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Patient care space categories

Sifu

SAWHORSE
Joined
Sep 3, 2011
Messages
3,315
2023 NEC 517 appears to have moved or removed the defined categories for patient care spaces (517.2 from the 202 NEC). If removed how are the appropriate sections like 517.18 administered, which has requirements for a category 2 space? If moved, where do I find them? The 2020 defined spaces included direct references to NFPA 99, which I assumed would tie the 99 categories to the NEC categories.

I checked what I believe to be the Health Care Governing Body, which I assume is the State Dental board and I can't find any reference to these spaces. The DP has included the requirements for a category 2 space, so is their designation enough?
 
2023 NEC 517 appears to have moved or removed the defined categories for patient care spaces (517.2 from the 202 NEC). If removed how are the appropriate sections like 517.18 administered, which has requirements for a category 2 space? If moved, where do I find them? The 2020 defined spaces included direct references to NFPA 99, which I assumed would tie the 99 categories to the NEC categories.

I checked what I believe to be the Health Care Governing Body, which I assume is the State Dental board and I can't find any reference to these spaces. The DP has included the requirements for a category 2 space, so is their designation enough?

The 2023 NEC no longer includes the specific definitions for patient care space categories that were previously found in section 517.2 of the 2020 NEC. Instead, the NEC now relies on NFPA 99 (2021 edition) for the categorization of patient care spaces. The reference to NFPA 99 ensures consistency across healthcare codes by categorizing spaces based on risk to patients rather than prescriptive definitions within the NEC itself. As a result, healthcare facilities must determine the appropriate category through a risk assessment process outlined in NFPA 99, which should then guide the application of NEC requirements.

In regard to 517.18, which addresses Category 2 spaces, the requirements for electrical installations remain in place. The responsibility for determining whether a space falls under Category 2 now lies with the healthcare facility’s governing body, which should conduct a risk assessment to classify the space accordingly. If the design professional (DP) has included the requirements for a Category 2 space in the design, it suggests that a risk assessment has been conducted. In most cases, the DP’s designation is sufficient, provided it aligns with NFPA 99 standards and is documented properly. However, the final determination rests with the Authority Having Jurisdiction (AHJ), who will ensure compliance with both NFPA 99 and NEC requirements.

If no references to these categories are found within the State Dental Board regulations, it is still important to follow NFPA 99 guidelines and rely on the risk assessment performed by the facility or design professional. The facility should maintain documentation of this assessment to demonstrate compliance during inspections or audits.
 
That was my assumption, but the 2023 NEC didn't bracket any references to NFPA 99 in the specific code (the fpn to 517.1 indicates that text followed by brackets have been extracted from the 2021 NFPA 99, but brackets are only shown for 517.8(C)), and the categories in NFPA 99 appear to be only for piped gas and vacuum system requirements based on the text of NFPA 99 15.1.2. I understand why they would remove and defer to NFPA 99 to avoid changes in one code not being consistent with another code but a direct reference or fpn advising to use NFPA 99 for categories would remove confusion, at least for me. But maybe they do and I'm just not seeing it.
 
Scoping for electrical system help.......

This dental facility has been declared to be a category 2 facility in response to my comments to verify the category by both the architect and electrical engineer. However in that same declaration they cite NFPA 99 6.4.2.1.2, which does not exist in any of the NFPA version since 2015, and where it existed prior to that was not applicable to their case. They use this citation to say that an EES is not required for a category 2 facility.

Per 99 4.3 the risk category must meet ch. 5 through 11, 14, &15 unless modified in those chapters.
Ch. 6: 6.5.1 requires a type 1 or 2 EES for a category 2 facility. (category 3 or 4 don't require an EES)
Ch. 15: Specific to dental facilities does not modify 6.5.1.

Based on the EE making the determination that it is a category 2 facility, I don't see why they think the code does not require an EES. Rather than repeat their response word for word I will paste it below. Basically they say since no critical care, no EES required. The code section they cite does not exist, but in general is correct in that an EES is required for category 1 facilities. What they fail to recognize (beyond the correct code reference) is 6.5.1, which DOES require an EES for category 2 facilities.

The architect provided a statement that it is a category 2 space, but that no sedation will be conducted, and there is no piped medical gas, only portable cylinders. This would seem to actually be a category 3 or 4 space, and not require an EES. But since they both declare it to be a category 2 I don't think I have a choice.

Am I missing something, or are they?

From the EE:
1740422136838.png
 
Maybe I have not had enough dental work, but I have not seen a procedure that would but me/ my health at risk if the power went out....At my dentist...
 
Just one of the reasons I think it is a category 3, but they insist that it is a category 2, but that an EES isn't required. I think they have two choices; correctly identify the facility as a category 3 with no required EES, or provide an EES for a category 2 they say it is. I will be having a conversation with them to see if I can see why they think it is category 2 and/or why they think they don't need an EES if it is.
 
The 2023 NEC no longer includes the specific definitions for patient care space categories that were previously found in section 517.2 of the 2020 NEC. Instead, the NEC now relies on NFPA 99 (2021 edition) for the categorization of patient care spaces. The reference to NFPA 99 ensures consistency across healthcare codes by categorizing spaces based on risk to patients rather than prescriptive definitions within the NEC itself. As a result, healthcare facilities must determine the appropriate category through a risk assessment process outlined in NFPA 99, which should then guide the application of NEC requirements.

...

If no references to these categories are found within the State Dental Board regulations, it is still important to follow NFPA 99 guidelines and rely on the risk assessment performed by the facility or design professional. The facility should maintain documentation of this assessment to demonstrate compliance during inspections or audits.

What's the likelihood of a walk-in urgent care clinic facility (of which my town of about 40,000 population seems to have ten thousand -- they're as ubiquitous as Subway sandwich shops and Dunkin' Donuts shops) will have performed or will ever perform such a risk assessment?
 
What's the likelihood of a walk-in urgent care clinic facility (of which my town of about 40,000 population seems to have ten thousand -- they're as ubiquitous as Subway sandwich shops and Dunkin' Donuts shops) will have performed or will ever perform such a risk assessment?
One of my questions as well, but I can find no direction on exactly who conducts it. I assume the "governing body" would be the state dental board, but I can find no mention of it in any of their documentation. In this case, the response is "no sedation". Clearly wouldn't be a category 2, but we'll see what they say. I left a VM. I will ask the designer where the risk assessment is. I expect to hear crickets.

I would hope that an actual medical clinic has a little more scrutiny, but not a lot of confidence in that either. Where this dental facility is not inspected by the state, a medical clinic would be. But both must be licensed, so there should be some oversight by the licensing board. I hope. When I inspected actual health care facilities (not dental offices) we were there as a function of the state licensing board, independent of the AHJ. I only inspected them, so I really don't know if the state board required or maintained any risk assessments. It was a long time ago, so not even sure if that was a thing.
 
I am forced to use that a lot, but it is certainly not user friendly.

That's a feature, not a bug. It's designed to provide the minimal amount of public viewing that will prevent the federal government from whacking them over the head, while making it so painful to use that people will buy the standards rather than try to use the free portal.
 

Sort of.

UpCodes is able to do what they do under the legal principle that adopted laws and regulations are exempt from copyright protection and can bee freely copied and disseminated. UpCodes can't reproduce the model ICC code documents, and they can't reproduce the model NFPA documents. Anything you see on UpCodes is a version of the code or standard as it was adopted by a specific political jurisdiction. We can't go to UpCodes and find an unamended copy of anything (unless a code or standard was adopted by a jurisdiction without being amended).

In the ICC code books printed for my state's IBC and IRC, there's a double vertical line in the margin that informs readers where the code was amended by the state when adopted. I don't believe UpCodes in any way flags where the adopting amendments are located, so in looking at any code on UpCodes it's risky to assume that what you're seeing might apply in any other state, municipality, or jurisdiction.
 
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