"Shall not apply"

d0nut

Member
Location
Omaha, NE
It means that those portions of article 700 specifically referenced do not apply to healthcare facilities. For example, 700.4 requires a generator to be sized for all of the connected loads to be operated simultaneously. NFPA 99, paragraph 6.7.1.2.7 states that the generator set(s) shall have capacity and rating to meet the maximum actual demand likely to be produced by the connected load of the essential electrical system.

Most of the requirements in NFPA 99 are also in NEC article 517. Paragraph 517.27 requires the life safety branch meet the requirements of Article 700, except as amended by Article 517. NFPA has also instructed the code making panel overseeing 517 that NFPA 99 is the governing standard for healthcare and that NFPA 70 should not contradict anything in NFPA 99. The most recent example I have is the selective coordination vs. coordination to 0.1 seconds discrepancy.
 

steve66

Senior Member
I think I've ran into this before too. You may be reffering to "700.10 D1 through D3 shall not apply. "

Does it mean the requirement does not apply? As in we are being less strict. You can ignore these requirements. That's the normal definition under of "shall not apply" used by NFPA.

But each paragraph lists a specific means of complying with the more general 700.10D. So does it mean that the specific means of complying listed in each paragraph shall not apply? IN other words, we are being more strict. You must find a better way to meet the more general requirement listed in 700.10D.

To make it more confusing, I'm not so sure they didn't really mean 700.10 D1.1 through D1.3 shall not apply. That would mean one must comply with either 700.10 D1.4 or 700.10 D1.5.

This whole idea of referring back and forth between 517, 700, and 99 yet deleting different requirements is getting a little crazy. Its even worse with the revisions every 3 years - as soon as they refer to one paragraph, it gets changed by another committee.
 

mbrooke

Batteries Not Included
Location
United States
Occupation
*
It means that those portions of article 700 specifically referenced do not apply to healthcare facilities. For example, 700.4 requires a generator to be sized for all of the connected loads to be operated simultaneously. NFPA 99, paragraph 6.7.1.2.7 states that the generator set(s) shall have capacity and rating to meet the maximum actual demand likely to be produced by the connected load of the essential electrical system.

Most of the requirements in NFPA 99 are also in NEC article 517. Paragraph 517.27 requires the life safety branch meet the requirements of Article 700, except as amended by Article 517. NFPA has also instructed the code making panel overseeing 517 that NFPA 99 is the governing standard for healthcare and that NFPA 70 should not contradict anything in NFPA 99. The most recent example I have is the selective coordination vs. coordination to 0.1 seconds discrepancy.

Thanks

But NFPA 99 says article 700 does not apply?
 

mbrooke

Batteries Not Included
Location
United States
Occupation
*
I think I've ran into this before too. You may be reffering to "700.10 D1 through D3 shall not apply. "
Exactly this.

Does it mean the requirement does not apply? As in we are being less strict. You can ignore these requirements. That's the normal definition under of "shall not apply" used by NFPA.

But each paragraph lists a specific means of complying with the more general 700.10D. So does it mean that the specific means of complying listed in each paragraph shall not apply? IN other words, we are being more strict. You must find a better way to meet the more general requirement listed in 700.10D.

To make it more confusing, I'm not so sure they didn't really mean 700.10 D1.1 through D1.3 shall not apply. That would mean one must comply with either 700.10 D1.4 or 700.10 D1.5.

This whole idea of referring back and forth between 517, 700, and 99 yet deleting different requirements is getting a little crazy. Its even worse with the revisions every 3 years - as soon as they refer to one paragraph, it gets changed by another committee.
I'm just like o_O
 

d0nut

Member
Location
Omaha, NE
But NFPA 99 says article 700 does not apply?
No. NFPA 99 (and NFPA 70, Article 517) states that Article 700 only applies to the life safety branch except as amended by NFPA 99 and NFPA 70, Article 517. Article 700 does not apply to the Critical or Equipment branches required in a hospital. All of the requirements in Article 700 not excluded by NFPA 99 or amended by Article 517 will apply to the Life Safety branch only. Also, the separate branches begin on the load side of their respective transfer switches.

For example, every switchboard and panelboard on the Life Safety branch requires a SPD because of the requirement in 700.8. The Life Safety branch on a single generator system also requires a portable generator connection box meeting the requirements of 700.3(F). This connection box is typically installed for the entire essential electrical system because it is easier and is more useful than just installing it for the Life Safety branch.

Since there appears to be quite a bit of confusion around the exempted sections, I will go through each one in detail. Since you used the 2018 NFPA 99 above, I will use the same version which also reverences the 2017 NFPA 70.

(1) 700.4 - 700.4 requires a generator to be sized for all of the connected loads to be operated simultaneously. NFPA 99, paragraph 6.7.1.2.7 states that the generator set(s) shall have capacity and rating to meet the maximum actual demand likely to be produced by the connected load of the essential electrical system. Therefore you only have to provide a generator sized to meet actual demand not all connected loads.

(2) 700.10(D)(1) through (3) - Requires feeder circuit, feeder-circuit equipment, and generator control wiring to be protected by sprinklers or be protected by a 2-hour fire rating, either through cable or raceway selection or concrete encasement. None of this applies. You can run the life safety feeders as THHN in EMT above a dropped ceiling that doesn't have the ceiling cavity sprinkled. A comment above 700.10 D1.4 and D1.5. These sections do not exist. I think there was some confusion and the correct references would be 700.10 (D)(1)(4) and (D)(1)(5). These would not apply since the parent 700.10(D)(1) does not apply.

(3) 700.12 - The amendment in NFPA 99 requires emergency lighting be supplied by a generator or other system meeting the requirements of 700.12 or by batteries in the luminaires. Therefore you need a generator or other system listed in 700.12 or luminaire batteries to provide the required emergency egress lighting. Please note this only applies to the life safety branch, so you would still need to provide a generator for the Critical and Equipment branches to meet the runtime requirements for the hospital.

(4) 700.32 - 700.32 requires selective coordination. NFPA 99 and Article 517 only requires coordination to 0.1 seconds for the Essential Electrical System. Therefore you only have to provide coordination to 0.1 seconds.
 

mbrooke

Batteries Not Included
Location
United States
Occupation
*
Thats just wonky o_O But your help is immeasurable. Probably the most confusing thing I've dealt with code wise. I'll ask more questions tomorrow.
 

mbrooke

Batteries Not Included
Location
United States
Occupation
*
For example, every switchboard and panelboard on the Life Safety branch requires a SPD because of the requirement in 700.8. The Life Safety branch on a single generator system also requires a portable generator connection box meeting the requirements of 700.3(F). This connection box is typically installed for the entire essential electrical system because it is easier and is more useful than just installing it for the Life Safety branch.
Single generator in the electrical sense correct? I know of buildings with multiple gens, but only one dedicated to the life safety. 😇 ;)




(2) 700.10(D)(1) through (3) - Requires feeder circuit, feeder-circuit equipment, and generator control wiring to be protected by sprinklers or be protected by a 2-hour fire rating, either through cable or raceway selection or concrete encasement. None of this applies. You can run the life safety feeders as THHN in EMT above a dropped ceiling that doesn't have the ceiling cavity sprinkled. A comment above 700.10 D1.4 and D1.5. These sections do not exist. I think there was some confusion and the correct references would be 700.10 (D)(1)(4) and (D)(1)(5). These would not apply since the parent 700.10(D)(1) does not apply.
I've seen many who interpret the code are requiring it. Not that you are automatically wrong. But I see many prints calls for concrete encasement of the life safety and protection of its branches.
 

d0nut

Member
Location
Omaha, NE
Single generator in the electrical sense correct? I know of buildings with multiple gens, but only one dedicated to the life safety.
Right. If you take down a generator for maintenance and the emergency egress lights would not illuminate upon loss of normal power, you need a way to connect another generator without modifying the permanent building wiring.

But I see many prints calls for concrete encasement of the life safety and protection of its branches.
It could easily be a local amendment or how the different NFPA codes are adopted that leads to this requirement, but if you are going strictly by NFPA codes it would not be required. Job specs are certainly permitted to exceed the NFPA requirements. You could have an owner require all circuits be concrete encased. It wouldn't be wrong, but you would still shake your head and tell all of your friends about this crazy job that put all conduits in concrete.
 

mbrooke

Batteries Not Included
Location
United States
Occupation
*
Right. If you take down a generator for maintenance and the emergency egress lights would not illuminate upon loss of normal power, you need a way to connect another generator without modifying the permanent building wiring.
I've got a secret weapon 😜 😜


Good? Bad? Indifferent?



It could easily be a local amendment or how the different NFPA codes are adopted that leads to this requirement, but if you are going strictly by NFPA codes it would not be required. Job specs are certainly permitted to exceed the NFPA requirements. You could have an owner require all circuits be concrete encased. It wouldn't be wrong, but you would still shake your head and tell all of your friends about this crazy job that put all conduits in concrete.
But is it really crazy? Why do hospitals get less security than an office building?
 

d0nut

Member
Location
Omaha, NE
That is an interesting approach. I probably would have tried to parallel the generators or have a tie breaker between the generator distribution equipment, but can see how the tiered transfer switch solution could work. Do you have to program in delays in the transfer switches to keep all of the load from going to generator 2 upon loss of normal power with this arrangement? Do you have any issues getting the Life Safety and Critical branches up in 10 seconds?

My guess as to why some of the requirements were removed is that with all of the extra hospital requirements for testing, maintenance, inspections, etc., there may be little practical benefit for the added construction costs. That got me thinking about the actual prevalence of hospital fires, and led me to this site: https://www.usfa.fema.gov/data/statistics/reports/snapshot_hospital.html

Some interesting facts on US hospital fires from 2012-2014:

1. Only 3% of fires extended beyond the room of origin.
2. 68.5% of fires were from cooking.
3. 60% of confined fires (44.5% of all fires) were confined to a cooking vessel.
 

mbrooke

Batteries Not Included
Location
United States
Occupation
*
That is an interesting approach. I probably would have tried to parallel the generators or have a tie breaker between the generator distribution equipment, but can see how the tiered transfer switch solution could work.
1) paralleling equipment is more costly 2) A single mode of failure on the busbar or parelleling logic renders the entire emergency system inoperative.

An example, several million square foot hospital with over 38 transfer switches all fed from one long massively complicated gear:



Do you have to program in delays in the transfer switches to keep all of the load from going to generator 2 upon loss of normal power with this arrangement? Do you have any issues getting the Life Safety and Critical branches up in 10 seconds?
Delay or interlocks. I prefer delays so each ATS is truly independent. No delay on the first, delay of about 5-8 seconds on the second after normal frequency and voltage is sensed on the emergency source. Service mode Selector switch can remove that delay.


No issue or delay if the first ATS is working correctly. If the first ATS fails to transfer or the life safety/life support generator does not start the second ATS transfers 5-8 seconds latter.

So 10 seconds normally, 15-20 seconds if something goes wrong. IMO this is acceptable because the first ATS fulfills the code minimum requirements. Second one is covering for failures which the code does not care about- ie no mandate that a hospital have more than one gen or more than ATS per branch.

There is the option of micro-controllers for speeding up that delay, but its more complexity and more that can go wrong.



My guess as to why some of the requirements were removed is that with all of the extra hospital requirements for testing, maintenance, inspections, etc., there may be little practical benefit for the added construction costs. That got me thinking about the actual prevalence of hospital fires, and led me to this site: https://www.usfa.fema.gov/data/statistics/reports/snapshot_hospital.html

Some interesting facts on US hospital fires from 2012-2014:

1. Only 3% of fires extended beyond the room of origin.
2. 68.5% of fires were from cooking.
3. 60% of confined fires (44.5% of all fires) were confined to a cooking vessel.

Yes, but fire works on containment. Do you really want a fire on one small hallway isolated with fire doors to take out feeders or branches crossing through the interstitial space?

Hospitals tend to have some of the worst power systems both in design and implementation.

Hurricane roles through. At one hospital the first generator does not start, second one explodes in a ball of fire 3 hours latter. Another hospital floods and fuel pumps in the basement shut down. At another the the paralleling gear can not synchronize overloading the one gen that energized the essential system... lots of event reports and stories over the years... all the while Goldman Sachs and major insurance buildings have power despite being 12 feet under water.

A lot of this comes from the way we viewed the sick I think...
 

d0nut

Member
Location
Omaha, NE
A lot of this comes from the way we viewed the sick I think...
I would blame the dollars more. When a power outage can cost you millions of dollars per hour or per minute, the ROI on some insanely robust electrical distribution systems looks pretty attractive. Easy to quantify, easy to fund, easy to build.

When most of your revenue is based on CMS reimbursements and subject to the whims of the federal government, it may be a bit more difficult to defend spending money beyond what is required. There are quite a few hospitals, especially in more rural areas, that are living on pretty thin margins.

Not that I am arguing against protecting the feeders, but it is a design decision that exceeds the NFPA requirements. Also, protecting the feeders would not have helped any of the cases you noted above. Again pure speculation here, but I still think that the incidences where protecting the feeders in a hospital would have mitigated or prevented an actual adverse outcome must be fairly rare. Otherwise I think it would be easy to provide justification to the code making panels to get those changes included.
 

mbrooke

Batteries Not Included
Location
United States
Occupation
*
I would blame the dollars more. When a power outage can cost you millions of dollars per hour or per minute, the ROI on some insanely robust electrical distribution systems looks pretty attractive. Easy to quantify, easy to fund, easy to build.

When most of your revenue is based on CMS reimbursements and subject to the whims of the federal government, it may be a bit more difficult to defend spending money beyond what is required. There are quite a few hospitals, especially in more rural areas, that are living on pretty thin margins.
Sure. But why let code make it so much worse? For example code requires three ATS. Why not have two of them supply patient bed areas?

Not that I am arguing against protecting the feeders, but it is a design decision that exceeds the NFPA requirements. Also, protecting the feeders would not have helped any of the cases you noted above. Again pure speculation here, but I still think that the incidences where protecting the feeders in a hospital would have mitigated or prevented an actual adverse outcome must be fairly rare. Otherwise I think it would be easy to provide justification to the code making panels to get those changes included.
In those cases certainly not. But if you ever see a fire where one side of the double doors looks normal and the other side is charcoal black you would be surprised. I also see things like dedicated critical and normal electrical rooms, only to have the risers side by side without protection. Practical diversity is easy to achieve.
 
Top