"Applicability" and "Application" of NFPA 99-2012 edition, chapter 6:
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Many surveyors are citing elements in NFPA 99, 2012 edition that are not valid, surveyors are not reading and analyzing the intent of the code as a whole and the intent of “Application” vs “Applicability” as articulated in each chapter.
In chapter 1, paragraph 1.3 “Application”, the code (NFPA 99) states “This code shall apply to all healthcare facilities” but in chapter 6, paragraph 6.1 “Applicability”6.1.1 states “this chapter shall apply to new healthcare facilities” and furthermore, 6.1.2 states that “the following paragraphs shall apply to both new and existing healthcare facilities” and it lists the specific paragraphs that apply to new and existing healthcare facilities (14 paragraphs are listed) and paragraph 6.1.3 furthermore indicates which paragraph only applies to exiting healthcare facilities (it lists 6.3.2.2.2.3) and does not apply to new healthcare facilities.
The importance of understanding the concept differentiation between “Application and “Applicability” could save you grief and money as follows;
NFAP 99 (2012 edition), paragraph 6.3.2.2.11 requires “one or more battery – powered lighting units” in deep sedation locations (as well as in anesthetizing location) such as Endo, Broncho rooms, etc. and surveyors as of late have been citing this requirement but out of context with the stated requirements of paragraph 6.1.1 since “this chapter shall apply to new healthcare facilities”.
CMS has defined new healthcare occupancies as anything built or renovated after July 6, 2016, the adaptation date of NFPA 101-2012 edition (the life safety code) and NFPA 99-2012 edition (healthcare facilities code).
There are many more issues in both chapter 6 and chapter 5 (medical gases) of NFPA 99-2012 edition where the applicability and application are being misinterpreted by surveyors that you should investigate whether the citation is valid based on applicability of the code to the chapter being cited.
Jack Waisblat
President JT Service Contractor Corp
