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NFPA 99 - Shared med gases - Humans/Animals

Question asked by mhart on Dec 4, 2018
Latest reply on Dec 26, 2018 by bob.sutter

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New guy here, first post.

Per 2018 NFPA 99 para 1.3 Application:

This Code shall apply to all health care facilities other than home care and veterinary care.

This is the only use of the word "Veterinary" in NFPA 99. I can find no AHJ type of criteria requiring separation of these two systems. Spoke to one of our local Third Party Certifiers, and they were also not aware of any rulings disallowing this interconnection.

Did some googling, and about the only references I can find are specific-institution requirements.

MD Anderson (a nationwide health care provider) does not allow it.

LSY (a major Architectural firm on the east coast with major Health Care projects) does not allow it.

The VA (Veterans Administration) Plumbing Design Manual does not allow it.

A client we are working with wants to combine these systems to save costs; and I can find no AHJ requirements to disallow their inclination. Note that there Veterinary Service already uses a WAGD system, as do the other Med Vacuum user areas, so that issue is not a concern.

In general, this sounds like a bad idea, regardless that it is not specifically disallowed. NFPA has not allowed combined Dental/Medical vacuum for years. This combined Veterinary/Medical vacuum seems similar enough to also be not allowed.

Comments welcome.

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milt.werner Dec 4, 2018 6:31 PM

Hi Mitch:

Our state licensing of health care facilities would not allow a non-health care facility use of a health care facility's medical gas system including vacuum systems because the state health care facility licensing agent has no enforcement authority in non-health care facilities to ensure the performance, maintenance, installation and testing of the portion of the system in the non-health care facility are in accordance with NFPA 99 for the protection and safety of the patients in the licensed health care facility.

You are correct NFPA 99 does not apply to non-health care facilities. It is the AHJ that administers and enforces the code not NFPA.

You may get approval from the local AHJ for the connection but highly improbable at the state and federal AHJ level.

Excerpt from 2018 NFPA 99:

Respectfully,

Milt Werner

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milt.werner Dec 6, 2018 12:48 PM

I wanted to add these sections of the 2018 NFPA 99 that support the limitations and prohibited uses of central system systems for medical gases.

To me the Veterinary services are nonmedical applications as supported by common English definitions.

Veterinary meaning: of, relating to, practicing, or being the science and art of prevention, cure, or alleviation of disease and injury in animals and especially domestic animals

Nonmedical meaning : not involving, relating to, used in, or concerned with medical care or the field of medicine : not medical.

Medical meaning : of, relating to, or concerned with physicians or the practice of medicine

Vacuum system use prohibitions in NFPA 99.

Definitions:

With all the above being said: In my opinion, Section 5.1.14.1.4 of the 2018 NFPA 99 would prohibit the medical-surgical vacuum system for humane medicine from being combined with Veterinary services.

Respectfully,

Milt Werner

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mhart @ milt.werner on Dec 13, 2018 11:05 AM

Milt,

Thank you for your reply and relevant NFPA Section quotes. This does indeed seem to clarify the situation, unequivocally.

While I am pretty sure the Third Party Certifier would have caught this at inspection time, this project is only in the design stages, and has not officially crossed their desk. I hate being blindsided by an "uh oh", when everyone is thinking the project is about done and ready to move in. Much easier on all when we are confident of the results in design.

We seem to see this more and more, with requests to ...maybe not bend, but to ...interpret Codes in support of cheaper outcomes. "If the Code does not explicitly say we can't do something, then what's the problem?".

My (somewhat) snarky reply that there is also no listed prohibition against operating an arc welder in a staffed and functioning OR Theater either, but that it would probably not be conducive to a positive patient outcome...

Thanks again,

Regards,

Mitch

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bob.sutter @ mhart on Dec 26, 2018 10:43 AM

Hello Mitch,

Because the veterinary system would contain a drug product (oxygen USP) as defined in the Federal Food Drug and Cosmetic act the system will need to be installed in accordance with the Food and Drug Administration (FDA) Current Good Manufacturing Practices (CGMP's).

Regards

Bob S.

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milt.werner Dec 4, 2018 6:31 PM
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Hi Mitch:

Our state licensing of health care facilities would not allow a non-health care facility use of a health care facility's medical gas system including vacuum systems because the state health care facility licensing agent has no enforcement authority in non-health care facilities to ensure the performance, maintenance, installation and testing of the portion of the system in the non-health care facility are in accordance with NFPA 99 for the protection and safety of the patients in the licensed health care facility.

You are correct NFPA 99 does not apply to non-health care facilities. It is the AHJ that administers and enforces the code not NFPA.

You may get approval from the local AHJ for the connection but highly improbable at the state and federal AHJ level.

Excerpt from 2018 NFPA 99:

Respectfully,
Milt Werner
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milt.werner Dec 6, 2018 12:48 PM
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I wanted to add these sections of the 2018 NFPA 99 that support the limitations and prohibited uses of central system systems for medical gases.

To me the Veterinary services are nonmedical applications as supported by common English definitions.

Veterinary meaning: of, relating to, practicing, or being the science and art of prevention, cure, or alleviation of disease and injury in animals and especially domestic animals

Nonmedical meaning : not involving, relating to, used in, or concerned with medical care or the field of medicine : not medical.
Medical meaning : of, relating to, or concerned with physicians or the practice of medicine

Vacuum system use prohibitions in NFPA 99.

Definitions:

With all the above being said: In my opinion, Section 5.1.14.1.4 of the 2018 NFPA 99 would prohibit the medical-surgical vacuum system for humane medicine from being combined with Veterinary services.

Respectfully,
Milt Werner
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- mhart @ milt.werner on Dec 13, 2018 11:05 AM
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  Milt,
  Thank you for your reply and relevant NFPA Section quotes. This does indeed seem to clarify the situation, unequivocally.
  While I am pretty sure the Third Party Certifier would have caught this at inspection time, this project is only in the design stages, and has not officially crossed their desk. I hate being blindsided by an "uh oh", when everyone is thinking the project is about done and ready to move in. Much easier on all when we are confident of the results in design.
  
  We seem to see this more and more, with requests to ...maybe not bend, but to ...interpret Codes in support of cheaper outcomes. "If the Code does not explicitly say we can't do something, then what's the problem?".
  
  My (somewhat) snarky reply that there is also no listed prohibition against operating an arc welder in a staffed and functioning OR Theater either, but that it would probably not be conducive to a positive patient outcome...
  Thanks again,
  
  Regards,
  Mitch
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  - bob.sutter @ mhart on Dec 26, 2018 10:43 AM
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    Hello Mitch,
    Because the veterinary system would contain a drug product (oxygen USP) as defined in the Federal Food Drug and Cosmetic act the system will need to be installed in accordance with the Food and Drug Administration (FDA) Current Good Manufacturing Practices (CGMP's).
    Regards
    Bob S.
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NFPA 99 - Shared med gases - Humans/Animals

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