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 4-188.8.131.52 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 8-184.108.40.206, 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.