Nov 17 2017

Co-Mingling Oxygen Cylinders

Category: Oxygen Cylinders,Questions and AnswersBKeyes @ 12:00 am
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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.


Oct 27 2017

E Size O2 Cylinders with Handles

Category: Oxygen Cylinders,Questions and AnswersBKeyes @ 12:00 am
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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.


May 05 2017

Electrical Outlets and Oxygen Cylinders

Category: Oxygen Cylinders,Questions and AnswersBKeyes @ 12:00 am
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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.


Apr 26 2017

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.


Feb 22 2017

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

Category: Oxygen Cylinders,Questions and Answers,Signs,StorageBKeyes @ 12:00 am
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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.


Mar 16 2015

Oxygen Storage

Category: Oxygen Cylinders,Questions and AnswersBKeyes @ 6:00 am
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Q: A local fire inspector approved our outdoor storage shed for full oxygen cylinders. Now a surveyor says it is not compliant because the shed is made of wood, and the accumulative total of oxygen stored exceeds 20,000 cubic feet and must meet NFPA 50 for bulk oxygen storage. Who is correct?

A: Sometimes it doesn’t matter who is correct, but more importantly what the standards and regulations require. First, I would disagree that oxygen stored in cylinders in quantities exceeding 20,000 cubic feet requires compliance with NFPA 50 Standard for Bulk Oxygen Systems at Consumer Sites. NFPA 50 is for a bulk oxygen system which is defined as an assembly of equipment, including cylinders, pressure regulators, safety devices, vaporizers, manifold, and interconnecting piping. It does not appear that you have that assembly; just the full cylinders of oxygen. However, oxygen stored inside the building in quantities exceeding 3,000 cubic feet must be stored in 1-hour fire rated enclosures that are constructed with non-combustible materials, according to NFPA 99 (1999 edition), section 4-3.1.1.2. But a storage shed outdoors that is at least 10 feet from the healthcare facility is not required to be fire-rated.  Keep in mind that just because a local AHJ approved this arrangement, that does not mean it will be (or must be) acceptable to all AHJs. Each authority has the right to interpret the situation to his or her own understanding, and you need to comply with the most restrictive..


Aug 25 2014

O2 Cylinders in Ambulatory Surgical Centers

Q: Since the Life Safety Code addresses ambulatory surgery centers in chapters 20-21, which does not reference oxygen storage requirements, do they have to abide by NFPA 99 concerning storage of compressed gas cylinders?

 A: According to the CMS S&C-07-10 memo dated January 12, 2007, Ambulatory Surgical Centers (ASC) are included in the scope of that interpretation memo and ASC are required to abide by the 2005 edition of NFPA 99, section 9.4.3. This allows them the same advantage as hospitals with no storage requirements for 300 cubic feet and less of non-flammable compressed gas per smoke compartment. For storage of non-flammable compressed gas over 300 cubic feet and less than 3,000 cubic feet per smoke compartment, the ASC needs to comply with Chapter 13 of NFPA 99, section 13-3.8 which refers back chapter 8. Section 8-3.1.11.2 provides the requirements for storage of non-flammable compressed gas in quantities less than 3,000 cubic feet, which do not include 1-hour fire rated barriers. However, since the CMS S&C memo grants a special dispensation for ASC to follow the 2005 edition of NFPA 99, for 300 cubic feet and less of compressed gas, then they are the same as hospitals in regards to storage of compressed gas. According to the CMS S&C memo, cylinders in use are not to be counted as cylinders in storage. Therefore, they are not included in the calculation of cubic feet of compressed gas when considering storage requirements.  NFPA 99 requires full compressed gas cylinders to be segregated when stored with empty compressed gas cylinders.


Jun 30 2014

Oxygen Storage in Business Occupancies

Q: Our hospital has an offsite building for our cardiac rehab, physical therapy, and pulmonary rehab programs. It also houses our business office and some physician offices. The building is classified as a Business Occupancy. What are the requirements for storing oxygen cylinders in a non-rated storage room?

A: A business occupancy that provides services for cardiac rehab, physical therapy, and pulmonary rehab programs is considered to be a health care facility. Assuming you are either Joint Commission accredited, or receive federal reimbursement monies for Medicare or Medicaid services, you are required to comply with NFPA 99 (1999 edition) Health Care Facilities standard. According to section 1-2, NFPA 99 (1999 edition) applies to all health care facilities, and section 2-1 defines a health care facility where medical care is provided. Chapter 13 in NFPA 99 is the chapter for “other” health care facilities which are not hospitals, nursing homes and limited care facilities. Section 13-3.8 requires all gas equipment to conform to chapter 8. Section 8-3.1.11 lists the storage requirements for nonflammable gases greater than 3,000 cubic feet and quantities less than 3,000 cubic feet which are similar (but not the same) as those requirements for hospitals. For storage of quantities of nonflammable gas greater than 3,000 cubic feet, the requirements are the same as those for hospitals, which are found in section 4-3.1.1.2 of NFPA 99. However, for quantities less than 3,000 cubic feet, there is a difference in storing nonflammable gas in quantities of 300 cubic feet or less. Hospitals have the advantage of having a special dispensation granted by The Centers for Medicare & Medicaid Services (CMS), in the form of S&C Letter 07-10, published January 12, 2007. In this letter, CMS allows hospitals (but not medical offices or clinics) the advantage of following the 2005 edition of NFPA 99, which permits quantities up to 300 cubic feet of nonflammable gas to not be stored in any special rooms or areas. This exception for ‘up to 300 cubic feet’ is not found in the 1999 edition of NFPA 99. Therefore, your business occupancy must store all nonflammable gas cylinders in quantities from 0 to 3,000 cubic feet in accordance with section 8-3.1.11.2, which requires a specially designated room which has a door capable of being locked, and all oxidizing gases in this room must be separated from combustibles by 20 feet (or 5 feet if the room is protected with automatic sprinklers), or the oxidizing gases are to be stored in a flammable cabinet with a fire rating of at least 30 minutes.


Oct 21 2013

Oxygen Cylinders on Wheelchairs

Category: Oxygen Cylinders,Questions and AnswersBKeyes @ 5:00 am
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Q: I came across a bunch of wheelchairs folded up in an equipment storage room. Each had an oxygen cylinder attached. Are these cylinders included in the tally for aggregate total stored in a smoke compartment?

A: No, they are not. CMS and most accreditation organization consider oxygen cylinder that are attached to a wheelchair, gurney or bed as being counted as ‘in use’. The cylinder must be properly secured in a designated holder in order to qualify.


Oct 14 2013

Oxygen Cylinders and Clean Linen Carts

Q: Are oxygen cylinder tanks (in holders) allowed to be stored in alcoves in corridors? Also, what about clean linen carts? I am told that our accreditation organization allows this, but I don’t know if CMS does.

A: Oxygen cylinders are permitted to be stored outside of a designated room, provided they are properly secured; they do not infringe upon the required corridor width; and the aggregate total of cubic feet of medical gas in cylinders (all gas, not just oxidizing gas) does not exceed 300 cubic feet per smoke compartment. So, a couple E size cylinders in holders, stored in an alcove sounds acceptable to me.

Under normal conditions, the presence of combustibles, such as paper, cardboard, plastics, and clean linen are not considered to be hazardous until the area in which they are contained exceeds 50 square feet. A clean linen cart in an alcove that does not exceed 50 square feet appears to not meet the requirements of a hazardous area (see 19.3.2.1), and therefore does not have to be contained in a room designated as a hazardous room. However, some accreditation organizations may take a different look at this, and consider the volume of a 6 foot tall, by 4 foot wide, by 2½ foot deep clean linen cart to be sufficient capacity of combustibles to be a significant threat, even though it does not meet the LSC definition of a hazardous area. I know that at least one accreditation organization requires the corridor and alcove to be sprinklered in order to store a clean linen cart there.


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