NFPA 99: Electrical changes to the 2015 edition

NFPA 99: Health Care Facilities Code (2015 edition) covers a broad range of criteria for health care facilities. Electrical engineers need details about the changes to the electrical portion of the code.


This article is peer-reviewed.Learning objectives:

  • Make use of NFPA 99-2015 to design electrical systems in health care facilities.
  • List changes to the new edition of NFPA 99, specifically Chapter 6, electrical systems.
  • Explain the language of various electrical codes, including NFPA 70.

As most health care design engineers are aware, the 2012 edition of NFPA 99: Health Care Facilities Code underwent a major overhaul and complete restructuring as compared with previous editions. It introduced a new Chapter 4, which establishes "risk categories" and requires a risk assessment to be performed for health care projects. This changed NFPA 99 from being a performance-based design document to a risk-based code. In addition, NFPA 99 was renamed in 2012 from the Standard for Health Care Facilities to the Health Care Facilities Code, which upgraded it from a standard to a code, making it more adoptable and enforceable.

Now that the industry has had time to digest this major change and begin performing risk assessments, it is time for yet another edition to take effect. So what did the 2015 edition of NFPA 99 change that design engineers need to be on the lookout for? Luckily, the 2015 edition has continued to build on the risk-based approach and there were no large structural changes to this edition. However, numerous technical changes have been made throughout the document that one must be aware of.

NFPA 99 versus NFPA 70

In first reading through the changes highlighted in the NFPA 99 handbook, the authors have made a concerted effort to bring some consistency across the two major electrical health care codes: NFPA 99 and NFPA 70: National Electrical Code (NEC), with special emphasis on Article 517, Health Care Facilities. In the past, there have been several contradictions or dissimilar language that led to confusion between the two NFPA codes. However, the 2015 edition of NFPA 99 makes a discernible effort to bring the two together to complement each other, and now NFPA 99 matches much of the wording in the 2014 version of NFPA 70 Article 517.

Why does NFPA have two different codes that appear to cover the same thing? While on the surface both codes appear to cover health care electrical systems, each serves a distinct purpose.

The main purpose of NFPA 99 Chapter 6 is to define the performance required for electrical systems. Meanwhile, NFPA 70 Article 517's main purpose is to define the ways systems are installed to achieve NFPA 99's defined level of performance. They are actually designed to complement each other with a distinction between installation and performance. However, it is hard to cover one topic without the other, which is why there is so much overlap between the two codes. It can become a bit overwhelming when you also include input from the other health care codes and standards, such as the Facility Guidelines Institute and various state-specific department of health services codes. However, it is the job of an electrical engineer to know these codes and how to apply them. Having an understanding of the intent behind each applicable code is what enables an electrical engineer to design the safest and most reliable systems. The design should meet or exceed all required codes and should also take into account the individual needs of the particular health care facility.

Risk-assessment changes

As previously mentioned, NFPA 99-2012 introduced the concept of a required risk assessment to assign a category level to the electrical systems within a facility. In 2015, the code further clarifies the requirements of the risk assessment. This edition adds section 4.2, which doesn't require a risk assessment when all Category 1 requirements are followed.

According to the 2015 NFPA 99 Handbook, "The reasoning is that if the highest level of safety prescribed by this code is provided in a facility, then there is no need to conduct a risk assessment." This means that if it is feasible to design your electrical systems to comply with all Type 1 essential electrical system (EES) and Category 1 requirements, then you can bypass the risk assessment. However, if your systems (or budget) cannot be designed to the highest level even for areas or spaces that officially could be classified in a lower category level, then a risk assessment must still be performed.

Chapter 6, electrical systems

There are several areas in which NFPA 99-2015 includes redefined or reworded sections to closer align to the way that NEC 2014 is written. Probably the largest global change across the code is the replacement of patient care "room" with "space." This revised term has two distinct impacts. First, it reflects a change that was made in NFPA 70-2014 so the two have now adopted the same language. Second, this section now allows a single large room to be broken into several smaller "spaces" and thereby treated differently.

For instance, in a large room, there may be more than one different service being provided in separate spaces, such as a labor and delivery room or trauma room. Now, there are subcategories under the definition of patient-care space including a Category 1 or Category 2 space, both of which can be simultaneously happening in the same room. This new wording further supports the risk-assessment mentality adopted by the code by requiring a closer examination of the risks to a patient based on the actual procedure that will be performed in any given portion of a room.

In addition to this, several other definitions have been updated in NFPA 99 and now are consistent with NFPA 70. These include ampacity, bathroom, ground-fault circuit interrupter (GFCI), and coordination. Although these may seem like trivial modifications, the change helps to make things less "interpretive" between jurisdictions and aids the engineer in knowing what to expect when working in several different localities.

Figure 1: The minimum number of receptacles as defined in NFPA 99 is shown. Courtesy: WSP + ccrd

The next revision encountered in the 2015 NFPA 99-2015 is under the "minimum quantity of receptacles required" for patient-care space in section (see Figure 1 for additional information on this requirement). The actual quantities have not changed, and both NFPA 70 and NFPA 99 now match, but the following verbiage was added to NFPA 99: "They shall be permitted to be of the locking or nonlocking type, single, duplex, or quadruplex type, or any combination of the three. All receptacles shall be listed hospital grade."

This modified language now coordinates with the language in NFPA 70-2014, Article 517. What currently does not match is the "spaces" or "areas." NFPA 70-2014 still defines the required quantities based on critical care or general care, whereas NFPA 99-2015 defines them by Category 1 or Category 2, respectively. However, both align with respect to the required quantities, so perhaps the 2017 edition of NFPA 70 will revise those definitions to align.

Other hot topics

There were several contentious sections in Chapter 6 in the 2012 edition of NFPA 99 that created quite a ruckus among industry professionals. The main ones were selective coordination, wet-procedure locations, and application to existing systems. These same hot topics remain largely unchanged in the 2015 version (despite several efforts to revoke them); however, some were expanded on for further clarification.

Regarding selective coordination, the 2015 edition remains unchanged. It requires overcurrent protective devices (OCPD) serving the EES be coordinated to 0.1 seconds and beyond. This differs from the requirements in NFPA 70 Article 700, which requires full selective coordination (meaning to 0.01 seconds and beyond). NFPA 99 relaxed this requirement and it maintains that, for health care applications, other factors must be considered in the selection of OCPDs, such as arc flash hazards, equipment damage, risk of fires, or extended outages, and that the 0.1-second minimum coordination threshold provides full OCPD coordination for the majority of fault conditions that occur.

Figure 2: NFPA 99-2015 now depicts specific requirements on how to use a ground-fault circuit interrupter (GFCI) device when used in an operating room. Courtesy: WSP + ccrd

The 2012 edition also defined an operating room as a "wet-procedure location" unless a risk assessment determines otherwise. It listed requirements for how to serve the power to these wet locations from either an isolated power supply system or GFCI protection. NFPA 99-2015 maintains this same language; however, it expands on additional requirements when GFCI protection is used in section The code now specifies that if you don't use an isolated power supply system for an operating room and instead choose to use GFCI, each receptacle shall:

  • Be an individual GFCI device
  • Be individually protected by a single GFCI device (see Figure 2).

This adds in the vital requirement that if a GFCI trips, only one outlet is interrupted. Having the power interrupted to more than one outlet could result in the loss of power to multiple pieces of equipment, causing a serious risk to the patient.

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