Within Our NFPA 99 Code We Have: 

Manufactured Assemblies

Factory assembled products designed for aesthetics or convenience that contain medical gas or vacuum outlets/inlets, piping or devices related to medical gases:

(see 2021 NFPA 99 part 3.3.104)

?? True or False ??

A Standard Medical Gas Outlet or Medical Surgical Vacuum Inlet.

Is NOT a Manufactured Assemblies ?

Hello everyone.

I've come across an interpretation that is completely clear to me; however, there could be more than one possible interpretation ass I was told.

I'm referring to the mandatory or non-mandatory requirement of Iber's for oxygen systems where the oxygen supply source is located outdoors and remote from the building it serves.

The EOSC first appeared in the 1987 version (I don't have NFPA 56F to see if it already existed in that standard). In this version, it only establishes one criterion that must be present for it to be required, which was that the oxygen supply source (cryogenic or otherwise) must be located outdoors.

4-3.1.10 Emergency Oxygen Supply Connection

4-3.1.10.1 Where the oxygen supply, cryogenic or other, is located outside of the building served, there shall be incorporated in the piping system an inlet for connecting a temporary auxiliary source of supply for emergency or maintenance situations.

However, in NFPA 99-2002 it is included among the minimum requirements to be met in .1.3.4.13 In-Building Emergency Reserve. This establishes a couple of relevant criteria.

5.1.3.4.13.1 In-building emergency reserves shall not be used as substitutes for the bulk gas reserves that are required in 5.1.3.4.11.4.

5.1.3.4.13.2 If a reserve is provided inside the building as a substitute for the EOSC, it shall be located in accordance with 5.1.3.3 as follows:

(1) In a room or enclosure constructed per 5.1.3.3.2

(2) In a room or enclosure ventilated per 5.1.3.3.3

5.1.3.4.13.3 In-building emergency reserves shall consist of either of the following:

(1) A gas cylinder header per 5.1.3.4.8 with sufficient cylinder connections to provide for at least an average day’s supply

(2) A manifold for gas cylinders complying with 5.1.3.4.9

I do not see on these specifications any call, criteria or any conditions that establish that this new mandatory element can be omitted or "replaced" by another element.

In this same version of NFPA 99-2002, it establishes new criteria for the implementation of the EOSC, and under what conditions this EOSC is required.

5.1.3.4.12* Emergency Oxygen Supply Connection (EOSC). EOSCs shall be installed to permit connection of a temporary auxiliary source of supply for emergency or maintenance situations under the following conditions:

(1) Where the bulk cryogenic liquid central supply system is outside of and remote from the building that the oxygen supply serves.

(2) Where there is not in the building a connected oxygen reserve sufficient for an average day's supply. (See 5.1.3.4.13 for requirements for such reservations.)

(3) Where multiple freestanding buildings are served from a single oxygen source such that damage to the interconnecting oxygen line could result in one or more buildings losing oxygen supply. In this situation, each building shall be provided with a separate emergency connection.

As we can see in 5.1.3.4.12(2), a condition is established that makes the EOSC mandatory: the existence of an Iber where the internal reserve within the building is NOT SUFFICIENT to supply an average day's supply. This criterion suggests that there is a possibility that the Iber may not be sized to meet the requirement for an average day's supply, and in this scenario, an EOSC would be mandatory.

If we analyze why the EOSC and later the Iber were included in the NFPA 99 Code, it is the possibility that the cryogenic oxygen supply source located outdoors or the piped distribution network could suffer damage that would leave the healthcare facility without oxygen supply.

In the case of the EOSC, it is clearly not a solution to a scenario such as the loss of the oxygen supply source, since there is no temporary source connected to supply the distribution network. I remember hearing few years ago that Jonathan Willard submitted for consideration the proposal to change the name of the EOSC to Maintenance Oxygen Connection (Jonathan corrects me if I'm wrong), since the requirement for an emergency solution was not met due to the lack of a connected source.  Based on the above, and in response to the risk analysis that showed a real possibility of patients being left without an essential medication like oxygen, there are documented events with many fatalities for the failure of the cryogenic source, the IBER (Emergency In-Building Reserve) is included in NFPA 99-2002. This emergency reserve includes a connected oxygen supply that will automatically activate in the event the central oxygen supply is lost. (https://www.dw.com/en/india-22-covid-patients-killed-after-oxygen-leak/a-57276790)

Based on the above referenced and established in the code in version 2002 regarding the EOSC and the Iber, and which has been maintained until version 2024, I consider that compliance and implementation of the Iber (emergency reserve within the building) is mandatory, when the central source of bulk oxygen supply is located outdoors and remote from the building served, additionally, the mandatory installation of an EOSC must be considered when the sizing of the Iber is less than the average supply of a day.

Having said this, I would like to know the opinions of the members of this large group of experts on the subject, regarding of the interpretation of those requirements.

Robert Kroening wrote:

Jose,

I believe the issue with your position is the difference between the referenced In Building Emergency Reserve and the Reserve.

These are two distinct supply systems. They are not the same.

A reserve is a component of the source system and is mandatory. It is most often located with the primary supply, but is not mandated to be located with the primary. If the reserve is not located with the primary supply, but located within the building, the referenced code section becomes relevant.

If the facility has an Emergency Oxygen Supply connection, then an IBER is not required. The facility has the option to install an IBER instead of an EOSC.

Thanks, Robert.

I have no confusion regarding the cryogenic fluid source system reserve or its configuration.

My position is regarding the Iber, which, being included in the code, is a mandatory requirement. In the case of the EOSC, it establishes that if there is an Iber sized for a day's supply, it is no longer required. It doesn't say otherwise. If it said, "if an EOSC exists, the Iber is no longer required," I would agree with your position.

For two elements to be substitutes for one another, it must be assumed that both are capable of performing the same function, and this is not the case. The Iber offers automatic oxygen supply upon activation, and the EOSC does not offer that condition.

In my opinion only:

I agree with Mr. Kroening / The In Building Emergency Reserve is only an option for an EOSC - NOT a requirement in addition to the EOSC.

Now let's run some numbers.

(first off I'm rounding the number up and down a little)

In the USA there are around 6,000K Hospitals.

In the USA there are 980,000K Hospital Beds. 

This would made this average size hospital bed size of 160.

One Single Oxygen (H) Tank/Cylinder suppling a patient at 4/5 LPM.

Will Only Last That Patient (24 Hours).

(again from the charts - I have had for years)

? how many tanks/cylinders shall this average size 160 bed hospital have connected ?

? what if the hospital was now 500 beds ?