Yoopersup, I don't have access to the handbook, but the way you write the code article references with a dash is pre 2002.

There is no 517.3 in the 2002 code.

The emergency issue is not the only problem, and as you said, may not apply at all in this case.

With the definition of Patient Care Area in 517.02, We would still have to meet the requirements of 517.13.

After rereading your post, it appears as though you are just talking about feeders, and if this is the case you are OK. (my mistake)

Roger