I thought I would share a project I am working on currently that could be interpreted a couple of ways. I am working on a Category One hospital small renovation project for HDR that involves an existing imaging suite with an MRI and two holding bays. HDR has been hired to add two more MRI units and equipment in the room.
The existing MRI bay is located behind a key card-accessible door off a main corridor. This MRI room and two holding bays contain a full spectrum of medical gasses (medical air, oxygen, vacuum, WAGD and nitrous oxide), with a zone valve and area alarm panel. See Figure 1 for the existing conditions.
One of the first things I did was request the risk assessment be provided, and I reviewed the 2010 FGI to see what gases would be required by code in the MRI as a minimum.
Per table 2.1-6 in the FGI, a minimum medical gas requirement in the MRI is only (1) oxygen, (1) medical air and (1) medical vacuum per room. The facility has requested WAGD and nitrous oxide be provided as well.
I reviewed the code sections in the 2012 NFPA 99 section 18.104.22.168.6, 22.214.171.124.7 and 126.96.36.199.7.2, and was a little confused at first, but I came to my own conclusion and figured I would take this learning/teaching opportunity to discuss among my inspectors, verifiers, city officials and other colleagues to see how they would interpret this condition with code.
I experimented a little with the way I posed the question. My goal was to see which code interpretations I would receive based on a short description and a reference to code verbiage only. The result: a couple of those who responded had a similar response to my own, two others held off their reply until they had some of their questions answered, and the rest were leaning the other way.
The two figures above were sent along as part two of my experiment to see if any of my colleagues would change their interpretation of the code.
Here is the culmination of all the responses, including my own.
Code verbiage provided below pulled directly from NFPA 99. Text in red are the important words I was trying to emphasize. I asked them how they would apply the following code sections based on the information I provided in the first three paragraphs of this article:
2012 NFPA 99 Health Care Facilities Code
Considering 188.8.131.52.6, I determined that the MRI room is located behind a locked door (key card access), and is an anesthetizing location. I also identified that the existing zone valve box is compliant with this section of the code, but is not in compliance with 184.108.40.206.7.
Having to go through three doors to get to the zone valve means it’s not immediately outside of the anesthetizing location and is in violation of this code section.
For a typical operating suite (anesthetizing area), a zone valve is installed outside of each anesthetizing location and is provided with one area alarm to monitor the source side of the valve boxes in the operating area.
These operating suites may or may not be behind key card-accessible doors as well, so how is one to apply this section of the code? In this case, the facility should provide a zone valve box outside the anesthetizing locations. Code section 220.127.116.11.7 also provides some additional information regarding sedation levels.
As long as the procedure involves putting a patient under one of the three sedation levels identified (in this case, they would be placed under general sedation), you would locate the zone valve box immediately outside each of the anesthetizing locations.
The next question relates to how the key-carded doors are affected in the event of a fire. Will the doors remain locked going in one direction forcing you to the nearest exit? Or will they unlock all together?
Our first responsibility is the patient, then employees and public’s safety. With this in mind, I would place the zone valve box immediately outside of the MRI room that contains the anesthetizing gasses. The reason is that the staff will have time to remove the patient from the gasses and out of the room safely before closing the valves to the room as they leave the area.
That was my approach to this situation and my interpretation of the codes; you may have your own interpretation of this situation and a different outcome.
My advice is to ask your code officials, medical gas inspectors, verifiers and other colleagues to compare interpretations of the code that you intend to apply (collaborate). You may end up learning something new or seeing it from another perspective.