Q: We recently had our triennial accreditation survey and the surveyors are saying that each individual oxygen tank must be labeled as being ‘Full’ or ‘Empty’, even though the rack is labeled or there is a sign above the tanks to indicate partial cylinders. Is this correct?

A: NFPA 99-2012, section 11.6.5.3 is pretty clear: “Empty cylinders shall be marked to avoid confusion and delay if a full cylinder is needed in a rapid manner.” So that tells me that cylinders that are empty need to be marked. But since the standard does not say how the cylinder needs to be marked, and since the Accreditation Organization did not say how the cylinder needs to be marked, the hospital gets to decide how to mark the cylinder.

So, if the plastic cap is missing from the empty cylinder or the plastic strap that holds the cap the on is missing, then the hospital can claim that is the method to mark the empty cylinder. NFPA 99-2012, section 11.6.5.2 says: “If empty and full cylinders are stored within the same enclosure, empty cylinders shall be segregated from full cylinders.” So, as long as the cylinders are segregated and as long as the empty cylinders are marked somehow, you should be good.