Partial O2 Cylinders
by Brad Keyes, CHSP, on Nov 4, 2020 12:00:00 AM
Q: Presently there is an interpretation at our facilities that "E" cylinders of oxygen that are "In Use" or "Not Empty" is an allowable title for storing oxygen tanks versus Empty and Full. Can you comment on this?
A: Where possible, I prefer to go by NFPA terminology, as does CMS. The Accreditation Organizations (AOs) typically do go by NFPA terminology, but sometimes they have their own unique terms for things that may depart from NFPA. In this situation, NFPA only uses the terms “Full” and “Empty” when referring to oxygen cylinders. NFPA 99-2012, section 220.127.116.11 says if empty and full cylinders are stored in the same enclosure, empty cylinders must be segregated from full cylinders. Section 18.104.22.168 continues by saying empty cylinders shall be marked to avoid confusion and delay if a full cylinder is needed in a rapid manner.
No-where in those sections does it address the cylinders that are neither full, nor empty (i.e. partials). So, when the codes and standards are silent on a subject, it is up to the authority having jurisdiction to decide what’s what. Some AOs are progressive on this and say partial cylinders should be stored separately, although they make it clear it is not mandatory. I like that idea of storing partial cylinders separately. I also like that term “partials” to describe them. The terms ‘In Use’ and ‘Not Empty’ don’t really say that these cylinders are partially full, but you may use whatever term you wish, but ‘partial’ seems to fit well. Make sure you comply with your accreditation organization’s standards (or recommendations) on compressed medical gas cylinder storage.