back to blog roll
Jeff Mize Jeff Mize, RRT, CHT, UHMSADS | Updated on Apr 8, 2019

Why is fire safety important in a hyperbaric oxygen therapy facility?

Hyperbaric Oxygen Therapy (HBO) facilities are constantly at risk of fire, as conditions needed for fires to ignite can be easily met inside a hyperbaric chamber - hyperbaric chambers are a high oxygen environment in which "fuel" can be easily found in the form of cloth, paper and others.

How can HBO facilities comply with CMS NFPA safety requirements?

The US Centers for Medicare & Medicaid Services (CMS) requires hyperbaric facilities be compliant with the 2012 edition of the National Fire Protection Association (NFPA) 101 Life Safety Code (LSC) and NFPA 99 Health Care Facilities Code (HCFC). (See CMS website)

The LSC is a set of fire protection requirements designed to provide a reasonable degree of safety from fire. It covers construction, protection, and operational features designed to provide safety from fire, smoke, and panic. The HCFC is a set requirements intended to provide minimum requirements for the installation, inspection, testing, maintenance, performance and safe practices for facilities, material, equipment, and appliances. The LSC and HCFC, which is revised periodically, is a publication of NFPA, which was founded in 1896. NFPA is a global, nonprofit organization devoted to eliminating death, injury, property and economic loss due to fire, electrical and related hazards. All NFPA codes and standards can be viewed online for free at 

Prior to July 5, 2016, hospitals, nursing homes, ambulatory surgical centers and related facilities had to demonstrate that their fire and life safety programs satisfied different editions of NFPA 101 in order to meet the requirements of the Conditions of Participation (COP), as defined by CMS. Health care providers that participate in federal reimbursement programs are required to meet the CMS COP expectations. 

What is new in the 2012 edition? 

CMS identified several provisions of the 2012 editions of the LSC and NFPA 99 that have been permitted for use since 2012. A number of substantive changes made to the 2012 editions of NFPA 101 and NFPA 99 were already permitted through the categorical waiver process outlined in Survey & Certification (S&C) letters. Code elements such as furniture and equipment in corridors, community cooking options, special door locking permissions, medical gas master alarms monitored by a central computer, and emergency generator testing are among the already permitted subjects.

“Consideration for new sleeping and treatment suite designs, person-centered care models, and equipment currently used in the healing environment are just a few of the changes integrated into the 2012 edition of NFPA 101,” said Robert Solomon, NFPA division manager for Building Fire Protection and Life Safety. “Acknowledging these changing factors and the risk-based assessment currently required by NFPA 99 - and used by providers, designers and authorities having jurisdiction - ensures that patients and residents are provided the level of fire and life safety protection expected today.”

There are newer NFPA editions published after 2012. Can we utilize them as well? 

Yes, those editions can be utilized.  The key point is, at a minimum the standards set forth in the 2012 edition are required to ensure compliance with CMS.

The federal rule-making process to recognize the 2012 NFPA code edition requirements was a long term initiative that garnered more than 350 public comments when the draft rule was published in 2014. CMS requires that facilities participating in the Medicare and Medicaid programs be compliant  NFPA LSC and HCFC published in 2012 or later. CMS partners with State Agencies (SA) to assess facilities for compliance with the LSC requirements. SAs may enter into sub-agreements or contracts with the State Fire Marshal offices or other State agencies responsible for enforcing State fire code requirements.


NFPA has created a CMS resource page with code requirements, training, webinars and other relevant content to help users as they transition from the 2000 edition of these two codes to the 2012 versions. Among the products and programs being offered by NFPA are:

  • Quick Compare Life Safety Code 2000 & 2012 for Health Care 
  • NFPA 101 Code and Handbook Set with FREE Quick Compare, Life Safety Code 2000 & 2012 for Health Care, 2012 Edition
  • Life Safety Code (2012) Essentials for Health Care Occupancies Class Room Training
  • Certified Life Safety Specialist (CLSS-HC) Certification Program

The Life Safety Code Comparison (PDF) by The American Society for Healthcare Engineering (ASHE) of the American Hospital Association compares 2000, 2009, and 2012 Life Safety Code.

The WoundReference Hyberbaric Oxygen Therapy Knowledge Base features guidelines to promote high standards of patient care and operational safety within the hyperbaric program and other important tools (See  Safety Program GuidelinesDesignation of Safety Director, and  Go-No-Go Lists / Prohibited Items)

For customized safety programs and other wound care and hyperbaric medicine consultation services, visit MidWest Hyperbaric

About the Authors

Jeff is a Principal Partner with Midwest Hyperbaric LLC and is the Co-founder and Chief Clinical Officer for Wound Reference. Jeff is a Registered Respiratory Therapist, a Certified Hyperbaric Technologist (CHT) by the National Board of Diving and Hyperbaric Medical Technology, a Certified Wound Care Associate (CWCA) by the American Academy of Wound Management. After receiving primary hyperbaric training from National Baromedical Services he trained as a UHMS Safety Director and is a UHMS Facility Accreditation Surveyor. He is the 2010 recipient of the Gurnee Award and the 2013 recipient of the Paul C. Baker Award for Hyperbaric Oxygen Safety Excellence. He has also served on the UHMS Board of Directors (2010-2015) In 2020, Jeff received "The Associates Distinguished Service award (UHMSADS). "This award is presented to individual Associate member of the Society whose professional activities and standing are deemed to be exceptional and deserving of the highest recognition we can bestow upon them . . . who have demonstrated devotion and significant time and effort to the administrative, clinical, mechanical, physiological, safety, technical practice, and/or advancement of the hyperbaric community while achieving the highest level of expertise in their respective field. . . demonstrating the professionalism and ethical standards embodied in this recognition and in the UHMS mission.”
Explore our Wound Care and Hyperbaric Solutions