Strange Observations – Part 39

Continuing in a series of strange things that I have seen while consulting at hospitals…

Okay… this was not taken at a hospital. This AC condensing unit was suspended from 2x4s for a restaurant in a small town in Iowa.

Ugh. Being a former HVAC guy, this makes my skin crawl.

Forward this picture to your HVAC contractor and let him have a good laugh today.

If you know where this was at, send my an email.

Fully Ducted HVAC System

Q: I have never been able to understand what a fully ducted heating system is and when a damper is not required. Can you explain this matter to me?

A: ‘Fully ducted’ HVAC systems are those in which the air in the HVAC system travels from the air handler to the room diffuser in ducts. The alternative is open return-air plenum ceilings or open supply-air plenum ceilings. Those types involve the open space above the ceiling for the movement of air, and there is no HVAC duct in that area. The return-air plenum ceilings are much more common than supply-air plenum ceilings, and would have an opening at the smoke compartment barrier (above the ceiling) to allow the movement of ventilation air without being inside ducts. What the Life Safety Code is saying is if you have ‘fully ducted’ HVAC system from the air handler all the way to the room diffuser on both the supply and return sides, and it penetrates a smoke compartment barrier, then the LSC does not require that you have a smoke damper in this barrier if the smoke compartments on both sides of the barrier are protected with sprinklers. While this is a huge benefit for facility managers, if you are required to comply with the International Building Code (IBC), they do not allow this exception, and you would have to have smoke dampers at the barrier.

Ventilation Requirements for Endoscopy Procedure Rooms

I was asked recently if the ventilation requirements for Endoscopy procedure rooms have changed recently, and the answer is yes. But the changes only apply to new construction, meaning you are not required to go back and retroactively update the ventilation design of the Endoscopy rooms.

The following editions of the Guidelines for Design and Construction of Healthcare Facilities have the following air pressure relationship requirements:



  • (AIA) 1996-1997 edition                 Neutral                 6 ACH                    2 ACH (outdoor air)
  • (AIA) 2001 edition                           Negative               6 ACH                    2 ACH (outdoor air)
  • (FGI) 2006 edition                           Neutral                 6 ACH                    2 ACH (outdoor air)
  • (FGI) 2010 edition                           Positive               15 ACH                     2 ACH (outdoor air)

So, from 1996 to 2010, the air pressure relationship for the endoscopy procedure room, went from being neutral, to negative, back to neutral, then to positive, and the air changes per hour (ACH) went from 6 to 15.

These are guidelines, and are not standards, meaning these are meant to be followed at the time of new construction, unless there are other reasons not to follow them (such as state requirements). The good thing is, as long as you have documented what edition of the guidelines you designed your Endoscopy procedure room to, you are not required to go back and update the room to meet the newer edition of the guidelines.

Typically, most states have firm requirements on ventilation requirements in hospitals that frequently follow along with the guidelines, so in those situations the hospital would have to follow the state’s requirements. Joint Commission has currently adopted the 2010 FGI guidelines (see EC.02.05.01, EP 6) which applies to new construction, and is not enforceable to older designs (many surveyors are not fully aware of this). Again, the guidelines are just guidelines, not standards. In lieu of any other reason, TJC would expect compliance with the guidelines that apply at the time the Endoscopy room was constructed.

CMS has not adopted any specific edition of the Guidelines…. See §482.41(c)(4) [A-0726], which requires ‘proper ventilation’. The CMS interpretative guidelines for this standard just says acceptable standards from AIA should be incorporated. This is not a specific requirement to use the AIA (or FGI) Guidelines. [NOTE: AIA used to write the Guidelines for Design and Construction, but in 2006 they turned it over to FGI.]

Portable Space Heaters

As I write this posting, it is very cold in Northern Illinois. Keeping a healthcare facility warm and cozy for staff is always a challenge in cold weather, but one of the biggest challenges is herding all those portable space heaters that seem to pop up without warning.

Portable space heaters are often found in the strangest places in hospitals and nursing homes, even though the major accreditors for healthcare organizations do not permit them in patient care or treatment areas of healthcare occupancies.

Portable space-heating devices are prohibited in healthcare care occupancies (such as hospitals, nursing homes, limited care facilities and hospice centers with more than 12 beds), with the exception of those portable heaters whose heating elements do not exceed 212 degrees F which are only permitted in smoke compartments which do not contain sleeping rooms, or patient care or treatment. [LSC 19.7.8]

However, in free standing medical offices which are classified as business occupancies, then the Life Safety Code has no restrictions on the use of portable space heaters.

But you need to be careful about using portable heaters in areas that are not traditional patient care or treatment areas. For example: The administrative offices of a healthcare occupancy (such as a hospital, nursing home, limited care facility or a hospice center with more than 12 beds) may be part of a smoke compartment that includes patient care or treatment areas.

The bigger picture is: If staff needs to use a portable space heater, then what does that say about the facility’s HVAC system? Even if an approved portable heater is used in an approved non-patient care or treatment area, it becomes a ‘red flag’ for a surveyor. Once it is noticed, a tracer may begin on why it is in use. If a surveyor determines the facility’s HVAC is not adequate to maintain staff’s comfort, it can be scored as a deficiency under EC.02.05.05 for a Joint Commission survey, or under section 482.41(c) [A-0722] for a CMS survey.

If you already have an approved Fire Safety Evaluation System (FSES) equivalency, or are considering one, then portable space heaters are not permitted in your organization at all. Question ‘D’ on worksheet 4.7.10 prohibit portable electric space heaters anywhere in your facility, if you are granted an approved FSES equivalency.

The bottom line… portable space heaters are trouble. Without the knowledge of the facility manager, staff tends to bring in  portable heaters from home without understanding what kind/style is permitted, and will use them in areas where they are not allowed. Heaters with orange glowing elements exceed the 212 degree F maximum allowed by the Life Safety Code. They add a load onto the electrical distribution system, which may not be designed to handle the extra current. The wrong type of heater may even start a fire if combustible products come into contact with them.

A good life safety code surveyor should be very skeptical of any portable space heater that they observe.