TJC Director of Engineering George Mills clarified TJC’s requirements for safe storage of medical gas cylinders in the February 2014 editions of both TJC Perspectives and EC News. The TJC articles, both entitled Maintaining Medical Gas Safety and located within the Clarifications and Expectations portion of each periodical, referred to NFPA 99-1999 section 4-3.5.2.2(b).

Section 4-3.5.2.2 is entitled “Storage of Cylinders and Containers—Level 1” and subsection (b) states:

“(b) Nonflammable Gases.

1. Storage shall be planned so that cylinders can be used in the order in which they are received from the supplier.

2. If stored within the same enclosure, empty cylinders shall be segregated from full cylinders. Empty cylinders shall be marked to avoid confusion and delay if a full cylinder is needed hurriedly.

3. Cylinders stored in the open shall be protected against extremes of weather and from the ground beneath to prevent rusting. During winter, cylinders stored in the open shall be protected against accumulations of ice or snow. In summer, cylinders stored in the open shall be screened against continuous exposure to direct rays of the sun in those localities where extreme temperatures prevail.”

Mr. Mills stated that the cylinders “should be stored in such a way that staff retrieving them in a hurry will not have to make a decision about which cylinders are full and which are not.” TJC’s position is that once a cylinder valve has been opened the cylinder is no longer considered full. The full cylinders must be segregated from all other cylinders. According to Mr. Mills, TJC also permits organizations to have “full” racks, “partial” racks and “empty” racks provided that clear segregation exists between the full cylinders and the others.

Organizations should also be sure to note the item (b)2 language in the NFPA 99 excerpt above that states “Empty cylinders shall be marked…” – a requirement that Mr. Mills also discussed.

In summary, TJC-accredited organizations should maintain safe storage of freestanding medical gas cylinders by physically separating and clearly labeling the cylinders to segregate full cylinders from partial and empty cylinders.  Once a cylinder valve is opened be aware that TJC no longer considers that cylinder to be full. Although the physical separation can be done by using separate racks, physical barriers, or color-coding the storage rack, we suggest that the approach be consistent within each facility. A multi-facility organization might also consider striving for organization-wide consistency if medical personnel float between facilities.