Article from ASSE Plumbing Standards Publication July-Sept. 2012 Health Care Facilities Code: In Primetime p. 9-11. Mark Allen.

It’s sailing vs. women’s beach volleyball at the Olympics; the specialist may watch their personal favorite, but the news follows the big audience. Perhaps then it’s not such a bad thing that NFPA 99 for 2012, speaking strictly about medical gases, does not represent the radical change that was seen in the 2002 or even the 2005 edition. The 2012 might even be seen as a bit of a breather from the pace of change experienced over the last editions. That’s not to say there aren’t plenty of interesting changes in the medical gas chapter, but the big news is elsewhere.

The 2012 represents the first omnibus restructure and rewrite of this document since it was initially published in 1984. The document, as a whole, moves NFPA squarely into areas of the medical facility that they have only impacted tangentially in the past. There are existing chapters with significantly changed briefs and several entirely new chapters. As examples particularly relevant to this readership, there is a new chapter on Plumbing Systems and a new one on HVAC. Of less interest perhaps, but of equal impact, wholly new chapters on Telecommunications, Emergency Management and Security have also been added.

Naturally, some of this is very controversial, and that controversy was the primary reason that NFPA was unable to issue the document as expected in 2010 (and that itself was late relative to the usual three-year cycle, which would have anticipated a 2008 edition). If you followed the process closely, you will see that even in the final published document, some concessions to the controversies were made. For instance, both the Plumbing and HVAC chapters are only shadows of the original proposals presented in the ROP (Report on Proposals) and ROC (Report on Comments) documents. These portions were seen to be critical to the rest of the document and thus were included. The other portions of the proposals were “returned to committee,” a parliamentary maneuver NFPA orchestrated to ensure that 2012 would get to print.

You can look to see that material reintroduced in the 2014 cycle, which incidentally is already in full swing. Most of us have not really had a chance to work with the 2012 yet, so the idea of a 2014 is a bit surreal, but NFPA is trying to get the document back on cycle after the long 2005 through 2012 delay.

One of the most important new chapters have been received with surprisingly little comment or controversy, but in fact has enormous impact on the document overall and on medical gases. A new Chapter 4, “Fundamentals,” has been added. It’s only seven paragraphs long, but chapter 4 wheels the whole 99 in a new philosophical direction. The underlying idea is to calibrate the equipment and building safety with the patient acuity being treated. Thus, if the patient or procedure is not going to depend on the equipment, the failure of that equipment does not need to be assures under all circumstances. Therefore, the intrinsic safety redundancy and backup utility systems to support that equipment can be less complex and thus hopefully, less costly. Chapter 4 makes this leap for the 99 and defines four “categories” of patient care. All of the other chapters are intended to follow this lead and be structured around this concept. Each chapter should define the requirements specific for each of the four “Categories” of systems.

Philosophically, few would argue the idea is sound. The medical gases committee has taken this view since 2002; most of you will be familiar with and may have struggles with the “levels,” which was in many respects a prototype of this concept.

Well, “No good deed goes unpunished,” as the old saw tell us. The struggles you have had with the “levels” will have introduced you to the complexity, confusion and, yes, perhaps even the venality that this otherwise excellent concept exposes.

How does one determine a “level” (now a “Category”)? Notionally, that decision is made by the facility owner, consulting with their medical staff and following a recognized risk assessment procedure (see 4.2) What if, medical staff is the owner? What if the owner stands to be the financial beneficiary of the decision? It’s expensive to put in a duplex vacuum pump; if you can twist the rules enough to allow you to be a Category 2, instead of a category 1, and the pump can then be simplex, well that’s money in your pocket.

While the old levels undeniably left a lot to be desired, at least the rules for applying them were pretty clear. They involved sweating through a decision tree and answering a few very specific questions. The test was rigorous, so there were very few Level 2 facilities. The new rules are far simpler-eligibility for Category 2 is now determined by the this single cause: Facility systems in which failure of such equipment is likely to cause minor injury to patients or caregivers shall be designed to meet system Category 2 requirements as defined in this code.

So, just define “minor injury” and you’re away. Think about that for a moment. “Minor” seems to have a lot to do with whether you are feeling it or looking at it, no? When it comes to “injury” most of us can’t even agree with our toddlers (the kid’s screeching like a bag of cars over a scratch that you wouldn’t waste time wiping dirt off of). But we must agree what’s “minor” when thousands of dollars are at stake and very complex medical procedures are being evaluated. Not so easy.

All four categories have similar eligibility requirements and the use will be faced with similar challenges in interpreting, evaluating and deciding which category to apply.

Another very import change will be found in the new 1.3.4 (most of us would never look here” this is the Administration Chapter after all). Here, it clearly requires that the facility must define occupancies. Although this responsibility has perhaps been assumed in the past, it is not made explicit and laid squarely on the facility. Properly applied, this new paragraph will immensely simplify design decision and alarms and valves.

Chapter 5 should have never been used by itself, but now it simply can’t be. Very important material has been moved into other chapters, such as ventilation for manifolds rooms, which is now out in Chapter 9. This appears to be the main reason for elimination the NFPA 99 C, which was the medical gases only extract from the 99. It won’t be possible to buy just the med gas portion of the standard any longer. Sorry and all, but you’ll have to cough up the full document (you can buy it as a PDF version though.)

You can purchase it either as the full code, as the Handbook (code plus commentary) or as a new publication called the “Medical Gas and Vacuum Installation Handbook,” which is the 99 with a bunch of other material that might be useful for the installer in particular.

You’ll notice that we refer to the 99 now as a Code. This is a promotion; NFPA 99 has always been the Health Care Standard, but now it is the Health Care Code. That means it is now up in the pantheon with the NFPA 1, the 101, the 70 or the other top tier documents that NFPA publishes. While not particularly relevant to the average user, this promotion potentially affects the way government agencies eill reference the document. In the past, most have incorporated it by reference through another document. For instance by putting the NFPA 101, Life Safety Code, into law, the 99 would be incorporated “by reference.” Now, government can directly pick up the 99 a bit more easily. One important potential consequence may be that the 99 can be updated without the government also having to update the 101 and vice versa. In practice, its hard to say what impact this will have, but it is a significant decision at NFPA.

Whatever format you choose for your 99, if you’re an installed the document that has to be next over the library is the ASSE/IAPMO/ANSI Series 6000, Professional Qualifications Standards for Medical Gas Systems Personnel. This document has also been revised (it always slightly lags the NFPA 99 revision.) NFPA directly references several chapters in this document, most importantly the 6010/6015 for installers, the 6030 for Verifiers, and new to the 2012, the 6040 for Maintenance Personnel.

6010/6015 and 6030 qualifications are required explicitly. The 6040, however, is one of two methods listed for the qualification of maintenance people. The other is self qualification using a procedure devised by the facility (as conscientious hospitals have long done). Although set out in the standard as alternative routes to the same place, these two, in fact, should be considered complementary. Even the best 6040 course can only teach basic safety and good practices, but will never be able to qualify a worker on the specific equipment in the facility or on the facility’s own practices.

There is also a basic list of elements of the maintenance program, as they relate to NFPA 99 requirements, included. Obviously, actual preventative maintenance elements relevant to the machinery would need to be layered on top of this very basic list. You will immediately notice that there are almost no intervals specified. This is left to the facility to determine based on their own equipment and risk management practice.

I began by pointing out that the NFPA 99-2012 is full of changes of interest to the medical gas specialist, but like networks, we only have time for the big highlight events. That’s just how primetime works.

If you wish to dive into the medical gas changes in detail,  BeaconMedaes publishes a pamphlet which will let you get your elbows dirty. Please contact me at mark.allen@beaconmedaes.com  if you’re interested in a copy.