used for this work, they must be certified, and they are responsible for submitting shop drawings to MBFS. In either case, copies of the shop drawings must also be submitted to OSEH Fire Safety Services and Factory Mutual.
- Projects involving electrical work:
The Licensing Rules for Child Care Centers require that electrical systems and service for new child care occupancies, along with additions to existing child care occupancies, be inspected and approved by the “electrical inspection authority having jurisdiction.” The licensing rules also allow MBFS to require an electrical inspection when existing rooms or buildings are converted to child care use, or for any existing child care center. After MBFS has reviewed the plans and specifications for a project, they will send written instructions regarding the requirements for the electrical inspection.
In the case of the University, the Code Inspection Group in AEC is considered to be an acceptable inspection authority. All electrical work requiring an electrical code inspection must be inspected by an AEC Electrical Inspector, and a copy of their Final Electrical Inspection Certificate must be maintained at the Child Care Center at all times. A copy of the Final Electrical Inspection Certificate must also be available for the MBFS Fire Marshal Inspector at the time of the final MBFS inspection.
- Other equipment and systems:
The MBFS administrative rules call for certain work to be performed in conformance with specified regulatory requirements. You should be prepared to demonstrate that these requirements have been met, if such documentation is requested by MBFS.
- If a boiler is used, then it shall be inspected and a certificate provided, as required, by the Boiler Division of the State of Michigan Bureau of Construction Code within the Department of Labor and Economic Growth.
- New furnace and water heater installations shall be inspected and approved by the Department of Labor and Economic Growth inspectors or local mechanical inspecting authorities at the time of installation. In the case of the University, the Code Inspection Group in the Architecture, Engineering, and Construction Department is considered to be an acceptable local inspection authority. All mechanical work requiring an inspection must be inspected by an AEC Mechanical Inspector, and a copy of their Final Mechanical Inspection Certificate must be available at the time of the final MBFS inspection for the renovation or construction project. MBFS also requires that existing fuel-fired furnaces and water heaters in child care centers be inspected at least once every two years.
- Elevators, escalators, dumbwaiters, and moving walks must be installed and maintained in accordance with the State of Michigan Elevator Code. Any work related to this equipment should be coordinated with the University of Michigan Plant Department Elevator Shop.