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Health Care Facilites Risk Categories

  • Thursday, February 28, 2019 10:49 AM
    Message # 7191908

    I recently had a discussion with a manufacturer of a devise that typically is used and installed in dental facilities, but more recently these devises are being used and installed in hospital Labor and Delivery Rooms.

    In this discussion about a code discrepancy, this manufacturer stated that I was misinterpreting the NFPA 99 code, because the use of this devise is to be considered a Category 3 installation, because the patients using this devise are not critical care patients nor are they be anesthetized, both of which would typically require the space to be considered Category 1.

    My question is this... Can a facility pick and choose spaces or areas within there facility to be designed, installed, and tested to the Category 3 requirements, while adjacent spaces or areas are considered Category 1?

    This facility has not performed a documented risk assessment to categorize this space or area as a Category 3.

    It has been my understanding that if any portion of the facility is to be considered anything but a Category 1 space, that they need to have performed and documented a risk assessment.

    This manufacturer is telling facilities that they do not need to meet Category 1 requirements when deploying these devises into hospitals, because they were built to the Category 3 requirements, and since this devise only allows for sedation to the minimal sedation level, it automatically falls under Category 1 requirements.

    To further explain this issue that we identified at this facility, is that the facility installed WAGD inlets (ceiling mounted) with gas specific hose drops, to be used in conjunction with this devise for minimal sedation of patients. When they received these devises from the manufacturer, the hose and connection for the exhaled anesthetic gases, had a medical vacuum adaptor. When the facility inquired about this discrepancy with the manufacturer (why medical vacuum adaptor, instead of WAGD adaptor) they were told that WAGD was not needed, and their warrantee would be voided if the facility changed the adaptor on the end of the devise hose to WAGD. So the facility cut the quick coupler (WAGD) off of the hose drop from the veiling inlet and replaced it with a medical vacuum quick coupler. This is what we discovered and brought to their attention. They have a WAGD inlet at the ceiling, connected to piping labeled WAGD, a purple hose drop, and now a white medical vacuum quick coupler on the end of the hose, that is connected to the devise hose.

    In our opinion, this is no longer a gas specific connection.

    What are your thoughts?

  • Friday, March 01, 2019 8:29 AM
    Reply # 7193418 on 7191908

    Bob,

    You have touched on one of the tender spots in the new 99.  We can see the bud  of this, but we have yet to see the flower, and less do we know if the flower will be sweet or stinky.

     

    In the 2018, two key design rules are now Category dependant - the provision of zone valves and the provision of alarms.  They are now required for "all Category 1 spaces" (vs. "all critical care and vital life support areas" as in former versions (5.1.4.6.2/5.1.9.4)).  In order for this rule to work, it is now essential that each occupancy in the building be separately assessed for it's "Category".  If you take the lazy man's approach and say General Hospital = Category 1, you are going to have to valve and especially alarm everything, which is going to get expensive.

    So to answer your point, Yes, each occupancy now needs a separate "Category" decision. 

    To my mind, the manufacturer in question has things upside down - no device determines Category, nor does the level of Anesthesia determine Category.  The only thing that can determine Category is the facility's risk assessment (4.2). Level of anesthesia certainly could be part of the facility's decision process, but that is for them to decide.

    Thus, if by the manufacturer's assertion the "device was built for Category 3", then I suppose it may be used in Category 3 locations.  That is really all that can be said.  Can it be used in "higher" Category locations?  That is for the facility alone to decide.  

    Now, I have been speaking from the Chapter 5 (medical) viewpoint.  Chapter 15 (dental) does determine Category by level of anesthesia.  Interesting perhaps but irrelevant, as you are not in a dental facility.

  • Monday, March 04, 2019 5:43 PM
    Reply # 7199415 on 7191908

    Hi Bob,

    Having a white vacuum inlet at the end of a violet hose is similar to having a Schrader Air outlet on a Nitrogen Control Panel.  It is no longer gas specific.


    Hi Mark,

    I was thinking that levels of anesthesia do help determine what category of system is required in Chapter 5.  In 5.1.1.2 (2018) Category 1 shall be applied where general anesthesia or deep sedation is performed.

    Deep sedation and general anesthesia are not permitted with a Category 2 or 3 system.  5.2.1.2 and 5.3.1.2.


    There are some nice examples of the different category spaces listed in annex A beginning at A.3.3.136.1.

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