Throughout my years of designing electrical infrastructures for health care facilities, I’ve seen this topic discussed many times in heated detail — particularly with reference to operating rooms. The resulting determination has varied throughout the years, and the outcome seems to trend with the latest “incident” that has hit our industry.
NFPA 99 (2012 edition) — aka the “Health Care Facilities Code” — does help us with the determination and gives us some guidance for defining a wet procedure location for a health care facility. Article 188.8.131.52.8.2 discusses Wet Procedure Locations in general, and Art. 184.108.40.206.8.4 specifically addresses operating rooms.
Article 220.127.116.11.8.4 states: “Operating rooms shall be considered to be a wet procedure location, unless a risk assessment conducted by the health care governing body determines otherwise.” This particular Article also has an asterisk (*) associated with it, which directs the reader to the Annex of the Code for further explanation. Although the Annex is not enforceable, it often enhances and assists in the explanation of the intent of the Code verbiage. The Annex explains, “In conducting a risk assessment, the health care governing body should consult with all relevant parties, including, but not limited to, clinicians, biomedical engineering staff, and facility safety engineering staff.”
What does this mean? Well, if no risk assessment is completed by the facility for the operating room, then the Code considers the room a wet procedure location by default. As a design engineer, I must comply with the Code. Often, I am told by the facility to “just tell us what to do,” but it is clear that the Code states it is not the design engineer’s responsibility to complete the assessment.
This shift of responsibility to the “health care governing body” is often difficult for some facilities to understand. I can easily advise my clients that an ortho room, rooms which require a significant amount of irrigation, and teaching hospitals are typically wet procedure locations — unless the facility has a stated protocol for liquid mitigation. If there are additional protocols in place, then the determination of a wet procedure location isn’t as clear cut. This is where the “relevant parties” at the facility become crucial members of the assessment team.
Even though it is not my responsibility as a design engineer to create the risk assessment, it is my responsibility to advise my clients that they can, and should, conduct a risk assessment to determine if the room actually is a wet procedure location. The facility knows the specific use of the rooms, the risks for their particular facility and staff, and their protocol for process and procedures. If the facility chooses not to complete a risk assessment, then per Code the room is to be deemed a wet procedure location. With the determination of a wet procedure location many other Code ramifications (and costs) are then required for the procedure (operating) room design.
The cost of the installation should not drive the wet location determination or the risk assessment. Each procedure room should be evaluated to determine its function and subsequent need to be protected as a wet procedure location. Just as budget shouldn’t be the determination for the room assessment, the Code required default of a wet procedure location does not need to be the basis of design for a room if it does not warrant the additional electrical provisions.