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.

Strange Observations – Oxygen Cylinder Storage

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

This room contained more than 300 cubic feet of compressed medical gases (but less than 3,000 cubic feet). And even though the picture does not show the whole room, what I wanted to capture is the fact that the oxygen cylinders in storage are not separated from combustibles by at least 20-feet, or 5-feet if the room is protected with sprinklers.

According to NFPA 99-2012, section 11.3.2.3 you must store oxidizing gases at least 5-feet from combustibles if the room is sprinklered, or at least 20-feet if the room is not.

It is obvious in this picture that some sort of plastic items are stored right next to the oxygen cylinders. Another option is to store the oxidizing gas cylinders in a fire-rated storage cabinet, then you do not need to maintain the 5-feet or 20-feet clearance.

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.

Signs on Doors to Rooms Used for Storage of Cylinders of Oxygen

Q: If there are oxygen tanks stored on a unit that does not exceed the 12 tank threshold, does the door to the storage area where the tanks are stored need to have a sign indicating that tanks are stored within?

A: No. Rooms with less than 300 cubic feet of oxidizing gases (or about 12 E cylinders) does NOT have to have a sign warning of oxidizing gases stored within. However, the door to a storage room containing oxidizing gases in quantities of 300 cubic feet or more  must have a precautionary sign, readable from a distance of 5 feet, and must be displayed on each door or gate of the storage room or enclosure. The sign must include the following wording as a minimum:

CAUTION:

OXIDIZING GAS(ES) STORED WITHIN

NO SMOKING

This requirement is found in NFPA 99-2012, sections 11.3.4.1 and 11.3.4.2, and applies to all healthcare organizations, new and existing. On this particular section of NFPA 99, there is no exception in having this sign if the facility is posted as being a NO SMOKING facility. That applies to other sign requirements where oxygen therapy is in use on a patient, but that exception does not apply to a storage room containing oxidizing gases.

So, as you are conducting your routine building tour, please keep an eye out for the required signs on any door where oxidizing gases are stored in quantities of 300 cubic feet or more.

NOTE: January 23, 2019 update: Joint Commission is now interpreting section 11.3.4.1 to require the sign mentioned above, to be on the door of a storage room containing any amount of compressed gas, even if the amount is less than 300 cubic feet. As an AHJ, they have the right to make that interpretation.

Door to Medical Gas Storage Room

Q: I have an existing medical gas storage room in an outpatient surgery center that was constructed with 1-hour barriers and ¾ hour fire rated door. A surveyor cited me because he says the door has to be constructed of non-combustible or limited combustible materials. The door that is installed is a high pressure decorative laminate with a bonded agri-fiber core with a 45 minute fire resistance rating. I maintain that doors are exempted from the noncombustible/limited-combustible provision. Who’s correct?

A: One scenario that the surveyor may hold you accountable to is medical gas systems in ambulatory care occupancies are regulated by the Life Safety Code, and not by NFPA 99. The Life Safety Code (2000 edition) would look at medical gas room as a hazardous room, and for ambulatory care occupancies, a hazardous room compares their level of hazard to their surrounding area. The section that regulates hazards in ambulatory care occupancies is section 20/21.3.2 which refers you to 38/39.3.2, which in turn refers you to section 8.4. Section 8.4 essentially says any area with a higher level of hazard than the surrounding area needs to be protected with fire protection sprinklers, or 1-hour fire rated barriers. Section 8.2.3.2.3.1 requires a 1-hour fire rated barrier to have at least a ¾ hour fire rated door as long as the fire barrier is not used as a vertical opening (such as a rated shaft) or an exit enclosure (such as a stairwell). Hopefully, you don’t have the med gas room in a stairwell, so a properly labeled ¾ hour rated doors is acceptable, and in this scenario I would say the surveyor is mistaken. However, if the surveyor requires that you comply with NFPA 99 in regards to medical gas systems, then that is an entirely different situation. Section 4-3.1.1.2 (a) 11 (a) of the 1999 edition of NFPA 99 requires doors to be constructed of non-combustible or limited combustible materials. If the 45-minute fire rated door that you have is laminated with limited combustible materials, then it would not be compliant with NFPA 99 (1999 edition), and I would say the surveyor is correct. Section 3.3.118 in the Life Safety Code defines what limited combustible materials are. I suggest you contact the manufacturer of the door and ask them to produce documentation whether or not the door meets the heat values stipulated in section 3.3.118, that may qualify the door as being constructed with limited combustible materials. Now, on another point of view, if the surveyor requires you to comply with NFPA 99, 2005 edition, the door to this room still has to be constructed from non-combustible or limited combustible materials, but it is no longer permitted to be ¾ hour fire rated, but must be 1-hour fire rated, according to section 5.1.3.3.2(4). The 2012 edition of NFPA 99 has the same requirement.

Oxygen Storage in Business Occupancies

Q: Our hospital has an offsite building for our cardiac rehab, physical therapy, and pulmonary rehab programs. It also houses our business office and some physician offices. The building is classified as a Business Occupancy. What are the requirements for storing oxygen cylinders in a non-rated storage room?

A: A business occupancy that provides services for cardiac rehab, physical therapy, 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. 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. 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 3,000 cubic feet and quantities less than 3,000 cubic feet which are similar (but not the same) as those requirements for hospitals. For storage of quantities of nonflammable gas greater than 3,000 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 3,000 cubic feet, there is a difference in storing nonflammable gas in quantities of 300 cubic feet or less. 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 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 3,000 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.