2014 twin state seminar july 18, 2014 impact of cms’ adoption of 2012 nfpa 101 & 99 dave...
TRANSCRIPT
2014 TW
IN S
TATE
SEMINAR
J ULY
18
, 2
01
4
Impact of CMS’ Adoption of 2012 NFPA 101 & 99
Dave Dagenais, CHFM, CHSP, FASHE
CMS IS PROPOSING TO ADOPT NFPA 101 & NFPA 99 WITH THE FOLLOWING MODIFICATIONS
ADOPTION, CHANGE IN DEFINITION
Changes definition of “health care occupancy” from applying to “4 or more patients” to “regardless of the number of patients served”
Could apply to hospital outpatient depts.Based on billing of hospital-based provider services in outpatient buildings
ROLLER LATCHES
Does not allow the exception in the LSC that permits use of roller latches
CMS standards have permitted use of roller latches for more than 20 years
Roller latches have become common in behavioral health
ALCOHOL BASED HAND RUBS
2012 LSC allows ABHRs
Accepts 2012 LSC requirements but adds “if installed to prohibit inappropriate access”
– Interpretive guidance is needed to determine what this means.
SPRINKLER 4-HOUR RULE
NFPA 25 formerly required evacuation or fire watch of facilities if a sprinkler system was out of service for more than 4 hours in a 24-hour period.
This has been changed in NFPA 25 to 10 hours to accommodate a “work day.”
CMS proposes going back to the 4-hour period.
CMS WILL REQUIRE OR SMOKE VENTS
Required when flammable anesthetics were used
Removed as operating room ACH increased, sprinkler requirements were added, severity of fire risk and extent decreased
36" SILL HEIGHT
Okay for new construction
As written will apply to existing constructionHow many existing facilities will this affect?What is the cost to fix this condition?
Is it worth it?Staff should not break out windows during a fire
Patients should not be evacuated through windows
ADOPTION OF NFPA 99, 2012 EDITION
Directly adopts NFPA 99: Health Care Facilities Code
Except chapters:Chapter 7 = IT and Nurse CallChapter 8 = PlumbingChapter 12 = Emergency
PreparednessChapter 13 = Security
CATEGORIC
AL WAIV
ERS
S&C 13-58
Issued August 30th, 2013
Covers several “categorical waivers”
Allows substitution of a centralized computer system for (one) Category 1 medical gas master alarm.
MEDICAL GAS MASTER ALARMS
Permits existing openings in exit enclosures to mechanical equipment spaces if they are protected by fire-rated door assemblies.
OPENINGS IN EXIT ENCLOSURES
Reduces the annual diesel-powered generator exercising requirement from two (2) continuous hours to one hour and 30 minutes.
EMERGENCY GENERATORS AND STANDBY POWER SYSTEMS
Allows more than one delayed-egress lock in the egress path where the clinical needs require specialized security measures or when a patient requires specialized protective measures for safety.
DOORS
Allows:
1. Suite to suite egress
2. Allows one of the two required exits to enter an exit stair
3. Increase the sleeping room suite size up to 10,000 sq. ft.
SUITES
Allows:
1. Reduction in the testing frequencies for sprinkler system vane-type and pressure switch type waterflow alarm devices to semiannual,
2. Electric motor-driven pump assemblies to monthly.
EXTINGUISHING REQUIREMENTS
Allows the increase in size of containers used solely for recycling clean waste or for patient records awaiting destruction outside of a hazardous storage area to be a maximum of 96-gallons
CLEAN WASTE & PATIENT RECORD RECYCLING CONTAINERS
Corridor Width
New “Effective” Corridor width
Fixed furniture allowed
Rolling carts, equipment and movement aids allowed
S&C 12-21
Bench c.c.
5’-
0”
8’-
0”
DECORATIONS
Increases the amount of wall space that may be covered by combustible decorations
20% Not Sprinklered30% Sprinklered50% Sprinklered in patient room (less than 4)
FIREPLACES
Allows the installation of direct vent gas fireplaces in smoke compartments containing patient sleeping rooms and the installation of
solid fuel burning fireplaces in areas other than patient sleeping areas
S&C 13-25
OR Relative Humidity
lowering the humidity requirement for operating rooms and other anesthetizing locations from at least 35percent to at least 20 percent.
HOW TO REQUEST A CATEGORICAL WAIVERDocument your desire and that you comply with the
waiver provisions in your policy and procedures manual.
Verbally announce that you are requesting the waivers at each entrance interview of a survey
Check with your State Agency and verify the waivers will be accepted for licensing
Indicate Life Safety waiver requests in your BBI
Indicate Environment of Care waiver requests in your management plan
NFP
A 99
2012 EDIT
ION O
VERVIEW
AND DIS
CUSSION
ITEMS DELETED-OVERVIEW
Laboratory requirements
Manufacturers’ requirements on electrical equipment
Annexes B, D, & E are deleted. They are technology not used any longer.
All of the Occupancy Chapters
NEW ITEMS-OVERVIEW
Standard becomes a Code
Fundamentals Chapter on Risk
Information Technology and Communication Systems
Plumbing
Heating
Emergency Management (new requirements)
Security
Fire Protection unique to Health Care Facilities
HOW THE CODE WORKS
Determine the worst case procedure.
Select the Risk Category.
Select the systems or procedures in the Code that are prescribed by that level of risk Category
ADMINISTRATION(CHAPTER 1)To provide minimum requirements for the:PerformanceMaintenance, Testing and InspectionSafe practices based on risk
ADMINISTRATION(CHAPTER 1)Applies to all health care facilities (other
than home health)
Applies to NEW construction and equipment only
altered or renovated or modernized
Some testing and maintenance requirements apply to existing
Emergency Management and Security apply to existing
REFERENCED PUBLICATIONS (CHAPTER 2)All Referenced publication material has been
updated to most current version
DEFINITIONS(CHAPTER 3)3.3.9 Anesthetizing location – General
anesthesia
3.3.17 Battery powered lighting units – NFPA 70
3.3.63 General anesthesia and levels of sedation
Deep sedationGeneral anesthesiaMinimal sedationModerate sedation
3.3.109 Medical support gas
FUNDAMENTALS(CHAPTER 4)Category 1 - Facility systems in which failure
of such equipment or system is likely to cause major injury or death of patients or caregivers shall be designed to meet system Category 1 requirements as defined in this code.
FUNDAMENTALS(CHAPTER 4)Category 2 - Facility systems in which failure
of such equipment is likely to cause minor injury to patients or caregivers shall be designed to meet system Category 2 requirements as defined in this code.
FUNDAMENTALS(CHAPTER 4)Category 3 - Facility systems in which failure
of such equipment is not likely to cause injury to the patients or caregivers, but can cause patient discomfort shall be designed to meet system Category 3 requirements as defined in this code.
FUNDAMENTALS(CHAPTER 4)Category 4 -Facility systems in which failure
of such equipment would have no impact on patient care shall be designed to meet system Category 4 requirements as defined in this code.
FUNDAMENTALS(CHAPTER 4)4.2* Risk Assessment. Categories shall be
determined by following and documenting a defined risk assessment procedure.
A.4.2 Risk assessment should follow procedures such as those outlined in ISO 31010, NFPA 551, SEMI S10-0307 or other formal process. The results of the assessment procedure should be documented and records retained.
GAS AND VACUUM SYSTEMS(CHAPTER 5)Adding testing and inspection requirements
on existing non-stationary medical booms
Testing per manufacturers recommendations, every 18 months or based on risk assessment.
GAS AND VACUUM SYSTEMS(CHAPTER 5)5.1.4.8 Zone Valves. All station outlets/inlets
shall be supplied through a zone valve as follows:
The zone valve shall be placed such that a wall intervenes between the valve and outlets/inlets that it controls.
“Wet Location” changes to “Wet Procedure Location” throughout the entire document
ELECTRICAL SYSTEMS(CHAPTER 6)
Requires that overcurrent protection devices only be accessible to authorized personnel and not permitted in public access spaces
ELECTRICAL SYSTEMS(CHAPTER 6)
ELECTRICAL SYSTEMS(CHAPTER 6)Increases minimum number of receptaclesGeneral Care – From 4 to 8Critical Care – From 6 to 14Operating Rooms – New requirement of 36
Permits fuel transfer pumps, receptacles, ventilation fans, louvers and cooling systems related to generators to be added to the life safety or critical branch (deleted from equipment branch)
ELECTRICAL SYSTEMS(CHAPTER 6)
ELECTRICAL SYSTEMS(CHAPTER 6)Monthly Generator Testing - 10 second
transfer not required (Annual Confirmation)
New section which permits switches in lighting circuits connected to Life Safety and critical branch as long as they don’t serve as illumination of egress as required by NFPA 101
ELECTRICAL SYSTEMS(CHAPTER 6)
ELECTRICAL SYSTEMS(CHAPTER 6)New section on campus electrical systems
being added
Attempts to clear up conflicts
with NEC
ELECTRICAL SYSTEMS(CHAPTER 6)Requires all operating rooms to be wet
procedure locations (unless risk assessment is done)
ELECTRICAL SYSTEMS(CHAPTER 6)Permits isolated power or ground fault
protection within operating rooms
ELECTRICAL SYSTEMS(CHAPTER 6)Eliminates emergency system heading and
equipment system heading and utilizes branches
Life SafetyCritical Equipment
ELECTRICAL SYSTEMS(CHAPTER 6)Added text to permit a 0.1 second delay for
selective coordination
IT AND COMMUNICATION (CHAPTER 7)New chapter covers IT roomsFire protectionNurse callEmergency callStaff emergency assistance
PLUMBING(CHAPTER 8)TIA will cover plumbing requirements
Essentially will refer to othermodel codes or standards
TIA
8.1.4.1 Nonmedical Compressed Air
8.3.1 Potable Water. Potable water systems shall comply with applicable plumbing codes.
8.3.2 Nonpotable Water. Nonpotable water systems shall comply with applicable plumbing codes.
8.3.3 Water Heating. Maximum hot water temperatures shall comply with applicable plumbing codes.
8.3.4 Water Conditioning. Water shall be treated or heated to control pathogens in the water.
8.3.5 Nonmedical Compressed Air.
8.3.7 Grease Interceptors.
8.3.10 Grey Waste Water.
8.3.11 Clear Waste Water.
HEATING, VENTILATION AND AIR CONDITIONING(CHAPTER 9)New TIA will cover oxygen transfilling room
requirements
Waste Anesthesia Gas Disposal (WAGD)
TIA
9.3.3 Commissioning
9.3.7 Medical Gas Storage or Transfilling.
9.3.7.5.2 Natural Ventilation
9.3.7.5.3 Mechanical Ventilation.
9.3.8 Waste Gas.
9.3.9 Medical Plume Evacuation
ELECTRICAL EQUIPMENT(CHAPTER 10)Chapter reorganized
Testing requirements have been updated
Leakage requirements have been updated
MULTIPLE OUTLET CONNECTIONS(POWER TAPS)10.2.3.6
• Allows power taps that meet the followingo Permanently attachedo Some of load not over 75%o Cord meets NFPA 70o Electrical integrity is regularly verified
and documentedo When new equipment is attached,
integrity must be verified again.
GAS EQUIPMENT(CHAPTER 11)11.3.2.5 Temperature limitations to storage
of cylinders must comply with 5.1.3.3.1.7 (temperatures not to exceed 54o C or 130o F.
11.4.3.1.1 Specifies the requirements for carts and hand trucks that transport cylinders (must be self supporting and have appropriate chains.)
EMERGENCY MANAGEMENT(CHAPTER 12)Completely rewritten and expanded for 2012Two categories of risk
In-patient facility is expected to be operableIn-patient and out-patient areas that augment the critical mission but not receive in-patients
Requires a Hazard Vulnerability Analysis (HVA)Natural HazardsHuman-caused EventsTechnological Events
EMERGENCY MANAGEMENT(CHAPTER 12)Requires plans to manage resources and
assets
Requires Exercises
Requires Evaluation of Exercises
Special Care was taken to avoid conflicts with the Joint Commission and CMS
SECURITY MANAGEMENT(CHAPTER 13)Planning for protection of the Staff and Facility
beyond disasters
Requires a Security Vulnerability Assessment (SVA)
Requires a responsible person
Education requirements of security staffCustomer ServiceEmergency ProceduresUse of ForceDe-escalationUse of Restraints
SECURITY MANAGEMENT(CHAPTER 13)Requires procedures for HostageBomb ThreatWorkplace ViolenceDisorderly ConductRestraining Orders
SECURITY MANAGEMENT(CHAPTER 13)Identifies known security sensitive areas Emergency DepartmentsPediatric and Infant Care unitsMedication StorageClinical LabsForensic Patient Treatment AreasDementia or Behavior Health UnitsCommunications, data infrastructure and medical records
SECURITY MANAGEMENT(CHAPTER 13)Other subjects coveredMedia controlCrowd controlSecurity equipment – follow NFPA 731Employee practicesSecurity operations
HYPERBARIC FACILITIES(CHAPTER 14)Piping requirements have been updated
New requirements for location of shutoff valve
Updated requirements for reserve to central supply system
New requirements for hyperbaric medical air system
FEATURES OF FIRE PROTECTION(CHAPTER 15) Chapter applies to new and existing
Pulls most of text from NFPA 101
Fire alarm and detection
Protection of gas cylinder storage
HVAC detection requirements
Defend in place requirements
Closets sprinkler exception (less than 6 sq. ft.)
Orientation and training requirements
NFPA 1
01
2012 EDIT
ION O
VERVIEW
AND DIS
CUSSION
Normally occupied building service equipment support area
People not present on a regular basis
DEFINITIONS(CHAPTER 3)
7.2.1.5.1
• Door leaves shall open readily from the egress side.
7.2.1.5.2
• The requirements of 7.2.1.5.1 shall not apply when door is exposed to elevator temperature in compliance with listing.
MEANS OF EGRESS(CHAPTER 7)
MEANS OF EGRESS(CHAPTER 7)7.2.1.5.10.6
Two release operation is permitted on existing doors when an occupant load does not exceed three providing it does not require simultaneous operation.
EXISTING HEALTHCARE OCCUPANCY(CHAPTER 19)19.2.2.2.5.1
• Door locking is permitted for clinical or security needs provided staff can readily unlock doors.o Provisions must exist for rapid removal• Remote control locks• Keys carried by staff• Other reliable means
o Only one lock per dooro More than one permitted with AHJ
DELAYED EGRESS LOCKS(CHAPTER 19)• More than one delayed egress lock is
permitted in the egress path
DELAYED EGRESS LOCKS(CHAPTER 19)19.2.3.4
• Permits items in corridor such as wheeled equipment, carts in use, medical emergency equipment, patient lift and transport equipment and fixed furniture as long as it does not reduce the corridor width to less than 5 feet.
SUITES(CHAPTER 19)19.2.5.7.2.3
• Permits sleeping suites to be 7500 sq. ft. where protected with sprinklers.
• Can go to 10,000 sq. ft. o Direct visual supervisiono Supervised sprinkler system o Automatic smoke detection
SUITES(CHAPTER 19)Permits suites to egress through adjoining suite and more than one intervening room.
ALCOHOL BASED HAND RUB(CHAPTER 19)19.3.2.6
• Exempts one dispenser per room from the 10-gallon per smoke compartment requirement.
DECORATIONS(CHAPTER 19)19.7.5.6
Increases the amount of wall space that may be covered by combustible decorations
• 20% Not Sprinklered
• 30% Sprinklered
• 50% Sprinklered in patient room (less than 4)
SPRINKLERS(CHAPTER 19)19.3.5.10
Sprinklers not required in clothes closets in patient sleeping rooms where the area does not exceed 6 sq. ft.
CONTAINERS FOR RECYCLING, CLEAN WASTE OR PATIENT RECORDS (CHAPTER 19)19.3.5.10
May be between 32 – 96 gallons if they meet FM standard 6921.
Thank You
Questions?
Dave Dagenais, CHFM, CHSP, FASHE