EM Lights in MRI

Q: I have a question on the requirement for the battery backup lighting inside the MRI suites. We are in the process of building two new MRI centers and I am receiving a lot of push back from the Project Engineer.

This engineering group specializes in MRI projects and they tell me they never install battery backup lighting and that NFPA 99 does not require battery backup lighting anywhere outside of an operating room. I was told to reference of NFPA 99-2012 which specifically mentions operating rooms. My reply was that does not specify only operating rooms so it is much broader in scope and since we use anesthesia in the MRI it would be required.

Before I stir up the pot anymore with the engineering firm I wanted to make sure that if Anesthesia is being used in the MRI room that emergency battery backup lighting should be in place.

A: Yes, you are correct. NFPA 99-2012, section requires one or more battery-powered lighting units within locations where deep sedation and general anesthesia is administered. That includes MRI areas, Cath Lab areas, and of course, Operating Rooms and Procedure rooms. ICUs and NICUs would typically not be included.

Just because the project engineer from the contractor has never been told to install battery-powered lighting units before does not preclude the fact that it is a requirement and it is enforced by CMS and the Accreditation Organizations. The engineer is mistaken.


EM Lighting in Out-Patient Facilities

Q: We have out-patient clinics classified as business occupancies. Are we required to have emergency egress lighting? If so what section of the 2012 or 2015 NFPA Life Safety Code outlines the requirement?

A: It depends. For new business occupancies section of the 2012 LSC says emergency lighting shall be provided where any one of the following conditions exists:

  1. The building is three or more stories in height;
  2. The occupancy is subject to 50 or more occupants above or below the level of exit discharge;
  3. The occupancy is subject to 300 or more total occupants.

For existing business occupancies section of the 2012 LSC says emergency lighting shall be provided where any one of the following conditions exists:

  1. The building is three or more stories in height;
  2. The occupancy is subject to 100 or more occupants above or below the level of exit discharge;
  3. The occupancy is subject to 1000 or more total occupants.

The emergency lighting must be installed in accordance with section 7.9, which discusses battery-powered emergency lights and those egress lights powered from generators. According to, new emergency power systems for emergency lighting shall be generator power, with a Type 10 (meaning no more than 10 seconds to transfer power), Class 1.5 (which means must provide emergency power for a duration of 90-minutes) and rated for Level 1 (which means the system shall be installed where failure of the equipment to perform could result in loss of human life or serious injury). Level 1 systems are described in NFPA 110 as rotating equipment energy converters powered by prime movers (i.e. generators). Existing condition emergency lights could be powered by battery-powered emergency lights.

Smoke Detectors

Q: Do you have to have smoke detectors in emergency electrical rooms or electrical rooms?

A: In a hospital? Only if you have an FSES equivalency that requires it, or the room is located inside an area under Specialized Protective Measure locks as described in section of the 2012 LSC. Otherwise, there are no NFPA codes or standards that require it. But check with your state and local authorities to see if they have regulations that require it.

Often times smoke detectors are placed in locations based on designer preference.

GFCI Receptacles

Q: Where can I find the requirements for ground-fault circuit interrupters (GFCI) protection in the dietary/kitchen area of a nursing home? I thought it was 6′ within a water source. But when I look in the 2011 NEC it does not say that. The way I read it, it is everywhere in the kitchen/dietary that is 110v. What is your thought, and where can I find the clarification?

A: According to NFPA 70-2011, section 210.8, says:

All 125-volt, single-phase, 15- and 20-ampere receptacles installed in the locations specified in 210.8(A)(1) through (8) shall have ground-fault circuit interrupter protection for personnel.

(6) Kitchens— where the receptacles are installed to serve the countertop surfaces

(7) Sinks — located in areas other than kitchens where receptacles are installed within 1.8 m (6 ft) of the outside edge of the sink

Section 210.8 does apply to healthcare facilities so NFPA 70-2011 does require GFCI receptacles in kitchens in healthcare facilities.

Surveyors will often use section 210.8 in assessing GFCI compliance in healthcare occupancies.

Battery Powered Emergency Lights

Q: In the standards manual from our accreditation organization it states that every 12 months the critical access hospital either performs a functional test of battery powered lights on the inventory required for egress for a duration of 1½-hours or replaces the batteries and tests 10% of all batteries and records the results. Do we need a written inventory of these lights? If so, can these lights be labeled on a drawing? Or do these need to be listed out in a spreadsheet?

 A: First of all…. be careful which edition of the standards you are reading. That accreditation organization changed their standard on this issue in 2018 and eliminated the option of replacing the batteries annually, and only testing 10% of them. The requirement since January 1, 2018 is you must conduct the annual 90-minute test on all of the batteries.

But to answer your question…. Yes… the battery powered emergency lights do need to be listed on an inventory in order to be sure all of them were tested. You need to list them on a spread-sheet that identifies them by location and/or asset-tracking number, so you can demonstrate that your tested each device and whether or not it passed or failed.

To help your staff located the devices quicker, you should consider listing them on drawings so each location can be tracked.

Tamper-Resistant Receptacles

Q: My question involves childproof outlets in healthcare. Where are they required and where in the code does it discuss not using snap-in covers?

A: According to NFPA 70-2011, Article 517.18(C), tamper-resistant receptacles are required in pediatric locations of health care facilities (i.e. hospitals, physician offices, therapy areas, etc.) including patient rooms, bathrooms, playrooms, activity rooms, and patient care areas of designated pediatric locations. As an option, the receptacle may use a listed tamper-resistant cover. The listing would have to be from an independent testing laboratory, such as UL, ETL, or the like. In essence, wherever an unattended child could be, you would have to have tamper-resistant receptacles.


Locked Electrical Panels

Q: Is it required to keep electrical panels locked even if they are behind doors that are restricted by card-access readers? Does it depend on which AHJ is inspecting it?

A: According to NFPA 99-2012, section (A), circuit breaker panels to Category 1 and Category 2 rooms must be secured against unauthorized access. If you can justify that only authorized individuals with approved badge readers can access the panels, then you should not have to lock the individual panels.

But section 1.3.2 of NFPA 99-2012 also says that construction and equipment requirements shall be applied only to new construction and new equipment. That means in existing conditions, relocating your circuit breaker panels to locked rooms is not a requirement.

This is one good reason to conduct the NFPA 99 Risk Assessment to determine what your Category ratings are for your electrical equipment and where they are located.

All AHJs should enforce this the same way… but we know that is not likely to happen.

Access To Electrical Rooms

Q: Please clarify if electrical closets and /or electrical rooms can be accessible to anyone. The NFPA70 National Electrical Code seems to require warning signs limiting access to authorized personnel only.

A: For many years there has not been any specific standard that says access to electrical control panels has to be restricted to authorized individuals only. But with the new NFPA 99-2012, section now says access to over-current protective devices (i.e. circuit breakers) serving Category 1 or Category 2 rooms is restricted to authorized individuals only. This standard actually only applies to new construction.

But be aware that for many years accreditation organization have cited healthcare facilities for not securing their circuit breaker panels from unauthorized access, and they base this on their “Safe Environment” standard, or as some people call it the ‘General Duty’ clause.

So, it has been enforced for years by accreditation organizations, and by some state agencies, while there has not been an actual standard that required securing the panels. So, I would suggest you do secure all electrical rooms from unauthorized access.

Oxygen Therapy and Beauty Salons

Q: I am curious if you know of any regulations that deal specifically with LTC residents with oxygen supply and beauty salons. We have a salon in house, and the beautician comes twice a week and I have a sign up that says no oxygen allowed in salon. Do you know of any specific regulations that relate to the use of oxygen in a salon?

A: After reviewing sections and of NFPA 99-2012, I believe oxygen therapy would not be permitted to be administered around hot appliances. While beauty salon heating devices such as hair dryers and curling irons typically do not get much attention from surveyors, NFPA 99-2012 does prohibit the administration of oxygen therapy around hot appliances… and hair dryers and curling irons are hot appliances. I would recommend that you not allow the use of O2 therapy equipment in a beauty salon.

Daisy Chain

Q: What would be the appropriate standard for a daisy chain?

A: I’m not entirely sure of what you are asking…. But when you say “What would be the appropriate standard for a daisy chain” I’m assuming you are referring to an extension cord (or power strip) plugged into another extension cord (or power strip). The Code trail that would prohibit that, is:

2012 Life Safety Code, section requires compliance with section 9.1 for utilities. Section 9.1.2 requires compliance with NFPA 70-2011 on all issues of electrical wiring and equipment. NFPA 70-2011, Article 400.8 (1) says: “…flexible cords and cables shall not be used …as a substitute for the fixed wiring of a structure”. So NFPA 70-2011, Article 400.8 (1) prohibits daisy chains, because the first extension cord (or power strip) is now acting as a substitute for the fixed wiring of a structure.

Also, NFPA 70-2011, Article 400.7 (B) says each flexible cords shall be equipped with an attachment plug and shall be energized from a receptacle outlet. That also prohibits a flexible cord (i.e. extension cord or power strip) from being plugged into another flexible cord.