HTM Discussion Group

Categorical Waiver for Wet Locations

  • 1.  Categorical Waiver for Wet Locations

    Posted 06-07-2018 13:15

    ​​Has anyone successfully gotten a categorical waiver approved to reduce the number of operating rooms that are considered wet locations by the NFPA99-2012 edition definition?

    We were notified during our last DNV survey that due to the adoption of the 2012 edition and because our OR's do not have LIM protection, we were going to have to start testing ground integrity on every device in every OR twice a year.  In our case, this would add well over a 1,000 additional checks in our ORs every year.

    I have heard that some facilities had been able to reduce the number of OR's that were considered wet locations by examining what type of cases were generally performed in each OR and getting the board to approve classifying only the OR's where the NFPA definition truly fits as wet locations.

    Any information or advice on this topic would be most appreciated!


    Joe Howe

  • 2.  RE: Categorical Waiver for Wet Locations

    Posted 06-13-2018 12:10

    I am not aware of any categorical waiver process regarding isolated power systems.

    NFPA 99 (2012) does make IPS (or GFCI, which would not be advisable for ORs) the default for wet procedure locations unless a formal risk assessment is conducted (as outlined in NFPA 99).

    I believe that the DNV surveyor was incorrect about the need for additional ground integrity testing in the absence of IPS. This is certainly not required by NFPA 99 (2012).

    Also, keep in mind that the IPS-related requirements of NFPA 99 (2012) are not retroactive for existing installations.

    I would recommend gathering additional information and then conducting a risk assessment to determine which (if any) of your ORs need to be designated as wet procedure locations.

    More detail can be found in AAMI's Electrical Safety Manual (2015).

    - Matt

    Matthew Baretich CCE PhD PE
    Baretich Engineering Inc
    Fort Collins CO United States (970) 493-8239