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.

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.

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.

Oxygen Cylinders in Fire Rated Cabinets

Q: In regards to oxygen cylinder storage, if the quantity of gas in storage is between 300 and 3000 cubic feet in a smoke compartment and the full cylinders are being stored in a fire-rated medical gas cabinet, the hospital was told that they do not need to be stored in a specially designated room. They were told the fire-rated cabinets act as a room themselves and they could place the cabinets anywhere in the smoke compartment. I don’t see it that way, and I believe that the cabinets only allow the cylinders to be stored without the need for separation from combustibles. Question is: What is permitted?

A: I believe you are correct. Section 11.3.2 of the NFPA 99-2012 says storage of non-flammable gases greater than 300 cubic feet but less than 3,000 cubic feet shall comply with the requirements of 11.3.2.1 through 11.3.2.3. Section 11.3.2.1 says storage locations shall be outdoors or within an enclosed interior space of noncombustible or limited combustible construction, with doors that can be secured against unauthorized entry. Section 11.3.2.2 says oxidizing gases cannot be stored with flammable gases, liquids or vapors.

11.3.2.3 says oxidizing gases must be separated from combustibles by one of the following:

  • Minimum of 20 feet
  • Minimum of 5 feet if the entire storage location is sprinklered
  • Enclosed cabinet on noncombustible construction having a minimum fire protection rating of ½ hour.

So… there you have it. Those yellow “Fire Cabinets” are double-walled construction and really only rated for 30 minutes and they are commonly called “NFPA 30” cabinets. But they are permitted to be used in lieu of having to meet the 5 foot or 20 foot distance requirement inside a designated room that is constructed with noncombustible or limited combustible materials, and has a door that is lockable. Limited combustible materials are traditionally gypsum wall board that has a thin layer of paper on the surface.

But make no mistake about it… while the oxygen cylinders may be stored inside the metal cabinets, they still must be stored inside a designated room with a lockable door.

Correction to Yesterday’s Posting

Hello readers…

I did it again. I made a mistake in my answer to yesterday’s posting, which asked the question if signs are required on doors to storage rooms where there is less than 300 cubic feet of oxidizing gases stored. Initially I said yes, citing NFPA 99-2012, sections 11.3.4.1 and 11.3.4.2 which identifies the need for signs on doors to rooms that store oxidizing gases.

But, thanks to my good friend Marge McFarlane of Superior Performance, LLC, she spotted the error and sent me an email identifying it.

If you want the details… here is where I made my mistake: Sections 11.3.4.1 and 11.3.4.2 of NFPA 99-2012 are under the heading of 11.3 “Cylinder and Container Storage Requirements”. Only rooms that store 300 cubic feet of gas or more are required to meet requirements for storage rooms. Since sections 11.3.4.1 and 11.3.4.2 are sub-sections of 11.3, they only apply to conditions identified under 11.3.

So, I took sections 11.3.4.1 and 11.3.4.2 out of context and thought it applied to all rooms storing oxidizing gases, which was incorrect. It only applies to rooms storing oxidizing gases in quantities of 300 cubic feet or more.

I’ve corrected the posting so the mistake is gone, but if you read it and thought you need to add signs on all the doors where oxygen cylinders are stored, please understand the signs are only required if the room contains 300 cubic feet or more.

Sorry… I apologize to my readers. I hope you will forgive me. I strive to be accurate and not make mistakes, but as you can see, understanding and interpreting the standards can be tricky.

Thanks, Marge.

Signs on Doors to Rooms Used for Storage of Cylinders of Oxygen

Q: If there are oxygen tanks stored on a unit that does not exceed the 12 tank threshold, does the door to the storage area where the tanks are stored need to have a sign indicating that tanks are stored within?

A: No. Rooms with less than 300 cubic feet of oxidizing gases (or about 12 E cylinders) does NOT have to have a sign warning of oxidizing gases stored within. However, the door to a storage room containing oxidizing gases in quantities of 300 cubic feet or more  must have a precautionary sign, readable from a distance of 5 feet, and must be displayed on each door or gate of the storage room or enclosure. The sign must include the following wording as a minimum:

CAUTION:

OXIDIZING GAS(ES) STORED WITHIN

NO SMOKING

This requirement is found in NFPA 99-2012, sections 11.3.4.1 and 11.3.4.2, and applies to all healthcare organizations, new and existing. On this particular section of NFPA 99, there is no exception in having this sign if the facility is posted as being a NO SMOKING facility. That applies to other sign requirements where oxygen therapy is in use on a patient, but that exception does not apply to a storage room containing oxidizing gases.

So, as you are conducting your routine building tour, please keep an eye out for the required signs on any door where oxidizing gases are stored in quantities of 300 cubic feet or more.