Risk Assessment for 20% Humidity

Q: Since CMS has adopted NFPA 99-2012 edition, is it necessary to do the risk assessment in order to maintain RH levels in ORs > to 20%.

A: Yes. The 2012 edition of NFPA 99 does not adopt the 2013 edition of ASHRAE 170 which allows for the 20% RH. The 2012 edition of NFPA 99 adopted the 2008 edition of ASHRAE 170 which did not allow for 20% RH. Therefore, in order to be compliant with CMS, you need to continue to conduct the risk assessment to allow for the use of the 20% RH.

The issue here is not all surveyors know this and some ask for the risk assessment and some do not.