Medical Gases in an ER

Q: We are planning on making a change of occupancy classification to our free-standing Emergency Room. We want to change the occupancy designation from health care occupancy to business occupancy. My question is, do we need to pull the oxygen gas system? If we choose to remove the oxygen manifolds, do we have to pull the piping from the wall outlets all the way back to the manifolds?

A: First of all, if you are CMS certified, you cannot change a free-standing ER from healthcare occupancy to business occupancy. According to CMS, ERs must be healthcare occupancy if they have observation rooms, or they must be ambulatory healthcare occupancies if they do not have observation rooms. This is a deviation from NFPA, but CMS can make that interpretation because they are one of the authorities having jurisdiction.

You may leave inactive piping for a medical gas system in a building, but if the ER is located in a healthcare occupancy, you cannot have outlets (or inlets) in an exit access corridor. The reason is section 19.3.6.1 of the 2012 LSC does not permit patient care activity open to the corridor. A medical gas outlet/inlet implies patient care activity, even if it has been disconnected.