Can a wood fire rated door by used in a medical gas room? Paragraph 220.127.116.11.2 (4) in NFPA 99 (2012) indicates a medical gas room can not be constructed of combustible materials. Does that apply to a 3/4 hour fire rated door wood door.
My answer is yes you can use a rated wood door.
OHHH I am not an engineer, so you can discount my reply if you want, and I cannot do math.
Elizabeth wrote: Can a wood fire rated door by used in a medical gas room?
As a former state life safety code surveyor for NFPA 99 compliance, I would cite the facility for using a wood veneered door with a 3/4-hour fire resistant rating instead of a metal door with a 1-hour fire resistant rating used for the construction of a medical gas rooms. The NFPA 99 code clearly states non-combustible or limited- combustible construction and 1-hour fire resistant rating to enclose medical gas rooms. Last time I checked wood was not a non-combustible or limited-combustible material. The NFPA 99 code was missing the words "fire barrier" so the NFPA 101 Section 8.2 for fire barriers could not be applied.
Excerpt of Paragraph 4 of Section 18.104.22.168.2 of the 2012 NFPA 99
Old dinasour still learning. When I was on the job in Inspector Certification classes we were taught to do apply ( do the the most restrictive). NFPA 101 being the more authortive document on life safety and providing source information for some sections of NFPA 99 why wouldn't Section 8.2 of NFPA 101 not be applical? Of course we are talking about Insprctor and Engineer inturpation which I have feelings against which is for a very huge discussion for another time.
Thanks that you caught this. I stand corrected. I think my mind was mixing up the code sections. The 2012 NFPA 99 Section 15.2 does require compliance to the 2012 NFPA 101 for construction and compartmentation of the building. Section 8.2 of the 2012 NFPA 101 deals with construction and compartmentation of the building. Section 8.3 of the 2012 NFPA 101 deals with the fire barrier requirements. I have looked in the 2012 NFPA 101 hazardous areas and the 2012 NFPA 99 medical gas storage requirements. They have no references that fire barriers were to enclose the medical gas room.
Section 18/19/3.2.4 requires medical gas storage to comply with the 2012 NFPA 99. Compartmentalization in accordance with Section 8.2.2 of the 2012 NFPA 101 that require fire barriers of the medical gas room was not required by the other Chapters (18/19) of the code.
I also looked into the CMS Survey and Certification letters for the any AHJ guidance to the construction of the medical gas rooms and found none.
I did however find that the 2015 NFPA 101 have revised Section 22.214.171.124.2 paragraphs for the indoor medical gas room construction.
With this in mind, the health care provider would have to contact the state's licensing and federal certification agent to get written approval to use the 2015 NFPA 99 requirements.
In addition to consulting with state licencing and federal certification agencies I also suggest that the Joint Council On Hospital Accredation be consulted. The adopted NFPA 2012 ED'S of 101 and 99 as their standards for hospital Life Safety and Fire Prevention. If this hospital wants to comply with the 2015 ED of NFPA 99 I think they would also need the Joint Council's approval also. As an aside I can remember form being on the job dropping patient's at hospitals and they would be in a tissy that the Joint Council was coming. lol
Lawrence thanks for the additional information. Great comments and fair enough on the subject.
For the audience, I just wanted to point that Medicare or Medicaid programs must be certified as complying with the Conditions of Participation (CoPs), or standards, set forth in federal regulations.
If a national accrediting organization such as the Joint Commission (TJC) has and enforces standards that meet the federal CoPs including the 2012 NFPA 101 and 2012 NFPA 99, Centers for Medicare and Medicaid Services (CMS) may grant the accrediting organization "deeming" authority and "deem" each accredited health care organization as meeting the Medicare and Medicaid certification requirements. The health care organization would have "deemed status" and would not be subject to the Medicare survey and certification process because it has already been surveyed by the accrediting organization. Accreditation is voluntary and seeking deemed status through accreditation is an option, not a requirement. Organizations seeking CMS approval may choose to be surveyed either by an accrediting body, such as the Joint Commission, DNV, and HFAP, or by state surveyors on behalf of CMS.
The AHJ, in terms of NFPA 101 and NFPA 99, is the federal government for the CMS certification process. I do not believe CMS has transferred that authority to any of the national accrediting organizations. The national accrediting organizations can not waive or modify the 2012 NFPA 101 or the 2012 NFPA 99 without CMS's waiving or modifying it first. Once the health care provider gets an code waiver or modification from CMS in writing, then the written documentation should be submitted to the national accrediting organization having "deemed status" for review.
Complying to the NFPA code is this instance may be the easier route to take. In my experience, very seldom does CMS response to a request to waive or modify the adopted code to the earlier editions unless a certification survey recommends the waiver due to a hardship to comply and the current fire safety was equivalent to the that required by the codes.
You ate right I also don't think that federal agencies that would allow an non government organization to fully controlled the accreditation of hospitals. All I can go by is the amount of angzity of hospital staff when they knew that the Joint Council was coming around for an inspection. Their findings must have hospitals keeping their accredation. Awhile ago there was a discussion on LinkedIn where the Joint Council citied a hospital where a patient privacy curtin blocked the discharge of a sprinkler head. They must have some affect on hospital accredation I think. I always viewed the Joint Council like the NFPA, ICC, IFSAC, ProBoard. All private non government for profit orginazations that have a profound influence on fire prevention/protection.
Great comments. The Joint Council in your area must be doing a superior job with fire safety in the hospitals. I see it from the inside quite differently.
When a hospital lost it "deemed status" with a CoP out of compliance, I had to do a complete Life Safety Code compliance survey of the entire facility using the CMS survey policies and procedures. The facility was not happy when I entered the building and let them know I would be conducting a facility wide Life Safety Code survey for CMS. The CMS regional offices were required to review their plans of correction. From those experiences, I expected two to three times more fire safety deficiencies than the TJC would have discovered. I would say the TJC did not pay much attention to fire safety standards as the clinical standards.
I must say the accreditation, which costs the facility a considerable amount of money, was to attract quality health care professionals because of the: disease management programs; clinical practice guidelines help organizations establish a consistent approach to care; an opportunity for staff to develop their skills and knowledge; promotes an environment of continuous improvement in the care of patients; advantage in a competitive health care marketplace and improve the ability to secure new business; a strong statement to the community about an organization’s commitment to providing the highest quality services; and certification may meet certain regulatory requirements in some states, which can reduce duplication on the part of certified organizations.
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