Q: We had a finding from a recent Joint Commission survey on EC. 02.01.01, EP 3. When the surveyor told us about it, he said it related back to an NFPA standard, but he didn’t say which one. What he cited us for was not having a roof over our empty O2 storage tanks that are kept out on the back dock. They are in a caged area, and are in racks. Do you know what NFPA standard we should look up to figure out how to correct this?
A: EC.02.01.01, EP 3 is a general-duty type of standard where TJC can cite anything that they feel is an un-safe condition. It is frequently used interchangeably with EC.02.06.01, EP 1. I suspect the surveyor used EC.02.01.01, EP 3 in this case because the deficiency was observed outside the building, and EC.02.06.01, EP 1 is for interior spaces.
So… the finding was the empty O2 cylinders did not have a roof over them, even though they were properly secured. I have reviewed NFPA 99, 1999 edition and cannot find a specific reference where O2 cylinders stored outside need to have a roof over them. Section 8-188.8.131.52(a) of NFPA 99-1999 says storage locations of nonflammable gases must be either outdoors in an enclosure or within an enclosed interior space of non-combustible construction. The definition of ‘enclosure’ does not include a reference to a roof.
However, section 4-184.108.40.206(a) says “Sources of heat in storage locations shall be protected or located so that cylinders of compressed gases shall not be heated to the activation point of integral safety devices. In no case shall the temperature of the cylinders exceed 130⁰F.” So, are O2 cylinders (even empty cylinders) that are exposed to the sunlight capable of exceeding 130⁰F and would their integral safety devices be activated? Apparently the surveyor thought so. If you disagree, you can appeal this finding through the clarification process and try to get it removed but I suspect the clarification would not be accepted.
Just my two cents worth… I’ve always seen roofs over outdoor O2 cylinder storage locations wherever I go.