E Size O2 Cylinders

Q: Can E-cylinders be stored in a closet where people hang their jackets even if they are in an acceptable storage cart?

A: Yes… up to a certain number of ‘E’ cylinders. Storage of compressed medical gases up to 300 cubic feet in accumulative quantity per smoke compartment is unregulated, other than the requirement in section 11.6.2.3 (11) of NFPA 99-2012 to properly secure the cylinders and to not store them in such a way that they obstruct the required egress. But once the accumulative total of stored gases exceeds 300 cubic feet per smoke compartment, then section 11.3.2 of NFPA 99-2012 regulates how they are stored:

  • Must be in a designated room constructed with non-combustible or limited combustible materials
  • Must have a door that can be secured against unauthorized entry
  • Oxidizing gases cannot be stored with any flammable gas, liquid or vapor
  • Oxidizing gases must be separated from combustibles by 20 feet, or 5 feet if the room is sprinklered, or enclosed in fire-rated cabinets

An ‘E’ cylinder (which is 25.5 inches tall and 4.3 inches in diameter) contains 24 cubic feet of gas when full, so that means you could have up to 12 ‘E’ cylinders in a single smoke compartment before you would have to comply with section 11.3.2 for storage.

Compressed Gas Cylinders

Q: In healthcare, when calculating the 300 cubic feet of oxidizing gases like oxygen and nitrous oxide, do “air” tanks figure into the calculation?

A: Yes… According to 3.3.128 of NFPA 99-2012, an oxidizing gas is a gas that supports combustion. And, according to 11.1.1, the NFPA 99-2012 Health Care Facilities Code applies to all nonflammable medical gases. So, if the cylinders of compressed air are medical gases, then yes; they apply to the oxidizing gases rule.

Strange Observations – Oxygen Cylinder Storage

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

Yes… we are looking at oxygen cylinder storage issues again… Yuck.

The sad thing is, scenes like this are not that uncommon in my line of work as a consultant. That means it is not as strange as I would like it to be.

NFPA 99-2012, 5.1.3.3.2 does require all compressed gas cylinders to be secured at all times. Presumably, those of you who are reading this realize this, and are as frustrated as I am when you find situations like this.

But put yourself in the position of the healthcare provider: Their number 1 priority is taking care of patients. Complying with Life Safety Codes, or other NFPA standards and regulations is not high on their list, and quite honestly, with everything they have to do, I’m okay with that. I’d rather they be concentrating on taking good care of me or my loved-one, rather than concentrating on making sure the corridor is not cluttered, or other basic LSC requirements.

So it is important for you to make compliance with the LSC as easy and simple as possible for those nurses, therapists, and technicians. That means, you need to do frequent rounding looking for basic violations as the one in the picture reveals. When you find these violations, you can do remedial training, but perhaps more importantly, make changes to eliminate the problem from happening again. In this case, obtain more storage racks so staff does not leave cylinders on the floor or unsecured.

Partially Full Oxygen Cylinders

Q: My Facilities Director just attended a state association of healthcare facilities managers. He stated that the presenter said that for oxygen cylinder storage and segregation, if a cylinder is not completely empty it is considered full. This is 180 degrees from what we have always been told. At our hospital, we have always said that any cylinder that is has been opened is no longer considered full and must be stored with the empties. Have you heard anything to this effect?

A: This sounds like a surveyor preference issue, to me. In other words, this may be just the presenter’s opinion, or perhaps a CMS Regional Office’ opinion. NFPA 99-2012, section 11.6.5.2 says “If empty and full cylinders are stored within the same enclosure, empty cylinders shall be segregated from full cylinders.” Well, a partial cylinder is not full, so in my way of thinking it cannot be stored with the full cylinders.

Actually, the presenter is not wrong when he says a partial cylinder should be stored with the ‘Full’ cylinders. Since NFPA 99 does not address partially full (or partially empty) cylinders, how they are stored is left to the AHJ to decide. If the presenter represented an AHJ, then he is within his right to say partial tanks cannot be stored with the empties. But taking this a step further, section 11.6.5.3 says “Empty cylinders shall be marked to avoid confusion and delay if a full cylinder is needed in a rapid manner”.

This shows us the intent of the code is to prevent a non-full cylinder from being grabbed in an emergency. If partially-full cylinders are stored with full cylinders, then that goes against the intent. However, the intent of the code is not well-written on this particular issue and we are stuck with what is written, which does not prohibit an AHJ interpreting section 11.6.5.2 to say partials cannot be stored with empties. I guess the best advice is to follow what Joint Commission is requesting… that there be three (3) separated storage areas; one each for full cylinders, partially full cylinders, and empty cylinders. That should solve the problem.

Curtains for Oxygen Storage

Q: Is there a code from NFPA or Joint Commission in regards to “cloth” curtains hanging in around/in front of oxygen cylinders. And if so would it make a difference if it is in an office setting vs hospital setting?

A: Yes… Both NFPA and Joint Commission prohibits the storage of oxygen cylinders within 20 feet of combustibles (or within 5 feet of combustibles if the room is protected with sprinklers, see NFPA 99-2012, 11.3.2.3), when the quantity of compressed gas stored is equal to or exceeds 300 cubic feet. It does not make a difference where the stored compressed oxygen is stored. NFPA 99 applies to all healthcare facilities.

Door to Compressed Gas Storage Rooms

Q: I have an oxygen/med gas storage room that is attached to the hospital, and can only gain access to the room by way of the exterior of building. Does the room have to have a fire-rated door assembly?

A: Well… that depends. If the storage room contains 3,000 cubic feet or more of compressed medical gases, and the room is located indoors, then the room must be constructed with 1-hour fire-rated construction and the door to the room is required to be 1-hour fire rated if new construction, and 3/4-hour rated if existing conditions. (See 5.1.3.3.2(4) of NFPA 99-2012).

However, the intent of 5.1.3.3.2 is to separate the compressed gas storage room from the rest of the facility by requiring 1-hour fire rated barriers, and if the door opening to the storage room opens into the facility, one could easily understand why a fire-rated door is required. However, if the door to the storage room opens to the outdoors (i.e. receiving dock) then one could make a point that the door is not required to be fire-rated, because there is no separation between the storage room and the rest of the facility at that point.

But the problem is, NFPA 99-2012 section 5.1.3.3.2 does not say that and does not appear to have any exception for a door to the storage room that opens to the outdoors. I think a rational, smart, understanding surveyor would agree with that point and not cite you for not having a fire-rated door that opens to the outdoors.

But will you always have a rational, smart, and understanding surveyor?

Compressed Flammable Gas

Q: Can we store compressed butane gas cylinders used for food-warming and heating in the kitchen or do they require special storage?

 A: NFPA 30 requires all flammable gases and liquids exceeding 1 gallon (aggregate total) must be stored in a proper fire rated cabinet, or in a hazardous room with 1-hour fire rated barriers. You are not allowed to store mixed substances, such as combustibles with flammable liquids and gasses. For quantities less than 1 gallon, they must be stored in their original container, or in a special safety can. Joint Commission does have a standard (EC.02.01.01) whereby they could cite you for having any flammable liquid or gas stored outside a fire rated cabinet regardless of the quantity.  

Oxygen Cylinders

Q: Several of our department have stretchers with onboard E-size oxygen cylinders.  Can these be considered “in use” and not count against the smoke compartment’s 300 cubic feet limit? Also, our nursing staff currently checks oxygen inventory daily and documents it on a log.  Is this a written code requirement?

A: Yes and No. All O2 cylinders that are mounted on gurneys, wheelchairs and medical equipment but are not actively used by patients are considered by CMS to be in use, and therefore are not subject to the 300 cubic feet threshold for stored medical gas cylinders. They explained their position on this issue in a memorandum called S&C-07-10, dated January 12, 2007. The Joint Commission has endorsed this position as well and has said as much at various opportunities.  In regards to the nurses checking oxygen levels on a daily basis, I am not aware of any LSC or Joint Commission requirement for this action. Perhaps there may be something about this from the state. I do know that plant operators frequently record the level of liquid oxygen in the bulk storage tanks but that is more for tracking purposes and to ensure they do not run out.

Compressed Gas Cylinders in Business Occupancies

I was recently asked what the requirements were for storing compressed gas cylinders in a business occupancy. According to section 1-2, NFPA 99 (1999 edition) applies to all health care facilities, and section 2-1 defines a health care facility where medical care is provided. Therefore a clinical business occupancy such as those which provides services for cardiac rehab, physical therapy, physician’s office, and pulmonary rehab programs is considered to be a health care facility. Assuming you are either Joint Commission accredited, or receive federal reimbursement monies for Medicare or Medicaid services, you are required to comply with NFPA 99 (1999 edition) Health Care Facilities standard.

Chapter 13 in NFPA 99 is the chapter for “other” health care facilities which are not hospitals, nursing homes and limited care facilities. Section 13-3.8 requires all gas equipment to conform to chapter 8. Section 8-3.1.11 lists the storage requirements for nonflammable gases greater than 3000 cubic feet and quantities less than 3000 cubic feet which are similar (but not the same) as those requirements for hospitals.

For storage of quantities of nonflammable gas greater than 3000 cubic feet, the requirements are the same as those for hospitals, which are found in section 4-3.1.1.2 of NFPA 99. However, for quantities less than 3000 cubic feet, there is a difference in storing nonflammable gas cylinders is in the 300 cubic feet or less quantity. Hospitals have the advantage of having a special dispensation granted by The Centers for Medicare & Medicaid Services (CMS), in the form of S&C Letter 07-10, published January 12, 2007. In this letter, CMS allows hospitals (but not medical offices or clinics) the advantage of following the 2005 edition of NFPA 99, which permits quantities up to 300 cubic feet of nonflammable gas per smoke compartment to not be stored in any special rooms or areas. This exception for ‘up to 300 cubic feet’ is not found in the 1999 edition of NFPA 99. Therefore, your business occupancy must store all nonflammable gas cylinders in quantities from 0 to 3000 cubic feet in accordance with section 8-3.1.11.2, which requires a specially designated room which has a door capable of being locked, and all oxidizing gases in this room must be separated from combustibles by 20 feet (or 5 feet if the room is protected with automatic sprinklers), or the oxidizing gases are to be stored in a flammable cabinet with a fire rating of at least 30 minutes.

Compressed Gas Stored in Dialysis Unit

Q: We have a contractual Dialysis Unit on the 2nd Floor of our Medical Office Building which consists mainly of one large open room. Very often in the treatment area they have more than 12 ‘E’ size cylinders of oxygen stored, that are not in use. Does the 12 cylinder rule apply to them even though they are an ambulatory care occupancy?

A: By saying the 12 cylinder rule, you are referring to the NFPA 99 requirement that requires quantities of compressed medical gas that exceed 300 cubic feet per smoke compartment to be stored in a designated room that has 30 minute fire rated walls, a door with a lock on it, and kept separate from combustibles by 20 feet (5 feet if the room is sprinklered). 12 full ‘E’ size cylinders contain slightly less than 300 cubic feet of compressed gas, so 12 ‘E’ size cylinders per compartment could be stored outside of the designated room, but once there are 13 of them, then they would all have to be stored in the designated room. The healthcare occupancy chapters in the LSC do require compliance with NFPA 99 in regards to medical gas storage (see 19.3.2.4), but the ambulatory care occupancy chapters (20 and 21) do not. But that is not the end of the story. Oxygen by itself is not a flammable gas, but it can make other items burn faster and at a lower temperature. Therefore, it is considered a hazard, and must be protected in a room designated as a hazardous room. But at what point does the quantity of compressed oxygen stored in the cylinders becomes a hazard? If this were healthcare occupancy, the answer to that question is made for us by NFPA 99 which sets a threshold of 300 cubic feet of compressed gas. But that standard is not listed as a requirement in the ambulatory care chapter of the LSC, so the authority having jurisdiction (AHJ) will have to decide for themselves what standard to use. I suggest you follow NFPA 99 requirements for oxygen cylinder storage until such time an AHJ says otherwise.