life safety code compliance.15 (2) [read-only] safety code compliance... · the 2012 life safety...
TRANSCRIPT
5/5/2015
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Survey Hot Topics&
Preparing for the 2012 Life Safety Code®
May 2015
RPA Effectiveness
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Agenda
Most Common NYSDOH K-tags
Status of the 2012 Life Safety Code
Key 2012 Provisions
Categorical Waivers
Power Strips
Q&A
K56 & K62: Sprinkler Systems
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K29: Hazardous Areas
K50: Emergency Plans
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K38: Exit Access
K25: Smoke Barriers
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K20: Stairwells & Shaft Enclosures
K18: Corridor Doors
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K147: Electrical Issues
K144: Generator Testing & Inspection
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K69: Commercial Cooking Equipment
K12: Construction Type
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Fire Safety Evaluation System (FSES)
The 2012 Life Safety Code®
Change Can Be Good!
Improved readability
Incorporates 12 years (4 editions) worth of changes
Primarily beneficial changes to Health Care Occupancies
Reflects benefits of automatic sprinkler protection
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2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations / exceptions
Comment period until June 16, 2014
Much review…NFPA, ASHE, AHCA
Expect adoption sometime in 2015
Waivers3/9/2012, CMS released Survey & Certification
(S&C) letter 12-21-LSC allowing health care facilities
to use the “cultural change” provisions contained
within the 2012 LSC Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
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Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 8/30/13, CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the “cultural change” provisions
Facilities do not have to be cited to apply these
waivers
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Categorical Waivers
Facilities must COMPLY!
Assess compliance with applicable 2012 LSC
sections – not as easy as you may think!
Waiver compliance is not “automatic” – MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT!
As directed by CMS, NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form –
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
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Categorical Waiver Declaration Form
http://www.phillipsllc.com/resources/resource-library /
Categorical Waivers
Facilities must PRESENT!
As directed by CMS, NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
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Categorical Waivers
1. Openings in Exit Enclosures
2. Door Locking for Patient Special Needs
3. Doors with Delayed Egress
Categorical Waivers
4. Suite-to-Suite Exiting
5. Suite Exiting Utilizing Stairs, Passageway or Exterior
6. Suite Size
7. Clean Waste and Patient Record Recycling
Containers
Containers are labeled & listed as meeting FM Approval Standard 6921
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Categorical Waivers8. Corridor Projections for Wheeled Equipment
• Equip. does not reduce corridor width to less than 60 in
• Fire Safety Plan addresses relocation of wheeled equip.
• Wheeled equip. is limited to i. Equip. & carts in useii. Medical emergency equip. not in useiii. Patient lift & transport equip.
Categorical Waivers9. Corridor Projections for Fixed Furniture
• 8 foot corridor• Furniture is securely attached to the floor or wall• Furniture does not reduce corridor width below 6’• Furniture located on one side of corridor• Furniture groupings do not exceed 50 ft2• Furniture groupings separated by at least 10’
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Categorical Waivers10. Alternative Type Kitchen Cooking Arrangements
Categorical Waivers11. Direct-Vent Gas Fireplaces
12. Solid Fuel-Burning Fireplaces
13. Combustible Decorations
14. Medical Gas Master Alarms
(a) Decorations do not exceed 20% of wall, ceiling, & door areas inside any room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30% of wall, ceiling, & door areas inside any room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50% of wall, ceiling, & door areas inside patient sleeping rooms having a capacity not exceeding 4 persons in a smoke compartment that is fully sprinklered
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Categorical Waivers
15. Emergency Generators and Standby Power Systems
16. Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17. Testing of Electric Fire Pumps
18. Relative Humidity Levels in Anesthetizing Locations
19. Fire / Smoke Damper Testingnote: this waiver option is applicable to hospitals only
Categorical Waivers
20. Power strips
Power Strip Use in Patient Care Areas: The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99. This also exempts resident rooms in long‐
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line‐operated electrical appliances in resident
rooms for diagnostic, therapeutic, or monitoring purposes.
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Power Strips
Underwriters Laboratories (UL) Listing Standard
Phrase / Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps (SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY! Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT! Use the Categorical Waiver Declaration
Facilities must PRESENT! Inform the AHJ during survey opening meeting