Are Operating Rooms Wet Locations?
An ongoing NFPA 99 debate focuses on the issue of whether operating rooms need additional protection—at additional expense—against electrical shock

NFPA Journal®, January/February 2010

By Richard P. Bielen, P.E.

One of the key areas of debate in last year’s discussion of NFPA 99, Health Care Facilities, centered around the topic of "wet locations." The current 2005 edition of NFPA 99 requires operating rooms and other potential wet locations in hospitals to have special protection—usually either isolated power-supply systems or ground-fault circuit interrupters (GFCIs)—against electrical shock. There are two opposing schools of thought on this, and the discussion is far from over. The proposed 2010 edition of NFPA 99 was returned to the Technical Committee at last year’s Technical Session at the NFPA Conference & Expo®, and, as a result, the Technical Correlating Committee has entered the document in the Annual 2011 cycle. This means the next edition of NFPA 99 will be the 2012 edition. It also gives committee members that much more time to engage in the wet locations debate.

The proposed 2010 edition of NFPA 99 included 12 Notices of Intent to Make a Motion (NITMAMs) that were presented as a motion for change and discussed and voted on by the NFPA membership. One NITMAM addressed the issue of wet locations, and the subject generated considerable discussion at the technical committee level. It also resulted in a great deal of public discussion, including hundreds of comments both in support of, and in opposition to, the committee position, which is, by default, that operating rooms are wet locations unless a risk assessment conducted by the health care governing body determines otherwise and thus require special protection against shock, as well as spirited discussion at the Technical Session.

The discussion pits two large, vocal groups against each other. One supports the committee’s position that operating rooms are wet locations, with public comments generally indicating that there is frequent standing water, saline solution, or body fluids on the floors of these areas, situations that are potentially hazardous to patients and staff due to the possibility of electrical shock.

An equally vocal group maintains that not all operating rooms are wet locations. Whether an area is "wet" depends on the procedure being performed, this group argues, adding that history has shown that electrical shock is not a problem in operating rooms. This group feels that adding special protection to all potentially wet locations would be a significant and unnecessary cost when historical records do not support this action.

Historically, the standard has not specified which areas are considered wet locations, instead specifying areas that are not required to be considered wet-procedure locations, such as patient beds, toilets, bidets, and wash basins. The proposed 2010 edition changed all that, however. The term "wet location" was changed to "wet procedure location" to differentiate it from the definition found in NFPA 70®, National Electrical Code®, and in the Report on Proposals (ROP) the technical committee proposed the following change to the definition of wet locations to include operating rooms:

"3.3.185* Wet Locations. The area in a patient care area where a procedure is performed that is normally subject to wet conditions, including all operating rooms, while patients are present, including standing fluids on the floor or drenching of the work area, either of which condition is intimate to the patient or staff.

A.3.3.185 Wet Locations. Routine housekeeping procedures do not define a wet location. Spillage of liquids in an operating room location where surgery is performed is considered a wet location."

This now meant that in new construction and renovations, operating rooms would be required to have special protection against electrical shock. Existing construction would not have to meet this requirement if written inspection procedures, acceptable to the authority having jurisdiction, were continuously enforced and if the electrical system were installed and maintained in accordance with NFPA 70. This proposal was debated by the committee and passed the written ballot.

Next steps
The committee debated this issue at the Report on Comments (ROC) meeting. After much discussion, it became clear that a consensus would not be reached. The committee listened to the arguments from both sides and offered some compromise wording, including the elimination of the term "operating rooms" from the original proposal, since it violated the Manual of Style by incorporating a requirement in the definition. The committee also develop the following wording: "Operating rooms shall be considered to be a wet procedure location unless a risk assessment conducted by the health care governing body determines otherwise." Annex material supported this wording as follows: "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."

The compromise was intended to specify the operating room as a wet procedure location as a default condition. However, the health care governing body would be permitted to conduct a risk assessment to determine if the operating room should be considered a wet procedure location or not, after it reviewed the type of procedures that would be conducted, the types of electrical equipment present, the housekeeping procedures, and other factors. The comment passed the ROC ballot. A floor motion on this issue was not successful at the 2009 Technical Session, where the membership supported the committee’s position.

NFPA 99 is now in the annual 2011 cycle, and the technical committee will go back to the ROP, review and take action on all the previously submitted public proposals, and generate any necessary committee proposals. The committee is essentially starting over—except that it now has the benefit of the experience and knowledge gained from the previous cycle when NFPA 99 was returned. The Technical Committee on Electrical Systems will conduct its ROP meeting at the end of January 2010 to take action on the public proposals and restart the wet location dialogue.

At this point, no one can predict what the outcome will be. However, the issue has been openly debated by the committee and the public. The committee is well informed on the pros and cons of wet locations and protection methods. Stay tuned to see the final outcome.

Richard P. Bielen is director of Fire Protection Systems Engineering for NFPA. He is staff liaison for NFPA 99.