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1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: M E M O R A N D U M TO: FROM: NFPA Technical Committee on Mechanical Systems Jeanne Moreau DATE: November 1, 2010 SUBJECT: NFPA 99 HEA-MEC ROC TC Letter Ballot (A11) The ROC letter ballot for NFPA 99 is attached. The ballot is for formally voting on whether or not you concur with the committee s actions on the comments. Reasons must accompany all negative and abstention ballots. Please do not vote negatively because of editorial errors. However, please bring such errors to my attention for action. Please complete and return your ballot as soon as possible but no later than Monday, November 15, As noted on the ballot form, please return the ballot to Jeanne Moreau either via to jmoreau@nfpa.org or via fax to The return of ballots is required by the Regulations Governing Committee Projects. Attachments: Comments

2 99-5 Log #CC403 HEA-MEC Technical Committee on Mechanical Systems, Revise text to read as follows: Globally change "Heating, cooling, ventilating, humidity control and process systems" to "HVAC systems" throughout the document. Delete sections and it's subsections and Delete the column called "process" from table A.9.2. Delete the column called "process air" from table A.8.2. The term Heating, cooling, ventilating, humidity control and process systems was changed to HVAC and it needs to be changed throughout for correlation purposed. The requirements for "process" was deleted and this was deleted throughout to correlate Log #150 HEA-MEC Delete the reference to humidity, or humidity control in Sections: (4) (4) A.9.2 Delete entire sections and Delete the references to humidity. The only reasons that have been identified for requiring humidity have been clinical. without any risk of injury, fire, or explosion there is no need for humidity requirements in this code except within hyperbaric chambers. We support the TCC s direction to remove the references to humidity which are already covered in other standards such as the FGI Guidelines and ASHRAE 170. Delete as proposed except for Also delete "Humidity Control" from Humidity does not appear in section

3 99-26 Log #7c HEA-MEC Technical Correlating Committee on Health Care Facilities, The scope of NFPA 99 does include all levels of anesthesia, therefore the definition must be all inclusive and the TC should review and change their action at the ROC stage. All the TC's should review their categories of patient care where anesthetics are used. This is a direction from the Technical Correlating Committee on Health Care Facilities in accordance with and of the Regulations Governing Committee Projects. The committee reviewed its chapters and did not find a need to make any modifications based on the new definitions for anesthesia. No action was needed Log #8c HEA-MEC Technical Correlating Committee on Health Care Facilities, The scope of NFPA 99 does include all levels of anesthesia, therefore the definition must be all inclusive and the TC should review and change their action at the ROC stage. All the TC's should review their categories of patient care where anesthetics are used. This is a direction from the Technical Correlating Committee on Health Care Facilities in accordance with and of the Regulations Governing Committee Projects. The committee reviewed its chapters and did not find a need to make any modifications based on the new definitions for anesthesia. No action was needed Log #10c HEA-MEC Technical Correlating Committee on Health Care Facilities, The scope of NFPA 99 does include all levels of anesthesia, therefore the definition must be all inclusive and the TC should review and change their action at the ROC stage. All the TC's should review their categories of patient care where anesthetics are used. This is a direction from the Technical Correlating Committee on Health Care Facilities in accordance with and of the Regulations Governing Committee Projects. The committee reviewed its chapters and did not find a need to make any modifications based on the new definitions for anesthesia. No action was needed. 2

4 Log #312 HEA-MEC Mark Jelinske, Cator, Ruma, and Associates Reject this proposal in it's entirety. This proposal goes way beyond the scope of NFPA 99 The scope of this code is to establish criteria to minimize the hazards of fire, explosion, and electricity in health care facilities providing services to human beings. The regulation of plumbing systems has no business being in NFPA 99. The submitted substantiation for the proposal states These systems are used in health care facilities with very little guidance until now. This is grossly inaccurate. Health Care Facility plumbing systems are subject to multiple prescriptive requirements such as state and local plumbing codes and state and local public health codes. In addition, the FGI/AIA Guidelines for Design and Construction of Health Care Facilities are considered the industry standard, and are adopted as code in many jurisdictions. There are multiple terms in this proposal that are not defined in this Code, such as non-potable water, black/grey/clear waste water, special use water systems. Actually, these terms are defined and regulated quite well in the multiple guidelines and codes that the proposer states are not available. So even if there is no need to define the terms in this Code, there is also no reason to regulate these systems in a Code limited to minimize the hazards of fire, explosion, and electricity in health care facilities, particularly since they are so well defined and regulated elsewhere. At best, this proposal is a waste of ink: Potable water systems shall comply with applicable plumbing codes. (what happened to very little guidance?) Plumbing fixtures shall be suitable for the intended use. At worst, this proposal adds one more level of regulation that has the potential to conflict with and confuse the implementation of model codes and guidelines and developed over decades by plumbing industry experts. The TC was following the direction of the TCC which was to include plumbing in NFPA 99. The TCC wanted to have a first-stop document that addressed many facets of systems and directed the TC to address this subject. Section of the scope addresses plumbing Log #CC400 HEA-MEC Technical Committee on Mechanical Systems, Add new section as follows: The category of risk applied to each plumbing system serving a space shall be independent of the category of risk applied to other systems serving that same space. A There are no interdependencies for each type of system (e.g., medical gas, electrical, potable water, non-potable water, non-medical compressed air, heating). A risk assessment of each system should be conducted to evaluate the risk to the patient, staff and visitors. It is possible when applying this section to identify multiple categories of systems serving a single patient. For example see table A.8.2 and A.4.1. This clarifies that a risk assessment of each building system should be conducted. The results of each risk assessment are independent for each system. There are no interdependencies for each type of system (e.g., medical gas, electrical, potable water, non-potable water, non-medical compressed air, heating). A risk assessment of each system should be conducted to evaluate the risk to the patient, staff and visitors. 3

5 Log #207 HEA-MEC James R. (Skip) Gregory, Health Facility Consulting Category Potable Water. Redundant or standby potable water sources shall be provided for Category 1 uses such that if the primary source of potable water fails, then the Category 1 uses of nonpotable water shall be capable of operating Nonpotable Water. Redundant or standby nonpotable water sources shall be provided for Category 1 uses such that if the primary source of nonpotable water fails, then the Category 1 uses of nonpotable water shall be capable of operating Water Heating. Redundant or standby water heating sources shall be provided for Category 1 uses such that if the largest piece of potable water heating equipment fails, the remaining potable water heating equipment shall be capable of maintaining the minimum temperature at all times Water Conditioning. Redundant or standby water conditioning systems shall be provided for Category 1 spaces such that if the largest piece of water conditioning equipment fails, the remaining water conditioning equipment shall be capable of maintaining the load Nonmedical Compressed Air. Redundant or standby nonmedical compressed air sources shall be provided for Category 1 spaces such that if the largest piece of nonmedical compressed air source equipment fails, the remaining non-medical compressed air source equipment shall be capable of maintaining the required flow and pressure to serve all Category 1 uses Special Use Water Systems. Redundant or standby special use water sources shall be provided for Category 1 spaces such that if the largest piece of special use water equipment fails, the remaining special use water equipment shall be capable of maintaining the flow and pressure to serve all Category 1 uses. Delete Entire Section. There has been no data or substantiation of adverse patient outcomes submitted to support this new section to the code, requiring redundant potable water, nonpotable water, water heating, water conditioning, nonmedical gas, and special use water systems. The definition of Category 1 is "Facility systems in which failure of such equipment or system is likely to cause major injury or death of patients or caregivers". The potential for the failure of this system to cause death or major injury is very unlikely. At the most a failure of these systems could cause discomfort, but not death or major injury. There is no justification to require redundant systems to this extent. A failure to these systems does not constitute an immediate danger to the health and safety of the patient and when these systems are renovated, patients are removed from the areas affected by the renovation. To require this type of redundancy for these systems will increase the cost of health care construction with no appreciable improved patient outcomes. Before this requirement is added, there should be data collected from hospitals that will provide the necessary justification for this added cost. This comment is supported by the Codes and Standards Review Committee of the Health Care Section of NFPA. 4

6 Log #131 HEA-MEC Redundant or standby potable water sources shall be provided for Category 1 uses such that if the primary source of potable water fails, then the Category 1 uses of nonpotable water shall be capable of operating. Delete Entire Section. There is no technical justification or data to support redundancy of this system. The definition of Category 1 is "Facility systems in which failure of such equipment or system is likely to cause major injury or death of patients or caregivers" the potential for the failure of this system to cause Death or major injury is very unlikely. at most a failure of this system could cause discomfort. It would take prolonged exposure without caregiver intervention before death or major injury would be potential concern. There are many options available to facilities to mitigate the potential problems of this system failure - such as patient relocation, temporary units, and limited exposure. The inclusion of this requirements doubles the amount of equipment that is required in the current standard. A cost benefits analysis needs to be done before the requirements in this code are increased this drastically Log #230 HEA-MEC Sharon S. Gilyeat, Koffel Associates, Inc. N/A Revise text to read as follows: Redundant or standby potable water sources shall be provided for Category 1 uses such that if the primary source of potable water fails, then the Category 1 uses of secondary nonpotable water shall be capable of operating. Editorial, secondary source refers to nonpotable but should refer to potable. Also wording previously not clear. 5

7 Log #132 HEA-MEC Revise text to read as follows: Redundant or standby nonpotable water sources shall be provided for Category 1 uses such that if the primary source of nonpotable water fails, then the Category 1 uses of nonpotable water shall be capable of operating. Delete Entire Section. There is no technical justification or data to support redundancy of this system. The definition of Category 1 is "Facility systems in which failure of such equipment or system is likely to cause major injury or death of patients or caregivers" the potential for the failure of this system to cause Death or major injury is very unlikely. at most a failure of this system could cause discomfort. It would take prolonged exposure without caregiver intervention before death or major injury would be potential concern. There are many options available to facilities to mitigate the potential problems of this system failure - such as patient relocation, temporary units, and limited exposure. The inclusion of this requirements doubles the amount of equipment that is required in the current standard. A cost benefits analysis needs to be done before the requirements in this code are increased this drastically Log #231 HEA-MEC Sharon S. Gilyeat, Koffel Associates, Inc. N/A Revise text to read as follows: Redundant or standby nonpotable water sources shall be provided for Category 1 uses such that if the primary source of nonpotable water fails, then the Category 1 uses secondary nonpotable water shall be capable of operating. Editorial, previous wording unclear. 6

8 Log #133 HEA-MEC Redundant or standby water heating sources shall be provided for Category 1 uses such that if the largest piece of potable water heating equipment fails, the remaining potable water heating equipment shall be capable of maintaining the minimum temperature at all times. Delete Entire Section. There is no technical justification or data to support redundancy of this system. The definition of Category 1 is "Facility systems in which failure of such equipment or system is likely to cause major injury or death of patients or caregivers" the potential for the failure of this system to cause Death or major injury is very unlikely. at most a failure of this system could cause discomfort. It would take prolonged exposure without caregiver intervention before death or major injury would be potential concern. There are many options available to facilities to mitigate the potential problems of this system failure - such as patient relocation, temporary units, and limited exposure. The inclusion of this requirements doubles the amount of equipment that is required in the current standard. A cost benefits analysis needs to be done before the requirements in this code are increased this drastically Log #128 HEA-MEC Redundant or standby water conditioning systems shall be provided for Category 1 spaces such that if the largest piece of water conditioning equipment fails, the remaining water conditioning equipment shall be capable of maintaining the load. Delete Entire Section. There is no technical justification or data to support redundancy of this system. The definition of Category 1 is "Facility systems in which failure of such equipment or system is likely to cause major injury or death of patients or caregivers" the potential for the failure of this system to cause Death or major injury is very unlikely. at most a failure of this system could cause discomfort. It would take prolonged exposure without caregiver intervention before death or major injury would be potential concern. There are many options available to facilities to mitigate the potential problems of this system failure - such as patient relocation, temporary units, and limited exposure. The inclusion of this requirements doubles the amount of equipment that is required in the current standard. A cost benefits analysis needs to be done before the requirements in this code are increased this drastically. 7

9 Log #129 HEA-MEC Redundant or standby nonmedical compressed air sources shall be provided for Category 1 spaces such that if the largest piece of nonmedical compressed air source equipment fails, the remaining non-medical compressed air source equipment shall be capable of maintaining the required flow and pressure to serve all Category 1 uses. Delete Entire Section. There is no technical justification or data to support redundancy of this system. The definition of Category 1 is "Facility systems in which failure of such equipment or system is likely to cause major injury or death of patients or caregivers" the potential for the failure of this system to cause Death or major injury is very unlikely. at most a failure of this system could cause discomfort. It would take prolonged exposure without caregiver intervention before death or major injury would be potential concern. There are many options available to facilities to mitigate the potential problems of this system failure - such as patient relocation, temporary units, and limited exposure. The inclusion of this requirements doubles the amount of equipment that is required in the current standard. A cost benefits analysis needs to be done before the requirements in this code are increased this drastically Log #130 HEA-MEC Redundant or standby special use water sources shall be provided for Category 1 spaces such that if the largest piece of special use water equipment fails, the remaining special use water equipment shall be capable of maintaining the flow and pressure to serve all Category 1 uses. Delete Entire Section. There is no technical justification or data to support redundancy of this system. The definition of Category 1 is "Facility systems in which failure of such equipment or system is likely to cause major injury or death of patients or caregivers" the potential for the failure of this system to cause Death or major injury is very unlikely. at most a failure of this system could cause discomfort. It would take prolonged exposure without caregiver intervention before death or major injury would be potential concern. There are many options available to facilities to mitigate the potential problems of this system failure - such as patient relocation, temporary units, and limited exposure. The inclusion of this requirements doubles the amount of equipment that is required in the current standard. A cost benefits analysis needs to be done before the requirements in this code are increased this drastically. 8

10 Log #208 HEA-MEC James R. (Skip) Gregory, Health Facility Consulting Category Potable Water. Provisions to allow the potable water system to continue to operate shall be provided On-site redundant or standby potable water sources shall not be required Mobile or temporary systems shall be acceptable Nonpotable Water. Provisions to allow the nonpotable water system to continue to operate shall be provided On-site redundant or standby nonpotable water sources shall not be required Mobile or temporary systems shall be acceptable Water Heating. Provisions to allow the water heating system to continue to operate shall be provided On-site redundant or standby water heating sources shall not be required Mobile or temporary systems shall be acceptable Water Conditioning. Provisions to allow the water conditioning system to continue to operate shall be provided On-site redundant or standby water conditioning sources shall not be required Mobile or temporary systems shall be acceptable Nonmedical Compressed Air. Provisions to allow the nonmedical compressed air system to continue to operate shall be provided On-site redundant or standby nonmedical compressed air sources shall not be required Mobile or temporary systems shall be acceptable. Delete Entire Section. This section is unclear and vague as to what is being required. For Category 2, redundant systems are not required, however mobile or temporary systems are required to supply these utilities but there is no definition or description of what a mobile or temporary system might be and there is no specified length of time these systems must operate. It is hard to imagine how a mobile or temporary system of potable or nonpotable water, for instance, could be provided that would take the place of the permanently installed utility system, for an unspecified length of time that could be construed as forever. How much water must be temporarily provided to satisfy this requirement is not clearly stated and therefore cannot be enforced. In addition, there is no data regarding adverse patient outcomes to substantiate this section that will add substantial cost to the design of health care facilities. This comment is supported by the Codes and Standards Review Committee of the Health Care Section of NFPA. Category 2 systems needs to be defined and specified within section 8.5. This is the direction of the TCC and needs to be there for consistency. The submitter has raised issues that will be addressed in a committee comment. See action on (Log #CC402). 9

11 Log #CC402 HEA-MEC Technical Committee on Mechanical Systems, Revise text to read as follows: 8.5 Category Potable Water. Provisions to allow the potable water system to continue to operate shall be provided On-site redundant or standby potable water sources shall not be required Mobile or temporary systems shall be acceptable. An emergency physical connection shall be provided to permit connection of temporary or mobile systems to the potable water system in the event of failure. A A temporary mobile system could be a tanker truck, tank, well, a bladder, etc as determined by the facility Nonpotable Water. Provisions to allow the nonpotable water system to continue to operate shall be provided On-site redundant or standby nonpotable water sources shall not be required Mobile or temporary systems shall be acceptable. An emergency physical connection shall be provided to permit connection of temporary or mobile systems to the non-potable water system in the event of failure. A A temporary mobile system could be a tanker truck, tank, well, a bladder, etc as determined by the facility Water Heating. Provisions to allow the water heating system to continue to operate shall be provided On-site redundant or standby water heating sources shall not be required Mobile or temporary systems shall be acceptable. An emergency physical connection shall be provided to permit connection of temporary or mobile systems for the purpose of restoring the water heating system in the event of failure. A A temporary mobile system could be a heat exchanger, a heating element, a burner, complete water heater or a mobile system as determined by the facility Water Conditioning. Provisions to allow the water conditioning system to continue to operate shall be provided On-site redundant or standby water conditioning sources shall not be required Mobile or temporary systems shall be acceptable. An emergency physical connection shall be provided to permit connection of temporary or mobile systems to the water condtioning system in the event of failure. A A temporary mobile system could be a water softener, filter or other temporary water conditioning or treatment system as determined by the facility Nonmedical Compressed Air. Provisions to allow the nonmedical compressed air system to continue to operate shall be provided On-site redundant or standby nonmedical compressed air sources shall not be required Mobile or temporary systems shall be acceptable. An emergency physical connection shall be provided to permit connection of temporary or mobile systems to the nonmedical compressed air system in the event of failure. A A temporary mobile system could be air compressors connected to the manifold Special Use Water Systems. Provisions to allow the special use water system to continue to operate shall be provided On-site redundant or standby special use water sources shall not be required Mobile or temporary systems shall be acceptable. An emergency physical connection shall be provided to permit connection of temporary or mobile systems to the special use water system in the event of failure. A A temporary mobile system could be a tanker truck, tank, well, a bladder, etc as determined by the facility. The new wording provides more guidance on what is required for mobile or temporary water and nonmedical compressed air systems. Examples are given for each. The intent was the provisions for the connection to the system be provided and not to describe the specific mobile or temporary device. 10

12 Log #134 HEA-MEC Provisions to allow the potable water system to continue to operate shall be provided. Delete Entire Section. There are no bookends for this section it is very difficult if not impossible to determine what provisions should be designed into a system to ensure that it continues to operate. This should at least be moved to the appendix. Category 2 systems needs to be defined and specified within section 8.5. This is the direction of the TCC and needs to be there for consistency. The submitter has raised issues that will be addressed in a committee comment. See action on (Log #CC402) Log #209 HEA-MEC James R. (Skip) Gregory, Health Facility Consulting Category Potable Water. Redundant or standby potable water systems shall not be required Nonpotable Water. Redundant or standby nonpotable systems shall not be required Water Heating. Redundant or standby water heating systems shall not be required Water Conditioning. Redundant or standby water conditioning systems shall not be required Nonmedical Compressed Air. Redundant or standby nonmedical compressed air systems shall not be required Special Use Water Systems. Redundant or standby special use water systems shall not be required. Delete Entire Section. The NFPA codes and standards contain minimum requirements that must be met. This section contains no such requirements. It should either be deleted or moved to the annex as advisory material. This material is needed as it is consistent with the other categories in this chapter which identifies what is required and what is not required. The lack of any requirements in Category 3 is specifically stated to avoid potential misinterpretation that plumbing systems should only be Category 1 and Log #17 HEA-MEC Technical Correlating Committee on Health Care Facilities, The TCC directs the TC on MEC to eliminate all references to humidity and humidity control systems as this document does not address clinical practices. This is a direction from the Technical Correlating Committee on Health Care Facilities in accordance with and of the Regulations Governing Committee Projects. See action on comment 99-9 (Log #150). 11

13 Log #61 HEA-MEC Bill Payne, Alamance Regional Medical Center N/A Revise text to read as follows: Chapter 9 Heating Heating, Ventilation and Air Conditioning (HVAC). Chapter 9 addresses issues such as cooling, humidity control, ventilation and Airborne Contaminants. Titling this chapter "Heating" is too limiting and misleading. The fuel requirements in this chapter are not just for the boilers that produce the heat, it includes the fuel for the generator that keep the rest of HVAC system running. With a chapter heading of "Heating", the immediate assumption is that this only pertains to boilers. 12

14 Log #162 HEA-MEC John Williams, Washington State Dept. of Health Redundant or standby heat generating sources shall be provided for Category 1 spaces such that if the largest piece of heat generating equipment fails, the remaining heat generating equipment shall be capable of maintaining the minimum temperature at all times Redundant or standby humidity control sources shall be provided for Category 1 spaces such that if the largest piece of humidity control source equipment fails, the remaining humidity control source equipment shall be capable of maintaining the maximum temperature at all times Redundant or standby supply air sources shall be provided such that if the largest piece of supply air source equipment fails, the remaining supply air source equipment shall be capable of maintaining the supply air flow Redundant or standby return air sources shall be provided such that if the largest piece of return air source equipment fails, the remaining return air source equipment shall be capable of maintaining the return air flow Redundant or standby exhaust air sources shall be provided such that if the largest piece of exhaust air source equipment fails, the remaining exhaust air source equipment shall be capable of maintaining the exhaust air flow Process Systems. Process heating, cooling, and ventilating systems necessary to support equipment essential to the function of Category 1 areas shall be provided with standby or redundant generation sources such that if the largest piece of source equipment serving the processes fails, the remaining source equipment serving the processes shall be capable of serving the load. The addition of redundant air tempering and exhaust systems is a significant scope change that is unwarranted. At no point in recent history has this code required redundant equipment for these systems. No substantiation has been provided during this process to identify what risks are being mitigated by this addition. What risks are these minimum criteria specifically designed to address: hazards due to downtime for maintenance or hazards related to disasters? The failure of an exhaust system may pose an immediate hazard to the occupants of a healthcare facility if those systems serve highly sensitive areas. However, the failure of sources of heat generation, humidity control, return air, etc do not create an immediate hazard. The building will remain tenable for a period of time which will allow for repair of a failed system. There are many viable temporary HVAC solutions that have successfully been employed prior to this code change. It is unlikely that a wide-scale disaster would affect something so specific as an individual piece of equipment. If it did, the redundant equipment would be subject to the same conditions and might also fail. Regardless, chapter 12 requires an approach to management of essential utilities during disasters that can be appropriately tailored to the climate, location, size of facility, etc. Without an understanding of the risk that this code tries to mitigate, it is incredibly difficult to assess alternate means and methods. Until the committee clearly articulates why this should be a minimum standard and identifies the risks that are being mitigated, redundant equipment should not be required. 13

15 Log #246 HEA-MEC Sharon S. Gilyeat, Koffel Associates, Inc. N/A Revise text to read as follows: The chapter deals with all HVAC issues. Recommend change to clarify actual scope of chapter and provide consistency with terminology used in NFPA 90A. "Heating" was missing. The proper designation is to refer to the term as Heating Ventilation and Air Conditioning Log #247 HEA-MEC Sharon S. Gilyeat, Koffel Associates, Inc. Revise text to read as follows:...category X spaces systems Throughout the chapter the committee has mixed up the reference of category to systems vs. spaces. This needs to be consistent. appear in the chapter. The committee has specifically used the terms "spaces" and "systems" appropriately as they 14

16 Log #313 HEA-MEC Mark Jelinske, Cator, Ruma, and Associates Reject the Proposal in it's entirety. This proposal goes way beyond the scope of NFPA 99 The regulation of comfort and clinical performance of HVAC systems has no business being in NFPA 99. In addition, the proposed chapter goes beyond the title Heating into other systems such as cooling, ventilation, smoke removal, room pressurization, etc. Health Care Facility HVAC systems are currently subject to multiple prescriptive requirements such as state and local Mechanical, Building, and Fire codes and state and local public health codes. Multiple NFPA documents already address the Life Safety aspects of HVAC systems in Healthcare Occupancies. In addition, and of specific healthcare interest, the FGI/AIA Guidelines for Design and Construction of Health Care Facilities, and ASHRAE Standard 170 are considered industry standard of care, and are adopted as code in many jurisdictions. ASHRAE Standard 170 has recently been consolidated with the FGI/AIA Guidelines to provide the healthcare facility/design/construction industry a strong coordinated voice. It would be a step backwards to promulgate additional regulations. There are numerous technical changes embedded within this document that have not been substantiated by the submitter. The above reasoning was given to reject proposal 99-76, and that was presented as a re-write of an existing topic. The same logic should be applied to an entirely new topic. If it is felt that NFPA must address HVAC systems to this level of detail, this proposal should be extracted to a separate document as a guideline, rather than as a Code directly referenced by NFPA 101. The TC was following the direction of the TCC which was to include HVAC in NFPA 99. The TCC wanted to have a first-stop document that addressed many facets of systems and directed the TC to address this subject. Section of the scope addresses HVAC Log #144 HEA-MEC Delete entire chapter and replace with: Ventilation systems shall be installed per ASHRAE 170. The requirements of this chapter are too stringent and duplicate the requirements that are found in other resources. The entire chapter should be replaced with a reference to ASHRAE 170. This chapter could be used in the future to cover issues not addressed in ASHRAE 170, or to further enhance the requirements. The TC was following the direction of the TCC which was to include HVAC in NFPA 99. The TCC wanted to have a first-stop document that addressed many facets of systems and directed the TC to address this subject. Section of the scope addresses HVAC. 15

17 Log #CC401 HEA-MEC Technical Committee on Mechanical Systems, Add new section as follows: The category of risk applied to each HVAC system serving a space shall be independent of the category of risk applied to other systems serving that same space. A There are no interdependencies for each type of system (e.g. medical gas, electrical, potable water, non-potable water, non-medical compressed air, plumbing). A risk assessment of each system should be conducted to evaluate the risk to the patient, staff and visitors. It is possible when applying this section to identify multiple categories of systems serving a single patient. For example see table A.9.2 and A.4.1. This clarifies that a risk assessment of each building system should be conducted. The results of each risk assessment are independent for each system. There are no interdependencies for each type of system (e.g., medical gas, electrical, potable water, non-potable water, non-medical compressed air, heating). A risk assessment of each system should be conducted to evaluate the risk to the patient, staff and visitors Log #62 HEA-MEC Bill Payne, Alamance Regional Medical Center N/A Revise text to read as follows: Energy Conservation. Heating, cooling, ventilating, humidity control, and process systems serving spaces or providing health care functions covered by this code shall comply with ASHRAE 90.1 or their local Energy Code. The NC Energy Code allows the user to follow either the NC Energy Conservation Code or ASHRAE If NFPA 99 requires us to follow 90.1, then we will not have the option to follow the State Code. See action on comment (Log #149) Log #149 HEA-MEC Revise text to read as follows: Heating, cooling, ventilating, humidity control, and process systems serving spaces or providing health care functions covered by this code shall comply with ASHRAE 90.1 or other locally adopted energy code. Many jurisdictions already have an energy code adopted, either ASHRAE 90.1 with amendments or other versions of the energy codes. The facilities should be required to meet one of the codes, but not multiple codes. Additionally, it seems that energy conservation is outside the scope of NFPA 99 and is better left to performance codes such as the FGI Guidelines. Revise text to read as follows: Heating, cooling and ventilating, humidity control, and process systems serving spaces or providing health care functions covered by this code shall comply with ASHRAE 90.1 or other locally adopted energy code. The action on comments (Log #141) and (Log #215) deleted processes. This is done for consistency. 16

18 Log #301 HEA-MEC Kirk Bantz, Saint Alphonsus Regional Medical Center Cooling Category 1 cooling systems shall be provided to maintain the space at maximum temperatures listed in ASHRAE/ANSI Redundant or standby cooling sources shall be provided for Category 1 spaces such that if the largest piece of cooling source equipment fails, the remaining cooling source equipment shall be capable of maintaining the maximum temperature at all times Self-contained cooling units that connect directly with outdoors through the building envelope shall not be permitted Humidity Control Category 1 humidity control shall be provided to maintain the space humidity consistent with ASHRAE/ANSI 170 or as required for the proper operation of life support equipment within the space, whichever is more strict Redundant or standby humidity control sources shall be provided for Category 1 spaces such that if the largest piece of humidity control source equipment fails, the remaining humidity control source equipment shall be capable of maintaining the maximum temperature at all times Ventilation, Outdoor Air Ventilation systems for Category 1 spaces shall be provided to introduce outdoor air into a building as required by the applicable building code and ASHRAE/ANSI 170 to achieve acceptable indoor air quality through the dilution of indoor air contaminants The location of the source of outdoor air shall comply with ASHRAE/ANSI Supply Air Ventilation systems for Category 1 spaces shall be provided to supply air into Category 1 spaces in accordance with ASHRAE/ANSI Redundant or standby supply air sources shall be provided such that if the largest piece of supply air source equipment fails, the remaining supply air source equipment shall be capable of maintaining the supply air flow Supply air systems for Category 1 spaces shall be provided with a smoke control system per NFPA 92A Return Air Ventilation systems for Category 1 spaces shall be provided to remove air not required to be exhausted from Category 1 spaces by ASHRAE 170 in accordance with ASHRAE Redundant or standby return air sources shall be provided such that if the largest piece of return air source equipment fails, the remaining return air source equipment shall be capable of maintaining the return air flow Return air systems for Category 1 spaces shall be provided with a smoke control system per NFPA 92A Exhaust Air Ventilation systems for Category 1 spaces shall be provided to remove air that is required to be exhausted from Category 1 spaces by ASHRAE 170 in accordance with ASHRAE Redundant or standby exhaust air sources shall be provided such that if the largest piece of exhaust air source equipment fails, the remaining exhaust air source equipment shall be capable of maintaining the exhaust air flow Exhaust air systems for Category 1 spaces shall be provided with a smoke control system in accordance with NFPA 92A Airborne Contaminant Control Ventilation systems for Category 1 spaces shall be provided to control contaminants in the air using air flow, dilution, and filtration in accordance with ASHRAE Pressurization for Category 1 airborne contaminant control systems shall be a minimum of 0.01 wc (2.5 Pa) across each barrier used as an control mechanism required by ASHRAE Air movement relationships to adjacent areas (positive/negative/neutral) shall be in conformance with ASHRAE/ANSI Filtration shall be in conformance with ASHRAE/ANSI Wet coils or drain pans shall not be permitted in these spaces Process Systems. Process heating, cooling, and ventilating systems necessary to support equipment essential to the function of Category 1 areas shall be provided with standby or redundant generation sources such that if the largest piece of source equipment serving the processes fails, the remaining source equipment serving the processes shall be 17

19 capable of serving the load On-Site Fuel Storage On-site fuel or the essential electrical system or both as required for proper operation of the system including controls shall be provided to serve heating, cooling, ventilating, humidity control, and process systems for Category 1 spaces * On-site storage shall be provided for enough fuel to continue operations of Category 1 spaces for a minimum of 96 hours of normal operation On-Site Fuel Storage On-site fuel or the essential electrical system or both as required for proper operation of the system including controls shall be provided to serve heating, cooling, ventilating, humidity control, and process systems for Category 1 spaces On-site storage shall be provided for enough fuel to continue operations of Category 1 spaces for a minimum of 24 hours of normal operation. The new redundant or standby climate controls simply increase the cost of healthcare operations while adding no degree of safety. I can find no evidence of instances where mortality was directly associated with the conditions this standard would eliminate. Presumptively these proposals will only be fully met by not only doubling the cost of mechanical equipment but also by increasing the load capacity of emergency power generation to run those systems currently not supported while providing no added margin of safety. On-site storage requirements for fuel are location specific. Global minimums may not provide enough fuel or may create unneeded hazardous material storage that increases potential for both fire and environmental damage. Additionally, the requirements in and to maintain "normal operation" in Category 1 spaces creates the requirement for a non-emergency branch of emergency power along with the potential need for a secondary generation system for emergency power Log #303 HEA-MEC Darrell Fugate, Saint Alphonsus Regional Medical Center Delete all reference to redundant mechanical equipment for systems in category 1 areas. Is there data to support the added costs associated with redundant equipment? Health care dollars should be reserved for higher priority initiatives to improve care to patients and we should not spend our limited resources on additional HVAC equipment that is not necessary. 18

20 Log #308 HEA-MEC William Morgan, St. Alphonsus R.M.C. I would like to delete this proposal. Hospital areas identified needing a redundant mechanical system are not separate from the system used to maintain other areas of a facility. To add the required equipment and controls to manage this would add an additional burden to the cost of new construction that added minimal value to our patients. Other than an airborne isolation infection environment there is no need. Where would it start and stop? Twice the compressors, pumps, chillers, generators, ductwork, plumbing, electrical... Unrealistic. The TC was following the direction of the TCC which was to include HVAC in NFPA 99. The TCC wanted to have a first-stop document that addressed many facets of systems and directed the TC to address this subject. Section of the scope addresses HVAC. document must perform a risk assessment and based on the outcome of the risk assessment, they would choose the appropriate Category for the system Log #311 HEA-MEC Charles Block, Spectrum Health Eliminate redundant mechanical systems. To retroactively add the number of air handling units that a larger hospital would be required to add is extremely unreasonable and unnecessary with an implemented and monitored preventive maintenance program. It also is a matter of space Log #325 HEA-MEC John Hohman, Michigan Society for Healthcare Engineering Drop the requirement of redundant mechanical equipment. Redundancy doesn t seem necessary and we don t see support for this change. 19

21 Log #136 HEA-MEC Redundant or standby heat generating sources shall be provided for Category 1 spaces such that if the largest piece of heat generating equipment fails, the remaining heat generating equipment shall be capable of maintaining the minimum temperature at all times. Delete Entire Section. There is no technical justification or data to support redundancy of this system. The definition of Category 1 is "Facility systems in which failure of such equipment or system is likely to cause major injury or death of patients or caregivers" the potential for the failure of this system to cause Death or major injury is very unlikely. at most a failure of this system could cause discomfort. It would take prolonged exposure without caregiver intervention before death or major injury would be potential concern. There are many options available to facilities to mitigate the potential problems of this system failure - such as patient relocation, temporary units, and limited exposure. The inclusion of this requirements doubles the amount of equipment that is required in the current standard. A cost benefits analysis needs to be done before the requirements in this code are increased this drastically Log #169 HEA-MEC Diane Hughes, UAMS N/A Revise text to read as follows: Shall be provided considered. Based on cost factors providing the redundancy. 20

22 Log #210 HEA-MEC James R. (Skip) Gregory, Health Facility Consulting Redundant or standby heat generating sources shall be provided for Category 1 spaces such that if the largest piece of heat generating equipment fails, the remaining heat generating equipment shall be capable of maintaining the minimum temperature at all times. Delete Entire Section. There has been no data or substantiation of adverse patient outcomes submitted to support this new section to the code, requiring redundant heating sources for Category 1 areas. The definition of Category 1 is "Facility systems in which failure of such equipment or system is likely to cause major injury or death of patients or caregivers". The potential for the failure of this system to cause death or major injury to a patient or caregiver is very unlikely. At the most a failure of these systems could cause discomfort, but not death or major injury. There is no justification to require redundant systems to this extent. A failure to these systems does not constitute an immediate danger to the health and safety of the patient and when these systems are renovated, patients are removed from the areas affected by the renovation. To require this type of redundancy for these systems will increase the cost of health care construction with no appreciable improved patient outcomes. Before this requirement is added, there should be data collected from hospitals that will provide the necessary justification for this added cost. This comment is supported by the Codes and Standards Review Committee of the Health Care Section of NFPA Log #137 HEA-MEC Redundant or standby cooling sources shall be provided for Category 1 spaces such that if the largest piece of cooling source equipment fails, the remaining cooling source equipment shall be capable of maintaining the maximum temperature at all times. Delete Entire Section. There is no technical justification or data to support redundancy of this system. The definition of Category 1 is "Facility systems in which failure of such equipment or system is likely to cause major injury or death of patients or caregivers" the potential for the failure of this system to cause Death or major injury is very unlikely. at most a failure of this system could cause discomfort. It would take prolonged exposure without caregiver intervention before death or major injury would be potential concern. There are many options available to facilities to mitigate the potential problems of this system failure - such as patient relocation, temporary units, and limited exposure. The inclusion of this requirements doubles the amount of equipment that is required in the current standard. A cost benefits analysis needs to be done before the requirements in this code are increased this drastically. 21