November 28, 2017 | | Comments 7
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Know the medical gas cylinder storage requirements

Editor’s note: This update was provided by Brad Keyes, CHSP, owner and senior consultant for Keyes Life Safety Compliance, LLC, and a consulting editor for Healthcare Life Safety Compliance.

 The following medical gas cylinder storage requirements are relative to the National Fire Protection Association (NFPA) Standards 99 Health Care Facilities (2005 edition) and are updated for 2017. In January 2007, CMS issued Survey and Certification memo 07-10, which clarified how oxygen cylinders should be stored, based on the 2005 edition of NFPA 99. The Joint Commission and the other accreditation organizations (AO) have adopted these clarifications and established clear requirements concerning medical gas cylinder storage. These AOs will assess your facility for compliance based on the following standards.

Medical gas cylinder storage

  • An aggregate total of compressed medical gases (e.g., oxygen, nitrogen, nitrous oxide) up to 300 cubic feet may be stored per smoke compartment in any room or alcove without special requirements for that room. Compressed gas cylinders must be secured in racks or by chains.
  • Quantities of compressed medical gases of more than 300 cubic feet but less than 3,000 cubic feet must be stored in specially designated rooms that meet the following requirements:
    • Rooms must be of noncombustible or limited-combustible construction (gypsum wallboard, tiled walls, etc.) with a door that can be secured from unauthorized entry (e.g., locked).
    • Oxygen may not be stored with other flammable gases or liquids.
    • Oxygen cylinders must maintain a minimum distance of 20 feet from combustibles (5 feet if room is sprinklered) or be placed within an enclosed cabinet having a fire rating of at least a half hour.
    • Cylinders must be secured in racks or by chains.
  • Quantities of compressed medical gases more than 3,000 cubic feet must be stored in specially designated rooms that meet the following requirements:
    • The room must have sufficient room to maneuver cylinders.
    • The room is able to be secured with lockable doors.
    • The room is constructed with noncombustible or limited-combustible construction, with a minimum fire rating of one hour (no allowances for fully sprinklered rooms). The entrance door to this room must also be fire rated for one hour, and not ¾ hour as allowed for other one-hour rated barriers.
    • The room is compliant with NFPA 70 National Electric Code, with electrical devices located at or above 5 feet from the finished floor.
    • The room is heated by indirect means, if heat is required. “Indirect” means gas-fired unit heaters and electric unit heaters are not permitted. Steam or hot water heating systems are permitted.
    • The room contains adequate racks constructed of noncombustible or limited-combustible materials and chains to secure all cylinders, full or empty.
    • The room contains a dedicated, continuously operating mechanical ventilation system that draws air from within 12 inches of the floor, with a means of make-up air provided.
    • In lieu of a mechanical ventilation system, and where natural ventilation is permitted, the room includes a natural ventilation system consisting of two louvered openings, each having a minimum free area of 72 square inches with one opening located 12 inches from the floor and the other located 12 inches from the ceiling. NOTE: Louvered natural ventilation openings are not permitted in an exit access corridor.

Definitions

  • One E-size cylinder = 24.96 ft.³
  • Twelve E-size cylinders = 299.52 ft.³
  • Therefore, up to 12 E-size cylinders may be stored in any smoke compartment without special requirements for the room.
  • One H-size cylinder = 250 ft.³
  • Therefore, one H-size and two E-size cylinders may be stored in any smoke compartment without special requirements for the room.
  • Cylinders on gurneys, crash carts, wheelchairs, etc., are considered “in use” and not subject to the total count for “in storage.”
  • Cylinders in a rack are “in storage.”
  • Empty cylinders are not considered part of “in use” or “in storage.”
  • A cylinder is considered “full” provided it still has its seal from the supplier. Once the seal has been removed, the cylinder is no longer considered full and cannot be stored with full cylinders.
  • NFPA 99 requires empty cylinders to be stored separately from full cylinders. This means partially full cylinders must be stored with the empty cylinders or stored separately from full or empty cylinders.
  • For the purpose of calculation of aggregate quantities of stored medical gas cylinders, empty cylinders must be considered as full cylinders since residual gas will remain in the cylinders.

Entry Information

Filed Under: Standards and Elements of Performance

Brian Ward About the Author: Brian Ward is an Associate Editor at HCPro working on accreditation news.

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  1. This article is stating that full and partials may be stored together and that empties must be stored alone.Could you please clarify for me
    Thx

    https://www.jointcommission.org/mobile/standards_information/jcfaqdetails.aspx?StandardsFAQId=1732&StandardsFAQChapterId=4&ProgramId=0&ChapterId=0&IsFeatured=False&IsNew=False&Keyword=

  2. Brian Ward

    Hi Lisa,

    Joint Commission did a 180 and reversed their position. Full and partial containers have to be kept separate.

  3. Is there a standard on when a tank should not be used to provide oxygen for a hospitalized patient? Is there a point at which an oxygen must be replace and cannot be used?

  4. Brian Ward

    There’s no NFPA standard that limits the number of oxygen cylinders used in a healthcare setting. Obviously, there are limits on storing oxygen cylinders, but none that I’m aware of that limits the use of the cylinders.

  5. Hi Brian,

    I saw you answered Lisa that TJC did a 180 and are now stating full and partials must be separated, however I cannot find anything stating this. Their website still states partials can be stored together. We are currently changing policy and I am needing to clarify. Is there documentation anywhere to confirm their position is to separate?

    Thank you very much for your time.
    Darin

  6. Brian Ward,
    Can you provide a link to that new position? The Joint Commission website still shows that full and partial tanks can be stored together as of 8/14.

  7. Brian Ward

    Hi all,
    Sorry for the long delay.
    In 2016 TJC published a standards FAQ that states “Full and partially full cylinders are permitted to be stored together, unless the organization’s policy requires further segregation.” It’s the third sentence in the first paragraph.
    In February of 2018 Patton Healthcare did a further write up about the changes in their newsletter.
    We also reached out to Steve MacArthur, a hospital safety consultant with the Greenly Company to get more information. Let me know if you need more.

    “TJC has changed their position on the storage of oxygen cylinders, though it is very difficult to figure out exactly when they had their change of heart. Prior to the change, TJC’s interpretation was that full cylinders had to be segregated from partials and empties:

    NFPA 99-2012

    11.6.5.2 If empty and full cylinders are stored within the same enclosure, empty cylinders
    shall be segregated from full cylinders.

    11.6.5.3 Empty cylinders shall be marked to avoid confusion and delay if a full cylinder is
    needed in a rapid manner.

    NFPA 99-2005

    9.7.5.2 If stored within the same enclosure, empty cylinders shall be segregated from full cylinders.

    9.7.5.3 Empty cylinders shall be marked to avoid confusion and delay if a full cylinder is needed in a rapid manner.

    In looking at the two most recent source documents (the 2005 and 2012 editions of NFPA 99), there really isn’t an appreciable difference in the intent, so I’m going to guess that the change in interpretation is the result of pushback from folks in the field (perhaps through the auspices of ASHE). I can say for as certainly as I can say without having any evidence (I don’t think they archive the FAQ’s, though there may be something in past Perspectives) that they definitely used to hold folks to segregating fulls from partials/empties, but now they don’t.

    What NFPA 99 indicates is still somewhat gray because it doesn’t speak to partially full cylinders and as they (more or less) represents an accreditation organization. At any rate, I did do an update in my blog earlier this year (http://blogs.hcpro.com/hospitalsafety/2018/03/cylindrical-musings-and-nudging-as-a-compliance-strategy), so it’s not like it passed unnoticed, though I didn’t “see” the change in the FAQ until someone had pointed it out (they used to do a good job of identifying when FAQs were updated/revised, but lately, not so much).”

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