The new chapter (Chapter 15) on dental gas and vacuum systems in NFPA 99 2018 has caught the attention of AHJs, architects, dental supply companies, fire marshals, building officials, landlords, and now even dentists themselves. This was the intended effect, but the current problem is that the 2018 edition of the code has not yet gone into enforcement. Instead what many dentists are discovering is that they are being told that they must meet the code that is currently in enforcement (usually either 2012 or 2015).
As a clinician and an advocate of safe gas systems in dental offices and patient safety, it seems that we have created a temporal dilemma with the new chapter. Please allow me to explain further: Chapter 15 has less strict compliance standards for dental offices when compared to Chapter 5. This was obviously done for a reason, and as a clinician that is both a dentist and anesthesiologist, I believe that this was done because of the relatively low surgical risk of dental procedures. This, in my interpretation, is why Chapter 15 Categories are based solely on the level of sedation and anesthesia provided in the facility. From this, it would make logical sense that if dental offices are suddenly going to have more uniform enforcement of building standards, they should be held to the current 2018 NFPA 99 standards.
Herein lies my question: Is there a process or protocol for dental offices to request to be certified under the new 2018 Chapter 15 code standards even though the locality may still be using 2012 or 2015 NFPA 99? Allow me to use a de-identified but concrete example. Dr X is building a practice and unfortunately during the design no one has instructed them that by providing anesthesia or sedation they are anything other than a Category 3 (by Pre 2018 NFPA 99). With the sudden increase in education regarding code compliance for dental offices, this dentist is now informed they must meet Category 1 or 2 standards. Dr X is confused and unaware of this, but in this case was told he must now complete a risk assessment to determine if the office will be Category 1 or 2 since they provide sedation at the office and also plan to have an anesthesia provider. (The office should be Category 1 based on an anesthesia provider assuming they do deep sedation or GA) However, a more stringent level of compliance is being applied using Chapter 5 instead of the new Chapter 15. What can dental offices do about this temporal gap from code creation to code enforcement, especially given such a drastic change as dentistry getting its own chapter and own version of piped gas rules?