Application of Section 24 of the CE Code, Part I, and CSA standard Z32: What, Why and How?

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Application of Section 24 of the CE Code, Part I, and CSA standard Z32: What, Why and How?
Doctors running to the operating room

Although this subject has been already discussed in one of my earlier articles, I continue to receive numerous questions on the required correlation between CSA standard Z32 and Section 24 of the CE Code, Part I (CE Code) on the extent of a “patient care area”, on the extent of application of Section 24 of the CE Code, on maximum potential difference between the bonding poles of receptacles designated for patient care areas, on testing requirements in a patient care, on application of essential electrical systems and on significance of the definition of “health care facility administration” in Section 24 of the Code.

So, let’s try to clarify these issues by responding to the following 5 questions:

1. Question: What is a “health care facility” for the purpose of Section 24 of the CE Code?
Answer: Subrule 24-000(1) of the CE Code (2018 edition of the Code is used for the reference purposes) states the following:
“24-000 Scope (see Appendix B)

1) This Section applies to the installation of

a) electrical wiring and equipment within patient care areas of health care facilities; and
b) the portions of the electrical systems of health care facilities designated as essential electrical systems.”

So, before we discuss the definition of a patient care area, indicated in the scope of Section 24, we need to have clarity in respect to a health care facility. It should be noted that in Canada, administration of the health care is a provincial/territorial responsibility, and the federal government directly administers health to groups such as the military, and inmates of federal prisons. The federal government also provides some care to the Royal Canadian Mounted Police and veterans, but these groups mostly use the public system. Thus, in each province or territory, a typical health care facility is an entity which supports the delivery of a range of health services. This fact is reflected by the definition of health care facility in Section 24 as follows: “Health care facility — a set of physical infrastructure elements that are intended to support the delivery of specific health-related services.” Health care facilities (HCF) are subdivided by specific classes, as a range of medical services in each such HCF can vary from group homes and outpatient clinics to complex teaching hospitals with continuing medical care and supporting diagnostic and therapeutic services. These classes of HCF are defined and described in the CSA standard Z32, which applies to “Electrical safety and essential electrical systems in health care facilities.”

So, the users of the CE Code must apply provisions of Section 24 in conjunction with design, installation and inspection of electrical equipment and wiring methods in health care facilities, in accordance with the scope of Section 24.

2. Question: What about compliance with provisions of Z32?
Answer: CSA Standard Z32 is not listed in the normative (mandatory) Appendix A of the CE Code. Compliance with this standard is not required by Section 24, except for the emergency power specifically mandated by Rule 24-306 – to comply with Z32 as follows:

“An emergency supply shall be

a) one or more generator sets in accordance with CSA Z32; and
b) located on the health care facility premises and installed in a service room or enclosure in accordance with CSA C282.”

So, unless use of the CSA standard Z32 for all aspects of electrical safety and essential electrical systems in health care facilities is legally mandated by the respective authority having jurisdiction, compliance with provisions of this standard does not appear to be required. Appendix B Note on the scope of Section 24 provides the following information on this standard:

“Rule 24-000

This Section consolidates requirements that arise from electrical safety considerations applicable to specific areas in health care facilities.

Code users should consult CSA Z32 for further information regarding electrical safety and essential electrical systems in health care facilities. CSA Z32 contains provisions that are supplementary to the installation requirements specified in Sections 24 and 52 of this Code. These provisions include, for example, the arrangement of normal and emergency power supply, classification of patient care areas, classification of loads and branches of an essential electrical system, arrangements of normal and emergency power supply sources for the loads of an essential electrical system, and the minimum number of receptacles per patient care environment.

The content of this Section reflects the changing nature of health care. Procedures once reserved for hospitals are now performed in medical clinics. As such, this Section applies to patient care areas in all health care facilities, and its requirements are based on the care area (e.g., basic, intermediate, or critical). This approach is consistent with the provisions of CSA Z32.”

Of course, very important informational (but not mandatory) notes in relation to application of Z32 are also provided through various references to specific Rules of Section 24 in Appendix B of the CE Code, but as it was mentioned above, unfortunately (in my view), compliance with (all relevant to the designers and installers) requirements of this standard (except for emergency generators) is not mandatory from the perspective of the CE Code.

It should be noted that the scope of Z32 (2015 edition of the standard is used for the reference purposes) states the following:

“1 Scope

1.1 General

1.1.1 Application

This Standard deals with the following subjects:
electrical safety associated with health care provision; and essential electrical systems for health care facilities.

Note: See Clause 3 for the definition of “health care facility”.

1.1.2 Exclusions

1.1.2.1 This Standard is not intended to apply to veterinary facilities, although its electrical safety principles could prove useful in the design, construction, and operation of such facilities.

1.1.2.2 Uninterruptible power systems, which may be used for specific critical applications are not covered by this Standard.
    

Note: If a UPS is used within a healthcare facility, refer to Annex J for more information.
    

1.1.3 Relationship to the Canadian Electrical Code
Provisions of this Standard are supplementary to the installation requirements specified in Sections 24 and 52 of the Canadian Electrical Code, Part I and require compliance with Canadian Electrical Code, Part II standards.”

It should be also noted that CSA standard Z32 contains certain requirements which could be very beneficial to the Code users (i.e. arrangements of emergency generators, classification of essential electrical system loads and branches, areas of required location of a unit equipment for emergency lighting, minimum number of receptacles and branch circuits in patient care areas, etc.).

Users of the CE Code should be also aware that all definitions of Section 24 are harmonized and correlated with the applicable definitions of Z32, and that Z32 contains additional definitions that could be beneficial to the CE Code users for the purpose of understanding application of Section 24.

3. Question: What is a “patient care area” for the purpose of Section 24 of the CE Code?
Answer: As it was indicated above, Section 24 applies to “electrical wiring and equipment within patient care areas of health care facilities”, and understanding the suitability of a patient care and its extent is very important to the CE Code users, in order to select relevant installation requirements mandated by Section 24. Patient care area is defined by Section 24 of the CE Code as follows: “Patient care area — an area intended primarily for the provision of diagnosis, therapy, or care.”

However, the Code users are not consistent in understanding whether the definition “patient care area” applies to such locations as waiting rooms of the emergency wards, nurse station areas, corridors leading to patients’ sleeping rooms, play areas in children’s hospitals, etc., and such inconsistency impacts on installation of receptacles in patient care areas, as many designers, installers and regulators apply different criteria to the extent of the patient care area. It should be also noted that a patient care area is further subdivided into basic, intermediate and critical care areas, and each of these areas are also defined by Section 24 of the CE Code and by Z32 as follows:

“Basic care area — a patient care area where body contact between a patient and medical electrical equipment is neither frequent nor usual.

Intermediate care area — a patient care area in which body contact between a patient and medical electrical equipment is frequent or normal.

Critical care area — a patient care area that is an anaesthetizing location, or in which cardiac contact between a patient and medical electrical equipment is frequent or normal.”

Understanding of these definitions and what specific parts of a HCF they include is very important to the Code users, as this understanding will allow the users to select applicable installation provisions of Section 24 of the CE Code in such areas.
Z32 offers the following examples of patient area classifications:

“The area classifications shall be those specified in Section 24 of the Canadian Electrical Code, Part I, which are
basic care area;

Note: Examples may include
     a) patient examination rooms;
     b) patient rooms in a long-term care facility; and
     c) patient rooms in general, specialty, and rehabilitation hospitals where body contact between a patient and medical electrical equipment is neither frequent nor usual.
intermediate care area; and

Note: Examples may include
     a) wards and treatment and examination rooms in general, specialty, and rehabilitation hospitals;
     b) renal dialysis units;
     c) areas for non-invasive electrodiagnosis (ECG, EEG, EMG);
     d) patient preparation areas;
     e) physiotherapy departments;
     f) ultrasound suites;
     g) dental clinics;
     h) chiropractic clinics;
     i) physicians’ offices; and
     j) patient bedrooms.
critical care area.
    

Note: Examples may include
     a) angiographic laboratories;
     b) cardiac catheterization laboratories;
     c) cardiac care units;
     d) emergency trauma units;
     e) intensive care units;
     f) intensive care neonatal units;
     g) operating rooms; and
     h) burn units.”

So far, so good. But what about a massage therapy office, where a massage therapist only uses his/her hands for a massage procedures, or what about a psychiatry office, where the psychiatric expert only uses a verbal communication for treatment of a patient?

The answer to these types of questions could be found in the objective of Section 24. Section 24 is intended to be applied to installation of electrical equipment to those patient care areas where a permanently or cord connected medical electrical equipment is used for the purpose of intentional contact at patient’s skin surface or internally during the patients treatment, diagnostics or monitoring.

Thus, if any concerns or uncertainty exists in respect to such use of medical electrical equipment, this issue should be communicated with the heath care facility administration. This (also defined) entity will be discussed in the answer on question 5 below.

And what about a contact with a person’s skin of such electrically powered tools, as barber’s hair cut machines, manicure and pedicure tools, tattoo or piercing equipment, etc.? These electrically powered tools are not intended to be installed in accordance with Section 24 of the CE Code, as the above listed establishments are not considered to be patient areas of a health care facility.

4. Question: What is an essential electrical system and how to deal with installations related to this system?
Answer: “Essential Electrical System” is defined in Section 24 of the CE Code and in Z32, and installation of the essential electrical system is covered by 24-300 series Rules of the CE Code. Section 6 of Z32 also applies to essential electrical systems.
Section 24 of the CE Code defines essential electrical system as follows: “Essential electrical system — an electrical system that has the capability of restoring and sustaining a supply of electrical energy to specified loads in the event of a loss of the normal supply of energy.”
Rule 24-302(1) clarifies that an essential electrical system comprises three separate components as follows:
“(1) An essential electrical system shall consist of circuits that supply loads designated by the health care facility administration as being essential for
a) life safety in accordance with Section 46;
b) care of the patient; and
c) effective operation of the health care facility.”
Clause 6.1.1 of Z32 echoes this clarification by the following statement:
“6.1.1 The requirements of Clause 6 shall apply to electrical systems that are considered essential for
a) life and fire safety as specified in Subsection 3.2.7.9 of the National Building Code of Canada;
b) effective and safe patient care; and
c) the effective operation of the HCF during an interruption of the normal electrical supply for any reason.”

Table 6 of Z32 offers a comprehensive classification of loads and branches of the essential electrical system and helps the electrical designers in identifying the loads that must be connected to a vital branch or that are allowed to be connected to delayed vital or to conditional branches of the essential electrical system.

USA, California, Hawthorne

5. Question: What role does a health facility administration play in application of Section 24 of the CE Code and in application of the CSA standard Z32?
Answer: Health care facility administration is a truly unique decision making entity, which has authority to apply certain provisions of Section 24 of the CE Code and of CSA standard Z32. HCF administration is defined by Section 24 as follows: “Health care facility administration — the unit responsible for planning, organizing, directing, and controlling the health care facility in accordance with the policies of the health care facility and government statutes.”

Z32 offers a similar definition of this entity, but also defines “Administrator” as follows:

“Administrator — the person responsible for operating the health care facility (or his or her designee).

Note: The term “administrator” is used in this Standard to denote the authority representing the health care facility and charged with responsibilities specified in this Standard. The administrator may (and usually does) delegate these responsibilities to appropriately qualified individuals.”

These respective definitions impact on application of Z32 and Section 24 of the CE Code.

For example, Rule 24-302(1) provides the following criteria for circuits of essential electrical system based on the designation by the health care facility administration of the loads connected to these circuits.

“24-302 Circuits in essential electrical systems (see Appendix B)
1) An essential electrical system shall consist of circuits that supply loads designated by the health care facility administration as being essential for

a) life safety in accordance with Section 46;
b) care of the patient; and
c) effective operation of the health care facility.”
It means that not the electrical inspection authority, but the HCF administration is ultimately responsible for determination of the essential electrical system in the HCF and for selection of the loads connected to vital, delayed vital or conditional branches of this essential electrical system.

Section 6 of Z32 also clearly allocates responsibility of the administrator for decision making on the extent of application of the essential electrical system and on the extent of the emergency power supply requirements for the essential electrical system.

Note 1 on Clause 6.1 of Z32 states the following: “1) Essential electrical systems should not be automatically deemed necessary for areas where the risk to patient safety is not dependent on the availability of the electrical supply. It is intended by Clause 6 that the administrator of an HCF may determine a need to comply with provisions of Clause 6 for the specific areas of the HCF.”

Despite the requirement for the redundancy of emergency generators, Clause 6.7.2(b) of Z32 allows the administrator to accept a single generator as the emergency power supply source for essential electrical system, as follows:

“6.7.2 Generator set redundancy

The following requirements shall apply to generator set redundancy:
a) An emergency power supply shall be provided by not less than two generator sets conforming to CSA C282 and arranged in such a manner that upon failure of one of the generators, the second generator will automatically provide power supply to the vital loads described in Clause 6.3 within 10 s of unsatisfactory condition in the service in use.
b) Notwithstanding Item a), where it is acceptable to the administrator of a HCF, a single generator set may be used.”

Clause 4.2.6.1 of Z32 allows the administrator (in consultation with clinical staff and facility designers) to determine the area classification based on the types of procedures performed in these areas, as follows:

“4.2.6.1 General
The administrator, clinical staff, and facility designers shall clearly define which types of procedures are to be frequently or normally performed in specified areas of the HCF.”

Hopefully, the discussion above provided some clarification on this very interesting and not always consistently understood subject. And lack of such consistent understanding of Z32 and Section 24 of the CE Code requirements may lead to tangible adverse impact, if no timely correlation is achieved between the electrical designers, HCF administration, clinical staff and the AHJ.


Ark Tsisserev is president of EFS Engineering Solutions, an electrical and fire safety consulting company, and is a registered professional engineer with a master’s degree in Electrical Engineering. Prior to becoming a consultant, Ark was the Chief Electrical Inspector for the City of Vancouver. He is the immediate past chair of the CSA TC for the CE Code, Part I and for the CSA Strategic Steering Committee for the Requirements of Electrical Safety. Ark also represents the CE Code Committee on the CMP-1 of the National Electrical Code. Ark can be reached by e-mail at: ark.tsisserev@efsengineering.ca
His company web site is www.efsengineering.ca

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