My daughter, Trina Bogart, is an emergency department doctor. She recently emailed me a seemingly simple question. However, when I went to the 2014 National Electrical Code (NEC), I realized it was actually more complicated. The question involved combination toilet and sink units installed in a hospital’s emergency department cubicles, which have receptacles close to the basin. This emergency department was designed around ambulatory care.


Trina wrote that “many hospital emergency departments have at least one or more critical-care areas used for treatment of critically ill or injured patients. Some large suburban emergency departments may have an entire critical-care area. These rooms or areas may have patients on life-support equipment, such as ventilators and heart/lung machines, and various procedures are performed on injured or ill patients. In addition, many emergency departments are faced with having to hold patients in the emergency area for prolonged periods of time due to lack of in-patient bed capacity within other parts of the hospital. At times, the holding time for these patients may be a few hours to a few days in these areas, such that the areas would qualify as general-care or critical-care patient bed locations.”


So, are the receptacles within 6 feet of the basins in these areas required to be ground-fault circuit interrupter- (GFCI) protected?


First, the basics for patient care from Article 517 and NFPA 99 must be examined. For example, 517.2 of the NEC and 3.3.136 of NFPA 99 define a patient-bed location as “the location of a sleeping bed, or the bed or procedure table of a critical care area.” The definition for patient-care spaces in the 2014 NEC contains three new definitions pertaining to this specific question. The first is a basic-care space in which failure of equipment or a system is not likely to cause injury to the patients or caregivers but may cause patient discomfort. The second is a general-care space in which failure of equipment or a system is likely to cause minor injury to patients or caregivers. The third is a critical-care space in which failure of equipment or a system is likely to cause major injury or death to patients or caregivers. Both general- and critical-care spaces would be at issue from a patient and caregiver point of view.


The requirements for GFCI protection must be determined by first looking at GFCI protection in Article 210 for general requirements for branch circuits. Section 210.8(B)(5) requires any 125-volt, single phase, 15- or 20-ampere receptacle located within 6 feet of an outside edge of a wash basin or sink for other than dwelling-unit applications to have GFCI protection.


There are two exceptions to this general rule. The first deals with industrial laboratories having nothing to do with healthcare. A few Code cycles ago, however, 210.8(B)(5), Exception No. 2 to (5) was inserted, stating that “receptacles located in patient bed locations of general care or critical care areas of health care facilities, [other than those in hospital bathrooms covered by 210.8(B)(1)] shall not be required to be GFCI protected where within 6 feet of the basin.” In addition, 517.21 states that GFCI protection shall not be required for receptacles installed in critical-care areas where the toilet and basin are installed within the patient room.


The intent of this section is to ensure that a GFCI receptacle or a GFCI-­protected receptacle is not installed in a general-care or critical-care patient-bed location where life support and other extremely important diagnostic and electrical support equipment could be inadvertently connected to the GFCI-protected circuit.


To answer the original question and resolve this issue, the individual healthcare facility leadership and authorities with medical knowledge would best be able to handle how these areas are treated from an NEC and design perspective. Would electrical equipment or system failure likely cause injury or death to the patient or caregivers? Is it likely that the patient may be inadvertently connected to a GFCI-protected circuit where enough leakage current would trip the GFCI and put the patient in further jeopardy? Normally, electrical engineers designing the system, electricians installing the circuits and electrical inspectors checking the emergency room area should not be required to make that determination. Instead, trained and knowledgeable personnel within the facility should make the GFCI-­protection requirement for these areas.