Future Shock: Proposed NFPA 99 Wet Location Revision Revives a Bad Idea

June 1, 2011 | Evaluations & Guidance


For healthcare facilities in the United States, the National Fire Protection Association’s NFPA 99: Standard for Health Care Facilitiesis one of the most important performance standards on electrical safety. The most current version of NFPA 99 is the 2005 edition. Although the standard is typically updated every three years, review and revision of the most recent edition has taken far longer. The updated edition of NFPA 99 is currently scheduled to be released later this year as the 2012 edition.

Although a great number of changes to NFPA 99 have been proposed, none of them is as controversial as the proposal that ORs should be considered wet procedure locations unless a risk assessment performed by the facility determines otherwise. (Currently, it is up to the governing body of the facility to determine what areas will be designated as wet locations.) Areas designated as wet locations must be provided with special precautions, such as isolated power systems (IPSs) or ground-fault circuit interrupters (GFCIs), to safeguard against electric shock. However, we find the proposal to be problematic, since it has not been established that these precautions would provide significant benefit, and, in the case of GFCIs, they may actually present additional risks that could endanger patients.

ECRI Institute opposes the proposed change to consider ORs to be wet locations. We believe that these precautions are unnecessary and may place a substantial financial burden on hospitals and needlessly waste resources, with no corresponding benefit to staff or patients. In this article, we outline our reasons for opposing the change. We also provide an overview of other proposed revisions to NFPA 99 concerning electrical equipment, many of which will result in more flexible requirements, and answer some common questions on electrical safety.

NFPA 99 establishes “criteria to minimize the hazards of fire, explosion, and electricity in health care facilities” (2005 edition, section 1.1.1). It is intended for use by healthcare facilities, parties involved in the design and construction of these facilities, and medical device manufacturers. Although it is a voluntary standard, NFPA 99 is referenced or adopted by many state and local authorities and is therefore binding on many healthcare facilities in the United States. It includes chapters on electrical distribution systems, gas and vacuum systems, environmental systems, materials, electrical equipment, gas equipment, and laboratories.

Recently, NFPA 99 was put under an extended review and update schedule in order to revise the current 2005 edition and transform it into a code. This transformation involves reorganizing the document, revising certain passages to reflect requirements rather than commentary or guidance, and reviewing provisions to ensure relevancy with today’s healthcare environment and to verify that they would have a positive impact on safety and healthcare. Although NFPA had hoped to release a 2010 edition, the NFPA membership returned the proposed standard to the committee after a vote in June 2009, citing a combination of technical issues that included a debate on wet locations and the lack of a preprint version. As a result, the standard was required to undergo the review process again, and is now due for another vote at NFPA’s annual conference in June 2011. If approved, the new edition will be issued as the 2012 edition and will be designated NFPA 99: Health Care Facilities Code. (Note that, in this article, we continue to refer to the document as a standard, rather than...

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