Feb 24 2017

Correction to Yesterday’s Posting

Category: BlogBKeyes @ 12:00 am

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 and 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 and 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 and are sub-sections of 11.3, they only apply to conditions identified under 11.3.

So, I took sections and 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.

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Sep 19 2016

A Reader Questions Brad’s Comment…

Category: BlogBKeyes @ 12:00 am

I had a reader question one of my postings on this blog, that I thought you might be interested in reading…

Oxygen Cylinder Storage

The reader wanted to know if the yellow fire cabinets could be used to store oxygen cylinders in lieu of storing them in a designated room, when the accumulative quantity per smoke compartment reaches the 300 cubic feet mark. I said no, according to NFPA 99-2012, section requires an enclosed interior space of non-combustible or limited-combustible construction.

The reader said “I contacted my accreditation organization’s standards interpretation group and asked them the question, and they said it was all-right to store the O2 cylinders in the yellow fire cabinets because they meet the definition of 1/2 hour fire rating.”

A check with one of the manufacturers of the yellow fire cabinets says their cabinets are NOT UL rated for 1/2 hour fire rating. They stated there is not any approved test parameters for the cabinet’s fire rating to be verified with the gypsum material installed in the cabinet’s wall cavity.

To be safe, it is best to not use the yellow fire cabinets for storage of O2 cylinders unless you know for sure the cabinet carries a UL (or similar) test laboratory fire rating of at least 1/2 hour.


Dec 16 2015

Outdoor Storage of O2 Cylinders

Category: BlogBKeyes @ 12:00 am

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- 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- 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.


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Jun 11 2015

Clarification on Oxygen Cylinder Finding

Category: BlogBKeyes @ 12:00 am


images[5] (2)My good friend Gloria Legere shared the following clarification that she wrote for a client hospital. The finding by the surveyor read:


There were full and non-full e-cylinders of oxygen co-mingled on a rack located on the loading dock.

Gloria’s clarification read:

The report of survey findings cited that at the xxx location, “there were full and non-full e-cylinders of oxygen co-mingled on a rack located on the loading dock”.

NFPA 99-1999 section 4-, which parallels the accreditation organization  standard, requires that gas cylinders should be stored in such a way that staff retrieving them in a hurry will not have to make a decision about which cylinders are full and which are not.  The accreditation organization published an article that cautioned hospitals to make sure full and partial or empty cylinders are physically separated to prevent staff confusion when retrieving a cylinder during an emergency.

The Hospital’s policy on storage of medical gas cylinders follows the requirements set forth by the NFPA and the accreditation organization for the storage of medical gas cylinders, however, the requirements of both the NFPA and the wording from the accreditor’s article cited, stress that the delineated storage requirements are to “prevent staff confusion when retrieving a cylinder during an emergency”.

The findings cited from our triennial survey indicate “full and non-full e-cylinders of oxygen co-mingled on a rack located on the loading dock”.  The cylinders located on the loading dock are not ‘in storage’ for patient use.  The cylinders, located on the loading dock area, are in a state of flux of shipping and receiving; either being delivered or retrieved by the delivery company or are overflow of product that exceeds the storage capabilities within the hospital. The cylinders are not accessible by staff caring for patients and patient care is never delivered in this area. Once the cylinders are brought into the hospital for use, the cylinders are appropriately stored in the designated racks in the patient care areas which differentiate by both location and signage separating the full cylinders from in-use/empty cylinders so that there would never be confusion by staff when retrieving oxygen cylinders for use in emergency situations or daily need.

The reply from the accreditor:

The clarifying evidence was accepted for observation 1 based on the cylinders being located on the loading dock and not interior to the building 


So the lesson learned here is to know and understand the codes and standards you are being surveyed against. Surveyors try and do the best job that they can, but they are not the final authority on the interpretation of the standards. It would have been interesting to know what the surveyor would have done if the above documentation was presented during the survey. Would the surveyor accepted the issue on the spot or would the surveyor have continued to document the finding?

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