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.