Oxygen Tanks

Q: Can oxygen tanks be stored under a stretcher or on a wheelchair when no patient is present.?
Would this be considered in use?

A: Yes… As long as the wheelchair or gurney is designed to secure an oxygen cylinder, it may be placed there even when it is not in use. According to CMS S&C letter 07-10, oxygen cylinders secured in wheelchairs and gurneys are considered in use and not considered in storage, and do not have to be included when calculating the total amount of compressed gas stored per smoke compartment.

O2 Cylinder Storage

Q: Can full oxygen cylinders be stored in a hospital soiled utility room?

A: Yes… however, anything stored in a soiled utility room is considered soiled. That would require staff to clean the O2 cylinder before using it on a patient, and the likely hood of that happening every time is not very good.

Most surveyors will have a problem with full O2 cylinders stored in a soiled utility room because of that issue and would expect the hospital to have a policy or at least a written procedure on the proper cleaning of each cylinder before use.

It is best to not store full O2 cylinders in a soiled utility room. Now, empty O2 cylinders stored in a soiled utility room should not be a problem because they would not be used on patients.

Medical Gas Shutoff Valves

Q: As a hospital security assessor, I am concerned about the availability of hospital gases in Behavioral Health Units. It would be easy for a patient to pull the tab off the plastic covering on the window and tamper with the gases. Would it be permissible to install a clear locking door with hardened glass in place of the plastic panel and provide access to the locked box via scan card with the caveat that the door would automatically unlock open during a fire event?

A: One has to ask why would there be medical gases on a behavioral health unit? Do you treat acute-care patients there? However, if you have them there, then you need to deal with them.

Your question appears to address the medical gas shutoff valves, or zone valves as they are often called. According to NFPA 99-2012, section 5.1.4.8, zone valves have to be visible, accessible and readily operable from a standing position in the corridor. NFPA 99-2012 does not prohibit the use of special locking arrangements for access to the zone valves.

I think you have a legitimate concern, especially if you document this concern in a risk assessment. But I suggest you contact your authorities having jurisdiction, and ask them if it would be permitted. At a minimum, I suggest you ask:

  • Your accreditation organization
  • Your state agency in charge of hospital design and construction
  • Your local building authorities
  • Your state or local fire marshal

Door to Compressed Gas Storage Rooms

Q: I have an oxygen/med gas storage room that is attached to the hospital, and can only gain access to the room by way of the exterior of building. Does the room have to have a fire-rated door assembly?

A: Well… that depends. If the storage room contains 3,000 cubic feet or more of compressed medical gases, and the room is located indoors, then the room must be constructed with 1-hour fire-rated construction and the door to the room is required to be 1-hour fire rated if new construction, and 3/4-hour rated if existing conditions. (See 5.1.3.3.2(4) of NFPA 99-2012).

However, the intent of 5.1.3.3.2 is to separate the compressed gas storage room from the rest of the facility by requiring 1-hour fire rated barriers, and if the door opening to the storage room opens into the facility, one could easily understand why a fire-rated door is required. However, if the door to the storage room opens to the outdoors (i.e. receiving dock) then one could make a point that the door is not required to be fire-rated, because there is no separation between the storage room and the rest of the facility at that point.

But the problem is, NFPA 99-2012 section 5.1.3.3.2 does not say that and does not appear to have any exception for a door to the storage room that opens to the outdoors. I think a rational, smart, understanding surveyor would agree with that point and not cite you for not having a fire-rated door that opens to the outdoors.

But will you always have a rational, smart, and understanding surveyor?

Oxygen in Use Around Hair Dryers

Q: Can you tell me what the rules are for oxygen usage around hair dryers might be?

A: As you can imagine, the codes and standards cannot have rules for every possible scenario. The NFPA codes and standards primarily deal with the storage of oxygen cylinders, and installation of piped oxygen systems. The NFPA codes and standards do not deal much with the use of oxygen… those standards would likely come from Respiratory Care regulations. To give you an idea, NFPA 99-2012, section 5.1.3.3.1.6 says indoor locations for oxygen shall not communicate with locations storing flammables, kitchens, and areas with open flames. Now, I presume there would not be any open flames around a hair dryer, but you get the idea that a heat source (i.e. a hair dryer) around oxygen is not a good idea. But, there is one standard in NFPA 99-2012 that could be of some help for you. Section 11.5.1.1.4 says: “Nonmedical appliances that have hot surfaces or sparking mechanisms shall not be permitted within oxygen delivery equipment or within the site of intentional expulsion.” Hair dryers are definitely ‘nonmedical’ and they do have hot surfaces, so you could use this section of NFPA 99-2012 to prohibit the use of medical oxygen therapy in close proximity to hair dryers.

Transfilling Oxygen Cylinders

Q: What are the requirements for a small storage room becoming a transfer station for filling oxygen cylinders? What code would there be? What type of ventilation do we need if any? Are there any fire ratings required if any?

A: If you’re referring to transfilling liquid oxygen, then you need to comply with NFPA 99-2012, sections 11.5.2.3.1 and 11.5.2.3.2. Specifically, the following is required:

  • A designated area separated from any portion of the facility where patients are housed, examined, or treated by a fire barriers of 1-hour
  • The area is mechanically ventilated, sprinklered and has ceramic or concrete floor
  • The area is posted with signs indicating transfilling is occurring and that smoking in the immediate area is not permitted
  • The individual transfilling the containers has been properly trained
  • The guidelines of CGA pamphlet P-2.6 are met

If you’re referring to transferring gaseous oxygen from one cylinder to another then you must follow CGA pamphlet P-2.5. Transfilling of any gases from one cylinder to another in patient care rooms of health care facilities is prohibited. See sections 11.5.2.2.2 and 11.5.2.2.3 of NFPA 99-2012.

Co-Mingling Oxygen Cylinders

Q: I am a consultant and I have a hospital that was cited for co-mingling full and not-full ‘E’ size oxygen cylinders on a rack located on the loading dock. Do you think that was a justified finding?

A: It depends… NFPA 99 says empty cylinders must be segregated from full cylinders when stored. That is a requirement. There must be some type of demarcation that clearly delineates where the full cylinders are and where the empty cylinders are. But it doesn’t really address the partially full cylinders; the ones that are not full but are not empty either. The general consensus by most authorities is, partially full cylinders are not full cylinders, so according to NFPA 99, they would have to be stored with the empty cylinders. The logic is they don’t want individuals grabbing an empty cylinder by mistake during an emergency.

Now, some accreditors have stated that they recommend hospitals to separate partially full cylinders from empty cylinders as well. In effect, they are suggesting hospitals should have three designated areas for O2 cylinder storage: Full; partially full; and empty cylinders. But this is a recommendation, not a requirement. Therefore, I can see where a finding would be legitimate when full cylinders were stored with empty cylinders; but I don’t see it would be a legitimate finding if a partially full cylinder was stored with a full cylinder… because NFPA 99 does not prohibit it.

E Size O2 Cylinders with Handles

Q: Our Respiratory Therapist has brought this question to me and I wanted your input. We have the new ‘E’ size oxygen cylinders that are called Oxytote. They are the “grab and go” cylinders with the built in regulators and on the top there is a very nice carrying handle. These cylinders are more efficient for us for several reasons, however our staff tends to carry them by the built in handle instead of having it secured in a cart. According to NFPA 99 only cylinders larger than ‘E’ size are to be transported using a hand truck or cart. We are hearing that Joint Commission is not allowing other places to transport these Oxytote cylinders by the handles. What are your thoughts?

A: After reviewing the operator’s manual for Oxytote cylinders, it is obvious that the handle provided by the manufacturer is intended to be used to transport the ‘E’ size cylinder. Also, according to NFPA 99, ‘E’ size cylinders are not required to be transported on carts or hand trucks, as you pointed out. Joint Commission does not have a standard that prevents the Oxytote ‘E’ size cylinders to be transported by grasping the manufacturer provided handle. Since NFPA 99 does not prevent it and since Joint Commission does not prevent it, I believe you are perfectly within your own right to carry the cylinder by the handle if you wish.

As far as you hearing other healthcare providers being cited by Joint Commission for carry Oxytote cylinders by the handle; don’t believe everything you hear. However, if a surveyor indicates that is a problem, tactfully ask the surveyor to show you in the standards where it prohibits that practice. If they claim it is an unsafe practice, then show them the operator’s manual from the manufacturer.

Calibration Gas Cylinders

Q: Are there any storage requirements for full small calibration gas cylinders? The tanks are secure in that they are in holders; however, they are stored under a shelf in a workstation where the machine that uses them is set up. They normally have about 4-6 small cylinders.

A: Yes, there are requirements for small calibration gas cylinders, but it sounds like you have it covered. NFPA 99 requires all medical compressed gas containers to be properly secured and to separate full cylinders from empty cylinders. Now, compressed gas used for calibration may or may not be required to comply with NFPA 99 based on the interpretation by the authority surveying your facility. But since there are multiple authorities who survey your facility, it is best to be conservative and treat calibration gas cylinders the same as medical gas cylinders.

Once you accumulate 300 cubic feet of compressed gas within a single smoke compartment, you then need to store the compressed gas in a designated room that has door that can be locked, and oxidizing gases need to be stored at least 20 feet from combustibles, or 5 feet from combustibles if the room is protected with sprinklers. However, a few small cylinders of calibration gas do not amount to 300 cubic feet so you are probably okay storing them where you are currently doing so.

NFPA 99 requires full cylinders to be separated from empty cylinders, but does not address partially full cylinders. This is a requirement of the standard so no one will accidentally grab an empty cylinder during an emergency. Since partially full cylinders are not full cylinders, then the presumption is they need to be stored with the empty cylinders. Joint Commission has published guidelines that they would like to see partially full cylinders separated from both full and empty cylinders, but this is not a standard requirement.

Electrical Outlets and Oxygen Cylinders

Q: In regards to oxygen cylinder storage on the nursing units, is there a code or standard that restricts the distance between a storage rack of 6 E size cylinders and nearby electrical outlet receptacles?

A: No, there is not an NFPA code or standard that addresses how close a storage rack of oxygen cylinders may be stored to an electrical switch or outlet receptacle, for spaces that have less than 3,000 cubic feet of compressed medical gases, which is typical for a nursing unit. However, NFPA 99 (2012 edition) does require ignition sources (i.e. electrical switches, outlets, receptacles, thermostats, etc.) to be mounted 60 inches above the floor in rooms designated for the storage of 3,000 cubic feet or more of compressed medical gases. The 2012 edition of NFPA 99 also allows for the protection of the electrical ignition sources (e.g. wire cages) in lieu of relocating them 60 inches above the floor. That is to prevent the taller ‘H’ size cylinders from damaging the electrical devices and causing an electrical short.