Temporary source systems

  • Friday, July 08, 2022 7:15 AM
    Message # 12842148

    Are there any NFPA code references for temporary back-feed systems used for supplying a hospital with vacuum and medical air temporarily while the source systems are being replaced?

    Also, can a simplex vacuum system be used as a backup to a fully code compliant system? The hospital maintains that a simplex back-up system would be better than no back-up should the main system go down. I'm having trouble finding an NFPA code reference that addresses these issues and wondering if anyone has come across this before.

  • Saturday, July 09, 2022 9:55 AM
    Reply # 12843175 on 12842148
    Al Moon (Administrator)

    In my opinion only and to best of my knowledge.

    NFPA 99 ready does not cover back-up systems or the back feeding of the medical gas or medical vacuum systems in the equipment sections. In the certification / verification section temporary systems are listed to be tested.  As a whole NFPA 99 is a document for installation, maintenance and testing of medical gas and medical vacuum system.

    Yes, it covers the main systems with its many sections and chapters.

    Can we review the words / TEMPORARY VIS EMERGENCY?   

    (Like understanding the words:   TRAUMA - TREATMENT / EXAM & TRIAGE)

    EXAMPLE 1:

    The bulk oxygen site needs a major repair for parts and labor and will take time to complete. I would think the goal would be to supply a TEMPORARY compliant NFPA 99 system. (i.e. that's why NFPA 99 for the 2021 edition, has required all the local signals from the EOSC, be wired directly to the two master alarm panels) 

    EXAMPLE 2:

    The bulk oxygen site was just struck by a Tornado. OMG - The facility needs an EMERGENCY set up. I would think the goal would be to supply the hospital / patients with USP Oxygen ASAP. In the words of Larry, the Cable Guy.



    In regard to the question simplex vis duplex back up. There is precedence in the NFPA 99 Code. This precedence is in the code concerns the In-House Oxygen Backup being a replacement for the EOCS. The In-House Backup system is not required to have a duplex final line regulators set.  




    Any Profession That Is Life Supporting / Is Life Threatening In The Wrong Hands

    Last modified: Friday, July 22, 2022 7:07 AM | Al Moon (Administrator)
  • Sunday, July 17, 2022 9:00 AM
    Reply # 12851469 on 12842148

    While I always appreciate Al's opinions and his commitment to the industry, I have to respectfully disagree with this interpretation.

    The way I interpret the code requirements with regard to "temporary" systems, is that they have to meet the same requirements as "permanent" systems.  This should not be confused with "emergency operations," which allow the health care organization to do what is necessary to keep patients safe regardless of the code requirements.  This would only occur under emergency operational status.

    For temporary systems, which would be used during a planned shutdown of the existing systems, the same level of patient protection, system redundancy, and monitoring must be maintained during operation.  There are a few indicators in the code that help validate this interpretation.

    The first being that the code simply states that piped medical gas systems must meet the requirements of the code.  There is no distinction in the code requirements between permanent and temporary systems.

    The second can be found in the Performance Criteria and Testing requirements found in 5.1.12 of the code.  It states in the very first paragraph of the general section the following. 

    Inspection and testing shall be performed on all new piped medical gas and vacuum systems, additions, renovations, temporary installations, or repaired systems to ensure, by a documented process and procedure, that all applicable provisions of this document have been adhered to and system integrity has been achieved or maintained.

    This to me is a clear indication that we expect the temporary systems to follow the exact same code requirements as any other system.  As a verifier, I would expect the systems to be subjected to the same testing, inspection, and verification requirements as a brand new system, and my code requirement checklists and testing procedures would remain the same as any other verification.

  • Friday, July 22, 2022 2:42 PM
    Reply # 12857990 on 12842148

    I have always interrupted the code the same as Jonathan's post.

    This is especially true with temporary supply systems that are in place for an extended period of time.

    I have seen temporary supply systems installed for as much as a year.

  • Sunday, July 24, 2022 12:07 PM
    Reply # 12859353 on 12842148

    I’ve been holding off to chime in. I agree with both thoughts that have been expressed. If we want to get technical Jonathan is correct. That does not make him right. Lately I don’t think of NFPA 99 as being a National Fire Protection Association book. It seems to have turned in to a patient safety book.

    With that said a properly installed emergency temporary backup system (with a notification that the back up system has been activated) (not necessarily meeting the full code compliance ) is readily available to the facility should either for safe maintenance or should there be a major failure on the main supply system just makes patient safety sense.

    The 2012 edition went through a major revision. NFPA 99 was changed from a standard to a code to reflect how the document was used and adopted and to indicate how health care is delivered. The risk to the patient does not change for a given procedure; if the procedure is performed in a doctor’s office versus a hospital, the risk remains the same. Therefore, NFPA 99 eliminated the occupancy chapters and transitioned to a risk-based approach. The new Chapter 4 outlined the parameters for this approach. The code reflected the risk to the patient in defined categories of risk. The health care organization shall ensure that policies are established and maintained that permit the attending medical professional to supersede the requirements of this code in order to satisfy the emergency needs of any patient. Each application of the provisions of, where this code's requirements are superseded to satisfy the emergency needs of a patient, shall be clearly documented and reviewed with the intent of meeting similar future needs within the requirements of this code.

    Through a risk assessment do whatever it takes to keep the patient safe.

    So as a verifier document what you see and remind them that they must do a risk assessment on the systems that they have stalled either permanently or temporary, or temporary permanent. If they have a system that is in full compliance and have installed a back up system not in full compliance for emergencies I do not have an issue with this.

    This is a personal opinion based on real life experience.

    Last modified: Sunday, July 24, 2022 12:55 PM | Don Holden
  • Tuesday, July 26, 2022 6:10 PM
    Reply # 12863326 on 12842148


    I don't think we are saying anything different.  I agree that a temporary system (installed prior to or during an emergency) specifically for "emergency preparedness" does NOT need to meet the requirements of NFPA 99.  There is no mandate in the code that says otherwise for these systems (in my humble opinion and as far as I can tell).

    However, the distinction I was trying to make (Maybe not as clearly as I'd hoped) is that a temporary supply system that is going to be used as a substitute for the primary supply system...usually during a planned and controlled shutdown (i.e. a temporary bulk system [cryogenic fluid central supply system] that serves the hospital while the primary supply is shutdown for repairs or replacement) must in fact meet all of the requirements of NFPA 99 if used under "normal" (non-emergency) operations.  This is clear to me, but maybe others see it differently.

    I think that was the crux of the original question as Matthew was talking about a simplex vacuum system being used to back feed the pipeline and whether or not that would be acceptable for a planned shutdown and replacement of the existing vacuum system, AND I believe it is NOT acceptable to use a temporary system for this purpose that doesn't have the backup and redundancies outlined in the code.

    Not to confuse the issue, but remember that there is the "equivalency" clause in the code that allows the AHJ to accept alternative methods to those prescribed in the code (i.e. alternative monitoring of the temp systems instead of meeting all the alarm monitoring requirements OR maybe even allowing a simplex system if not serving patients relying on the system for survival), but this is only with the approval of said AHJ.  The code also allows the AHJ to waive requirements if they can be convinced to do so.  This would be one way to bypass the code requirements for these temporary systems, but we don't see that really ever happen if there is a concern for patient safety.

    Although, I recognize that you are in the middle of no where.  So, it might be more prevalent on the islands :)

    Hope you're well!!!

  • Thursday, July 28, 2022 10:46 AM
    Reply # 12865766 on 12842148

    The biggest issue I see is exactly what is the definition of "temporary" ?

    Is it for a few hours during a scheduled shutdown or do they expect to see the "temporary system" in place for months ?  Customers lie constantly.

    We always require temporary systems to meet the current code.

    If they don't,  we write it up as a deficiency and throw the ball back into their court.

    We've seen too many "temporary, but not really temporary" systems through the years that don't come close to being code compliant.

16339 Kranker Drive, Stilwell, KS 66085