NFPA 70B, Recommended Practice for Electrical Equipment Maintenance, has historically been just that: a recommendation.
However, beginning in 2023, that recommendation will now become a standard, i.e., it will be become enforceable once adopted by an authority having jurisdiction (AHJ). Furthermore, if approved by National Fire Protection Association (NFPA) membership and the NFPA Standards Council next summer, NFPA 70B will acquire its new status as a standard at the end of next year. While it may not become applicable immediately, it is important to be ready for the eventual change.
Although there is no indication it will be directly adopted by the Centers for Medicare & Medicaid Services, NFPA 70B will likely be referenced in future editions of NFPA 70® National Electrical Code® (NEC). It may also be adopted directly by states as they adopt current editions of the NEC.
The adoption of NFPA 70B won’t come without its conflicts, however. Recent editions of NFPA 99, Health Care Facilities Code, have included a section on electrical preventative maintenance. The intent of the new section of NFPA 99 isn’t to create a new requirement, but rather to locate all the requirements in one, easier to use location for health care facilities managers. NFPA 70B also has developed some new requirements that conflict with existing NFPA requirements that health care organizations will need to sort out with their local AHJ. A few examples of this include:
Receptacles and ground fault circuit interpreters:
NFPA 99 section 18.104.22.168 includes requirements for annual inspection of electrical receptacles in patient care spaces, but NFPA 70B may now require visual inspection as frequently as every month depending on its condition. NFPA 70B determines frequencies depending on three equipment condition levels: Equipment Physical Condition 1 being like new, Equipment Physical Condition 2 including equipment that has revealed issues in the past and Equipment Physical Condition 3 including equipment that has required repairs over the past two maintenance cycles.
Critical equipment that could “endanger personnel” must be identified as Condition 3, which may include patient care receptacles depending on the AHJ interpretation. It should also be noted that NFPA 99 focused on the receptacles in the patient care space, whereas NFPA 70 addresses all receptacles.
NFPA 99 requires transfer switches to be visually inspected monthly and tested and maintained every three years, whereas NFPA 70B could require inspection, testing and maintenance every year if the transfer switches are classified as Condition 3.
While in most situations the requirements in NFPA 99 would likely govern, in situations where local or state AHJ’s have adopted NFPA 70B and have not adopted NFPA 99, the AHJ would not recognize the conflict. It will be important to keep an eye on future adoptions and ensure that the requirements already established by NFPA 99 are considered in any local adoption efforts.