Understanding the fire safety requirements in NFPA 99-2012

Learning the fire and life safety requirements of NFPA 99 as they relate to hospitals and health care facilities is critical.


Learning objectives

  • Know the basic premise of NFPA 99: Health Care Facilities Code as it pertains to fire and life safety.
  • Understand the risk assessment categories of NFPA 99, and how to apply them.
  • Review how NFPA 99 should be applied in health care facilities including hospitals.


NFPA 99: Health Care Facilities Code is an unusual document within the family of NFPA codes and standards, in that it covers many items that are not fire safety-related. However, it's important to understand the standard's fire safety-related requirements that will be discussed here. The primary focus of this article will be the standard's fire safety-related requirements. The 2012 edition of NFPA 99 represents the most significant change from previous editions, and it is the edition that seems to be more likely used by health care facilities since it was adopted by the Centers for Medicare & Medicaid Services (CMS). The most recent version is the 2018 edition.

The 2012 edition of NFPA 99 took a long time to develop since the last edition was published in 2005. After the production of the 2005 edition, the Correlating Committee on Health Care Facilities made the decision to rewrite the document using a risk-based approach versus an occupancy-based approach. The basis for this change was centered on reflecting how health care is delivered as opposed to the use and occupancy or "name" of the facility in which the care is delivered. For example, if a patient needs medical gas, whether they are in a long-term care facility or a hospital, safeguards need to be in place to protect the patient and caregivers. This change allows facilities to use NFPA 99 to determine the risk to their patients from the procedures offered in their buildings, and it provides requirements to protect against those risks. Instead of basing requirements for certain systems and equipment based on the name on the front of the building, the requirements are based on a risk assessment of what would happen to patients or caregivers if the system was lost or compromised.

The fundamental question to be addressed when performing the risk assessment is whether injuries or deaths to patients or staff will occur should the system or equipment fail. The four risk categories are summarized as:

  • Category 1: Failure of the system or equipment is likely to cause major injury or death to patients or caregivers.
  • Category 2: Failure of the system or equipment is likely to cause minor injury to patients or caregivers.
  • Category 3: Failure of the system or equipment is not likely to cause injury; but rather patient discomfort.
  • Category 4: Failure of the system or equipment would have no impact on patient care.

Figure 1: Medical gas system outlets. Courtesy: Koffel Associates, Inc.There are some chapters that do not use the categories. Chapter 12 of NFPA 99 creates its own categories based on the role of the health care facility within the community. The requirements of Chapter 13 apply to all facilities as determined based on the Security Vulnerability Assessment (SVA) and actual security concerns that exist in the facility.

Other than assuming that everything is Category 1, NFPA 99 does not provide an alternative to performing the risk assessment (Section 4.2.2). While there are many codes that offer a risk assessment as an alternative option, NFPA 99 is unique in that the risk assessment is mandatory. The risk assessment should be performed based on an assumption that without the protective measures required by NFPA 99, the system or equipment will fail; and you do not consider the probability or frequency of such a failure. The protective measures required by NFPA 99 for the category of systems are intended to mitigate the risk by reducing the likelihood of failure; or providing a back-up should the primary system or equipment fail. Also, when doing the risk assessment, you do not need to consider any intervention by facility staff during the failure scenario. 

Applying NFPA 99

NFPA 99 applies to all health care facilities other than those in which home health care is provided. While most building and fire codes define a health care occupancy as one in which four or more occupants are not capable of self-preservation, NFPA 99 does not define a health care facility by its minimum occupant load, nor does it consider occupants' capability of self-preservation. In other words, when health care is delivered, the equipment and systems must meet the requirements of NFPA 99 regardless of the number of patients for whom care is being provided.

The construction and equipment requirements contained in NFPA 99 apply only to new construction and new equipment. Existing systems and equipment are permitted to continue in use unless the code specifically states otherwise—or the authority having jurisdiction (AHJ) determines that the continued use constitutes a distinct hazard to life. The administrative requirements, which generally include policies and preventive maintenance requirements, apply to new and existing facilities, systems, and equipment.

Figure 2: This graphic illustrates a medical gas system and area valves. Courtesy: Koffel Associates, Inc.Medical gas systems

The Technical Committee on Piping Systems classifies gas systems as Category 1, Category 2, and Category 3 based on the categories determined by the risk assessment. However, the overall requirements are very similar to the prior editions. Category 2 systems are Category 1 systems, but components can be simplex rather than duplex. A single vacuum pump, a single regulator, a single master-alarm panel, etc. is permitted in a Category 2 system. Originally, Category 3 systems were dental systems; however, starting with the 2015 edition of NFPA 99, the Technical Committee on Piping Systems has tried to provide a true Category 3 system.

Gas storage

The requirements for bulk storage are coordinated with NFPA 55: Compressed Gases and Cryogenic Fluids Code. Outdoor bulk storage mandates a minimum of two egress routes. There has been a specific attempt to clarify that nonflammable medical gas storage areas are not hazardous locations in accordance with NFPA 70: National Electrical Code. In conjunction with that, the former requirement that electrical fixtures be at least 5 ft above the floor has been deleted and replaced with a requirement that they be protected from damage. It was not the intent for the 5-ft rule to imply that there is an electrical hazard, rather it was to protect the electrical equipment from damage while the cylinders are moving. All the ventilation requirements have been moved to the new Chapter 9 on HVAC systems that first appeared in the 2012 edition. Chapter 9 now allows natural ventilation in lieu of mechanical ventilation, and more information has been provided for both systems. Except for medical air compressors, no motor-driven equipment is allowed in the same room with medical gas storage. It is not uncommon to find motor-driven equipment in the same room as medical gas storage in existing facilities, but this is one example where the requirements for new facilities do not apply to existing facilities.

Figure 3: This photo illustrates a hospital life safety branch. Courtesy: Koffel Associates, Inc.Gas systems

It is important to note that the labeling requirements are retroactive. This includes labeling of piping, alarms, and valves. Inaccurate valve labeling is a very common problem in health care facilities and should be reviewed for accuracy. The problem tends to be more with zone valves and area alarms. Surveyors find that more than half of the hospitals have errors with the labeling of zone valves. Even in brand-new systems, problems have been found due to labels being based on architectural room numbers rather than the using the correct method of actual room numbers. The staff needs to have the ability to quickly determine what valve must be closed when there is a fire in the room.

Electrical systems

Although it appears that Chapter 6 (Electrical Systems) in NFPA 99 has not reacted to the risk assessment basis, it has by default. Just because a facility is called the XYZ hospital, it might not require a Type 1 essential electrical system (EES), based on the risk assessment. Once it is determined that a Category 1 EES is required, then Chapter 6 requires that a Type 1 EES must be installed. If Category 2 is required, then either Type 1 or Type 2 EES shall be installed. There are very few differences between Type 1 and Type 2 EES other than how the power is distributed.

All operating rooms are now automatically wet-procedure locations unless a risk assessment is conducted to show that a specific operating room is not a wet-procedure location. This is a reversal of the former requirements that wet-procedure locations were determined by the facility administration. This assessment is still required for other areas of the facility that might be wet-procedure locations. Note that this includes a change in terminology from wet locations to wet-procedure locations. This was to emphasize the difference between the NFPA 70's "wet locations" and the use in NFPA 99 of "wet-procedure locations." A sink qualifies as a wet location in NFPA 70 but not in NFPA 99. The "procedure" must be wet under NFPA 99. 

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