EHS Global Moments: Reduced Oxygen Environments, U.S. vs EU Regulations

The world is full of environment, health and safety regulations, with new ones being added every day. Most of these requirements focus on manufacturing operations, but a surprising number of regulations apply to offices and other non-manufacturing, lower-risk operations! Check in with us once a month for our new blog series: EHS Global Moments, where we highlight a country-specific EHS regulation applicable to non-manufacturing operations, organized by place, topic, or theme.

Many data centers outside the U.S. have oxygen concentrations that are reduced below atmospheric levels for fire suppression reasons. However, this raises a big health and safety concern, considering that low oxygen concentrations can cause death from asphyxiation. The facilities with hypoxic air systems, which use nitrogen from ambient air to displace oxygen, are tightly controlled and monitored. In comparison, confined spaces such as tanks, utility vaults and manholes,  typically do not have well-controlled atmospheres, presenting more hazards for workers, like hazardous chemicals or physical hazards in addition to low oxygen. The regulatory approach for addressing low oxygen in data centers differs around the globe—here, we compare and contrast guidance from the U.S. and EU on reduced oxygen environments:

• In the U.S., regulations are code-based, with a set lower oxygen limit of 19.5%, below which employees are not allowed to enter without use of supplied air respirators or other controls. (This is codified by US-OSHA in 29CFR 1910.134, the Respiratory Protection standard).
• In the EU, data centers with hypoxic air systems are regarded as fundamentally different from confined spaces.  The EU regulatory approach is risk-based, which allows employees to work in lower-than-atmospheric oxygen concentrations in data centers when a risk assessment has provided ample assurance of employee safety. Data center operators in most European countries fulfill risk assessment requirements by designing and operating their hypoxic air facilities in accordance with EN 16750:2017, Fixed firefighting systems – Oxygen reduction systems – Design, installation, planning, and maintenance. EN 16750:2017 is a guidance document from which member countries may create local regulatory requirements. 

These differing regulatory approaches have created some conflict for our U.S.-based clients who send employees into data centers with reduced oxygen environments. While easier from a policy perspective to adopt the conservative U.S. limit of 19.5%, this approach is strongly contested in the EU, and has high cost and business consequences. 

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