Windowless Surgical Suites

[Coug Dad]

It appears to me that the 2012 NFPA 101 and NFPA 99 eliminated the requirement for smoke exhaust in windowless surgical suite using anesthesia. The requirement was very explicit in the 2005 edition but since NFPA 99 was totally restructured, is it not there or am I missing it? Anyone have experience with this? Is there a similar requirement in IBC?

 

[mtlogcabin]

This might get you started depending on the size and layout of the building.

2009 IBC

408.9 Windowless buildings.

For the purposes of this section, a windowless building or portion of a building is one with nonopenable windows, windows not readily breakable or without windows. Windowless buildings shall be provided with an engineered smoke control system to provide a tenable environment for exiting from the smoke compartment in the area of fire origin in accordance with Section 909 for each windowless smoke compartment.

 

[Coug Dad]

Thanks MLC. The building is not windowless so 408.9 would not apply. NFPA 99 2005 specifically requires smoke exhaust in windowless surgical suites. That requirement does not appear to be in the 2012 edition.

 

[cda]

101 also took out the requirement for openable windows in the patient suites

 

[mtlogcabin]

I don't believe the section requires the whole building to be window less. It would apply to portions of a building as well

407.4 requires smoke compartments in an I-2 (depending on sq ft and occupant load) so if the surgical portion in the smoke compartment is windowless then an engineered smoke control system is required

 

[Dr. J]

I have way too much experience with this.

Yes, the 2012 version of NFPA 99 has eliminated the requirement for smoke evacuation from windowless anesthetizing locations. No, there is not a similar requirement in the I codes. In fact the real issue is the conflict between the previous versions of NFPA 99 and the I codes.

The issue between NFPA 99 and the I-codes is in it's application. While CMS wants the Anesthetizing Location to be actively purged during a fire alarm, meaning that smoke dampers and fans must remain on, the I codes wants everything shut down unless a full blown IBC/IFC Ch. 9 engineered smoke control system is used. This is obviously a huge impact to an already complicated healthcare HVAC system.

One thing to keep in mind, is that as far as CMS and TJC are concerned, the 1999 version of NFPA 99 is what is adopted, and therefore Anesthetizing Location smoke evac is still required. Around here it seems CMS is making a concerted effort to cite existing hospitals and ASC's without Anesthetizing Location smoke evac before it is officially eliminated when the 2012 NFPA 101 is finally adopted. Also, in CMS's alleged mind the "windowless" part has no bearing - all Anesthetizing Locations require smoke evac, with or without windows. They are also expanding their definition of what an Anesthetizing Location is. Such as an MRI where they "might" use inhalation anesthesia.

 

[Code Shepherd]

IBC 408.9 only applies to Group I-3 occupancies so be careful about requiring smoke control just because there are no windows. To be clear, the IBC only requires full 909 smoke control in atriums, malls, underground buildings and windowless I-3s. Other uses such as stages or high rise have some form of smoke control such as venting or smokeproof enclosures.

IBC does not and never has required a separate form of smoke evac for surgical suites, nor has it ever discussed anesthetizing locations the way NFPA 99 does. You can get the brunt of IBC's healthcare requirements in Sections 308, 407 and 1014.2 (suites). Don't forget Section 422 as of the 2009 for ambulatory health care. The biggest deal in IBC as mtlogcabin points out is the smoke compartmentation.

Dr. J is absolutely correct in his statements and this is an issue healthcare will be dealing with for the next few years. NFPA 99 2012 references ASHRAE 170 for heating, cooling, ventilation and process systems in Section 9.3.1. ASHRAE 170 does not require smoke evac of operating rooms. There is discussion that CMS wants to keep the smoke evac provision of NFPA 99 even though the new edition takes it out; TJC has been clear in it's recommendation to adopt the new 99 as written.

Laslty don't hold your breath for CMS to adopt 2012 101 or 99. The buzz we are hearing is 2 to 3 years minimum.