Adopting NFPA 99

NFPA 99-2015 establishes criteria for levels of health care services or systems based on risk to patients, staff, or visitors in health care facilities to minimize the hazards of fire, explosion, and electricity. Here’s what’s in the current code and what engineers need to know once their authorities having jurisdiction enforce this version.


This article has been peer-reviewed.The 2015 edition of NFPA 99: Health Care Facilities Code is available for adoption by authorities having jurisdiction (AHJ) as well as by building department, state hospital licensing groups, the Dept. of Veterans Affairs, and other government entities. There have been minor technical changes to the update of the 2015 edition, which is a refinement of the 2012 edition that introduced risk-based codes.

The 2012 edition of this code was a major rewrite and change in approach. The editions prior to 2012 were based on building occupancy classification as evaluated using NFPA 101: Life Safety Code. Typical examples of occupancies were health care, ambulatory care, and business.

NFPA 99-2015 edition is a refinement of the 2012 edition. The concept and application of the risk-based NFPA 99 is the direction of the code. Risk-based codes shift more responsibility to the designers than in a prescriptive code. Collaboration between owners, users, designers, and the AHJ is important to the proper use of a risk-based code. The appeal of the risk-based code is custom applications of design criteria to the project. There is potential for cost savings and ongoing savings in operations.

NFPA 99 was updated in 2012 to address the trends in health care delivery. Procedures, care, and treatment of patients have evolved over the years. The building or facility and services provided also have changed. While the occupancy of the building provided a general risk evaluation for patients, many procedures, care, and treatments moved to buildings and areas with fewer than four persons being rendered incapable of self-preservation. Complicated and potentially high-risk procedures, care, or treatments are being performed on one patient at a time in facilities with systems that may not be able to respond the same as a higher risk facility, such as an ambulatory care center or acute care hospital.

In the major rewrite of the 2012 edition of NFPA 99, the occupancy designations were replaced with risk categories. Risk categories are based on the risk of the procedure, care, or treatment provided to the patient regardless of the building occupancy in which it occurs. This was a major shift in the application of this code. The technical changes were minor; however, the application by risk to patient can increase the level of systems required to protect the patient.

NFPA 99 is now a risk-based code. It requires the owner and design team to perform a risk assessment for the procedures, care, or treatments that will occur in areas of the building. From this risk assessment a risk category is designated. Chapter 4 lists the four risk categories. In chapters 5 through 13, the risk category is used to determine the activities, systems, or equipment requirements. Some chapters have not developed requirements for all of the risk categories.

Defining the risk category

Risk categories are:

  • Category 1: Activities, systems, or equipment whose failure is likely to cause major injury or death of patients, staff, or visitors shall be designed to meet Category 1 requirements as detailed in the code.
  • Category 2: Activities, systems, or equipment whose failure is likely to cause minor injury of patients, staff, or visitors shall be designed to meet Category 2 requirements as detailed in the code.
  • Category 3: Activities, systems, or equipment whose failure is not likely to cause injury to patients, staff, or visitors, but can cause discomfort, shall be designed to meet Category 3 requirements as detailed in the code.
  • Category 4: Activities, systems, or equipment whose failure would have no impact on patient care shall be designed to meet Category 4 requirements as detailed in the code.

The code gives some guidance to determine what is considered major injury. Section A 4.1.1 lists items that the technical committee considered major injuries. Some examples include loss of an eye, chemical burns, and hypothermia.

Figure 1: The flow chart is an outline path to using NFPA 99. The risk evaluation is based on the procedure, treatment, or equipment, and the effect on the patient staff or visitors. All graphics courtesy: Jensen HughesChapter 5 on medical gas and vacuum systems is an example of the change to a risk-based approach. The chapter identifies three risk categories specific to these systems. Risk-category-1 medical gas and vacuum systems provide reliability and robustness to minimize the failure rate or failure mode. Category-1 systems are selected if failure of the system results in loss of life or major injury. This requires the owner, users, and design team to evaluate the risk based on the activity, procedure, or treatment of the patient. There are tools available and referenced in the annex material of the code (Section A 4.2) to assist in properly assessing risk. Figure A 4.2 is a simple sample risk evaluation. The code does not require detailed risk assessments. However, the code does require a risk assessment be performed. New to the 2015 edition, the risk assessment is not required to be documented if the risk is Category 1.

Major changes

Changes to NFPA 99 may impact a fire protection engineer’s design approach. These are:

  • Wet procedure location options are available
  • Ventilation of anesthetizing locations was removed
  • Information technology (IT) and communication systems, a new topic, was introduced in NFPA 99-2012
  • Emergency management criteria were expanded in the 2012 edition
  • Fire protection criteria were added in the 2012 edition.

Wet procedure locations: The code defined previously all operating rooms as wet procedure locations, which had set the criteria for special protection against electric shock in the wet procedure locations. Section allows the owner/designer to perform a risk analysis to determine if the operating room can be used without being considered a wet location. Procedures and equipment can be used in the operating rooms to reduce the risk of the operating room being a wet procedure location. This documentation must be accepted by the health care governing body. Owners and designers may have an option to omit special protection against electric shock if they can demonstrate a risk mitigation plan to address the wet procedure location issues.

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