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2012
THE HEALTHCARE ENVIRONMENT
UPDATE
George Mills, Director
Engineering Department
The Joint Commission
Department of Engineering 2012 - 2
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LS & EC RANKING IN TOP 10 IN 2011
2. 56% LS.02.01.20 EP 13 Corridor Clutter3. 52% LS.02.01.10 EP 9 & 5 Penetrations
& Rated Doors 4. 45% LS.02.01.30 EP 2 Hazardous
Areas5. 40% EC.02.03.05 All EP’s Fire Safety
Testing 10. 31% LS.02.01.35 Sprinkler System
Department of Engineering 2012 - 3
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LS.02.01.20 (56%)
The hospital maintains the integrity of the means of egress.EP 13 Corridor Clutter
Also scoredEPs 16 – 22 Suites issues
Equivalize > 5000 sq ftEP 1 Doors locked in means of
egress
Department of Engineering 2012 - 4
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CORRIDOR STORAGE
“If the corridor looks cluttered…it probably is” Corridor clutter is not a PFI issue Carts Allowed:
Crash Carts Isolation Carts Chemo Carts Based on a HITF the following carts are not
allowed: Linen Hampers Latex Carts
Anything in the egress corridor more than 30 minutes is storage
Department of Engineering 2012 - 5
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CORRIDOR STORAGE
Dead end corridors may be used for storage Less than or equal to 50sqft space
Surge issue: based on policy patients may be treated in the egress corridor during surge conditions
Goal is continuous compliance for patient safetyNOT oscillating compliance
Department of Engineering 2012 - 6
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LS & EC RANKING IN TOP 10 IN 2011
2. 56% LS.02.01.20 EP 13 Corridor Clutter3. 52% LS.02.01.10 EP 9 & 5 Penetrations
& Rated Doors 4. 45% LS.02.01.30 EP 2 Hazardous
Areas5. 40% EC.02.03.05 All EP’s Fire Safety
Testing 10. 31% LS.02.01.35 Sprinkler System
Department of Engineering 2012 - 7
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LS.02.01.10 (52%)
Building and fire protection features are designed and maintained to minimize the effects of fire, smoke, and heat.EP 9 PenetrationsEPs 5 – 7 Door issuesEPs 1 & 2 Building Type issuesEP 8 Duct issues
Department of Engineering 2012 - 8
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LS & EC RANKING IN TOP 10 IN 2011
2. 56% LS.02.01.20 EP 13 Corridor Clutter3. 52% LS.02.01.10 EP 9 & 5 Penetrations
& Rated Doors 4. 45% LS.02.01.30 EP 2 Hazardous
Areas5. 40% EC.02.03.05 All EP’s Fire Safety
Testing 10. 31% LS.02.01.35 Sprinkler System
Department of Engineering 2012 - 9
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LS.02.01.30 (45%)
The hospital provides and maintains building features to protect individuals from the hazards of fire and smoke.EPs 16 – 23 Smoke Barriers & DoorsEP 2 Hazardous Areas
Department of Engineering 2012 - 10
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LS & EC RANKING IN TOP 10 IN 2011
2. 56% LS.02.01.20 EP 13 Corridor Clutter3. 52% LS.02.01.10 EP 9 & 5 Penetrations
& Rated Doors 4. 45% LS.02.01.30 EP 2 Hazardous
Areas5. 40% EC.02.03.05 All EP’s Fire Safety
Testing 10. 31% LS.02.01.35 Sprinkler System
Department of Engineering 2012 - 11
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EC.02.03.05 (40%)
The hospital maintains fire safety equipment and fire safety building features.Features of fire protection
NOTE: #1 for Critical Access Hospitals
Department of Engineering 2012 - 12
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LD.04.01.05 EP 4: WHAT TO DO WHEN THE DOCUMENTATION ISN’T THERE…
During survey specific documentation is reviewed If the documentation is not available write the observation
as non-compliant Also score LD.04.01.05 EP 4
If the documentation becomes available later in the survey to the survey team, the team can: Consider removing the previous finding if documentation
confirms the activity was completed as per the EP LD.04.01.05 EP 4 may also be removed during survey
If the survey team would prefer not to evaluate the documentation the organization can submit clarification
If the organization clarifies after survey: SIG Engineers will review and evaluate compliance LD.04.01.05 EP 4 remains
Department of Engineering 2012 - 13
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LS & EC RANKING IN TOP 10 IN 2011
2. 56% LS.02.01.20 EP 13 Corridor Clutter3. 52% LS.02.01.10 EP 9 & 5 Penetrations
& Rated Doors 4. 45% LS.02.01.30 EP 2 Hazardous
Areas5. 42% EC.02.03.05 All EP’s Fire Safety
Testing 10. 31% LS.02.01.35 Sprinkler System
Department of Engineering 2012 - 14
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LS.02.01.35 EP 6
There are 18” or more of open space maintained below the sprinkler deflector to the top of storage.
NOTE: Perimeter wall and stack shelving may NFPA 25-1998, 2-2.1.1
Department of Engineering 2012 - 15
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18” RULE
18”18”
OK OK OKWrong
Wall Wall
Ceiling
Perimeter Shelving Perimeter
Shelving
Department of Engineering 2012 - 16
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LIFE SAFETY CODE SURVEYOR
LSCS Background Facilities or Environment of Care based Prefer CHFM certification
All HAP and CAH will be surveyed for a minimum of 2 days by a LSCS Greater than 1.5 million sq ft will be surveyed
for a third day by the LSCS An additional day is added for every three
buildings that are classified as healthcareExample: for a HAP organization with 2 million
square feet of healthcare occupancy and 5 buildings classified as healthcare occupancy:
the number of LSCS days would be 4
Department of Engineering 2012 - 17
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LIFE SAFETY CODE SURVEYOR
Interfaces with survey team member(s) LSCS Survey Focus
Life Safety Chapter EC.02.05.03 EC.02.05.07 EC.02.05.09
May conduct the EC Session May conduct the EM Session
Other “Observations” May also survey
LD.04.01.05 EP 4 Accountability LD.04.04.01 EP 2 Hi-Priority LD.01.03.01 EP 5 Resources
Department of Engineering 2012 - 18
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WHAT TRIGGERS ITL(IMMEDIATE THREAT TO LIFE)
Significantly compromised fire alarm system
Significantly compromised sprinkler system Significantly compromised emergency
power supply system Significantly compromised medical gas
master panel Significantly compromised exits Other situations that place patients, staff or
visitors at extreme danger
Department of Engineering 2012 - 19
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WHAT TRIGGERS ITL(IMMEDIATE THREAT TO LIFE)
PDA01An Immediate Threat to Health or Safety exists for patients or the public within the hospital.
CONT01The Immediate Treat to Health or Safety has been successfully abated and verified through the direct observation or other determining method.
Department of Engineering 2012 - 20
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AFS 10 IS RELATED TO THE SOC AND PFIS
Failure to make sufficient progress on previously accepted PFIs (LS.01.01.01 EP 2)
Failure to develop ILSM policy and implement appropriate ILSMs (LS.01.02.01 EP 3)
Failure to manage previously accepted PFIs affects the Joint CommissionBoth organizations are aware of
deficiencies that have been managed using the PFI process
Department of Engineering 2012 - 21
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DEFICIENCY RESOLUTION Resolution to a deficiency:
Resolve it immediately Correct it within 45 days:
Management process that documents the deficiency and actions to resolve
ILSM must be considered Plan For Improvement located in the
Statement of Conditions™ Corrected within 6 months of the
Projected Completion Date ILSM must be considered
Department of Engineering 2012 - 22
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45 DAY CORRECTIVE ACTION Documented
Origination date Completion date Kept available for rolling 3 years Life Safety deficiencies Must not exceed 45 days If greater than 45 days create a Plan For
Improvement (PFI) If originally a work order, close out as complete
and generate the PFI Must be made available to the Joint Commission
During survey to confirm management of the deficiency
During CMS/Joint Commission validation process upon request
Department of Engineering 2012 - 23
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HOW MANY OPEN PFIS ARE TOO MANY?
The PFI process was created to allow organizations to self assess and create a Plan for Improvement
The self disclosure has never defined how many is too many
The ILSM process was created to allow both the organization and The Joint Commission to be aware of Life Safety Code deficiencies
Failure to make progress on previously accepted PFIs, including failure to implement ILSMs results in Conditional Accreditation
Department of Engineering 2012 - 24
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HOW MANY OPEN PFIS ARE TOO MANY?
Survey Process: There is no limit to the number of PFIs Evaluate both closed and currently open PFIs in
the View All screen Spot check during building tour both some
closed and open PFIs to evaluate how well the organization is managing the PFI process
Evaluate the scope of PFI entries Are there life safety deficiencies Are they greater than maintenance items
(i.e. screws missing from a door hinge)
Department of Engineering 2012 - 25
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STATEMENT OF CONDITIONS: PFI
PFIs should be related to the LS Chapter Corridor clutter is not a legitimate PFI
PFIs should provide specific information No blanket statements
“…penetrations on 3rd floor” Specific references to Life Safety Drawings is
acceptable 32 penetrations as identified on LS
Drawing 3rd Floor, Center Tower dated 3/3/2010
Projected Completion Date is for all listed items (i.e. “32 penetrations”)
Department of Engineering 2012 - 26
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TWO FORMS OF EQUIVALENCIES
Fire Safety Evaluation System (FSES) A process of calculating the features of life
safety and deducting any deficiencies, with the outcome determining if the building is equivalized based on the FSES
Traditional Equivalency A process of field verification identifying
alternative methods of fire safety that off-set the identified deficiency
Field verification from one of the following: Registered architect Fire Protection Engineer Local AHJ responsible for fire safety
Department of Engineering 2012 - 27
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HISTORY AUDIT TRAIL
The History Audit Trail is used by SIG Engineers when considering extensions or other activities related to an organization
Prior to surveying, the surveyor must preview the History Audit Trail to discover if equivalencies or other actions have occurred by SIG Engineers
When surveying, brief but accurate information entered in the File Room is important
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2012 LIFE SAFETY CODE
George Mills, Director
Department of Engineering
The Joint Commission
Department of Engineering 2012 - 29
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NFPA 101-2012
1. Means of Egress Enhanced Patient lift & transport equipment may be
stored in the Means of Egress, provided 5ft clear corridor width is maintained Fire plan addresses management of
storage Accommodates current “equipment in use”
Department of Engineering 2012 - 30
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NFPA 101-2012
2. Fixed seating permitted provided 6ft clear width < 50sqft with 10’ between
groupings Groupings must be on same
side of the egress corridor
Department of Engineering 2012 - 31
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NFPA 101-2012 CORRIDOR COOKING
4. Cooking Facilities One cooking area may be open to the egress
corridor per smoke compartment Any additional cooking areas must be in
protected room similar to hazardous areas Provisions:
No deep fat fryers Safety equipment to de-activate fuel supply Grease baffles installed No solid fuel (i.e. charcoal)
Department of Engineering 2012 - 32
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NFPA 101-2012 FIREPLACES
5. Fireplaces in smoke compartments with patient sleeping rooms
Section 18/19.5.2(2), (3) and (4) Allow the installation of direct vent
gas fireplaces In smoke compartments containing
patient sleeping rooms Installation of solid fuel burning
fireplaces in areas other than patient sleeping areas
Department of Engineering 2012 - 33
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NFPA 101-2012 DECORATIONS
6. Allow the use of Furnishings, Mattresses, and Decorations including Section 18/19.7.5
Allows the installation of combustible decorations on Walls Doors Ceilings
LSC Section 18/19.7.5.6
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GENERAL INTERPRETATIONS
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BUILDING MAINTENANCE PROGRAM (BMP)
The BMP is no longer available to offset findings during survey, but is considered “best practice”
All EPs related to the original ten BMP items are ‘C’ categories
Department of Engineering 2012 - 36
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GENERAL LIFE SAFETY INTERPRETATIONS
Alcohol Based Hand Rub (ABHR) placement:LS.02.01.29 EP 12 and NFPA 101
19.3.2.6 (6) states, The dispensers shall not be installed over or directly adjacent to an ignition source.
The Joint Commission published information in 2006 defining “adjacent to” as no closer than 6inches, center of the dispenser to center of the ignition source
Department of Engineering 2012 - 37
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GENERAL LIFE SAFETY INTERPRETATIONS
NFPA 101, 2012: 18/19.3.2.6. (8) Dispensers shall not be installed in the following locations:Above an ignition source for a horizontal
distance of 1 in (25 mm) to each side of the ignition source.
To the side of an ignition source within a 1 in. (25 mm) horizontal distance from the ignition source.
Beneath an ignition source within a 1 in. (25 mm) vertical distance from the ignition source.
Department of Engineering 2012 - 38
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FIRE & SMOKE DAMPER INSPECTIONS
Ensure inaccessible dampers truly are by random sampling
Confirm ILSM policy is implemented for any horizontal exits or egress enclosures that are compromised by inaccessible dampers
Evaluate adequacy of damper accessibility plan
Department of Engineering 2012 - 39
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EC.02.06.05 EP 1 Effective 1/1/2011 the Joint Commission will
recognize the Facilities Guidelines Institute (FGI) Guidelines for Design & Construction of Health Care Facilities
ASHRAE 170 has been attached to the Guidelines Ventilation Table 20 – 60 % RH requirement of relative humidity in
seven affected areas of the Surgical Environment, and one in Diagnostic & Treatment. NOTE CMS has not adopted this, but remains
at 35 – 60%RH The established 60% upper range however
should be maintained for issues such as mold growth.
Department of Engineering 2012 - 40
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RH% TREATMENT AREAS
Class A Operating/Procedure room Class B and C operating rooms Operating/surgical cystoscopic rooms Delivery room (Caesarean) Treatment rooms Trauma room (crisis or shock) Laser eye room Diagnostic & Treatment: Gastrointestinal
Endoscopy Procedure Room
Department of Engineering 2012 - 41
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CENTRAL STERILE LAYOUT Physically separated soiled and clean work rooms
Soiled Work Room: Work surface, sink, washer/sterilizer decontaminators Soiled room is not to have direct contact with the OR
Clean assembly /work room Hand washing station Sufficient workspace and equipment
Self-closing door or pass through is acceptable between soiled and clean work rooms
Storage provisions for humidity, temperature, and ventilation Location of storage may be within the clean assembly/
workroom in a permanently designated space
Guidelines for Design & Construction of Health Care Facilities FGI 2010 edition 3.7-5.1.2 - 3.7-5.1.2.3
Department of Engineering 2012 - 42
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ENDOSCOPY PROCESSING ROOM
May be one room, dedicated to endoscopy equipment processing Sized as per amount of equipment processed Work flow from soiled to clean
Clean should not be exposed to soiled• 3ft min clearance clean from soiled at all times • Droplet contamination is concern
Work surface and sink Hand washing station Sufficient workspace, utilities and equipment
Ventilation Negative air pressure to surrounding areas Minimum 10 ach (2 fresh, outside); direct exhaust NO requirements for temperature or humidity
Guidelines for Design & Construction of Health Care Facilities FGI 2010 edition 3.9-5.1.1 - 3.9-5.1.1.2
Department of Engineering 2012 - 43
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ENDOSCOPY PROCESSING ROOM Storage
May be a cabinet in the endoscopy processing room Cabinet must have doors Cabinet must be at least 3ft from potential
droplet contamination• Consider route from processor to the cabinet• Route should not cross through soiled
processing area Storage may be in a separate room
Inventory of Scopes Recommended practice is to include scopes in the
Medical Equipment Inventory
Guidelines for Design & Construction of Health Care Facilities FGI 2010 edition 3.9-5.1.1 - 3.9-5.1.1.2
Department of Engineering 2012 - 44
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SCORING
EC.02.05.01 EP 1: Improper system designInability of the mechanical system to
achieve required results EC.02.05.01 EP 4: Lack of written
inspection, testing & maintaining frequenciesContinuous monitoring by a building
automation system (BAS) is acceptable
Department of Engineering 2012 - 45
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SCORING
EC.02.05.01 EP 6: Ventilation system is unable to provide appropriate pressure relationships, air-exchange rates and filtration efficiencies Specific areas lack
negative or positive pressures in relationship to adjacent areas • i.e. Endoscopy Processing Room should
be negative to the egress corridor the correct number of air changes per hour Improper filtration
• MERV = minimum efficiency reporting value
Department of Engineering 2012 - 46
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SCORING Tissue test: only to be used as a pre-screening tool to
evaluate if further investigation needs to occur To perform the flutter test take a tissue and let it hang
just off the floor near the bottom edge of a door If the tissue indicates incorrect air flow, stabilize the
area by closing doors and windows, wait a few minutes and re-screen
If the organization presents a Testing & Balancing report the following questions should be asked
• when was the balancing done (seasonal issues) • are any specific requirements (such as keeping a
door closed) needed to achieve satisfactory results
If non-compliance is determined write a clear and specific finding
Department of Engineering 2012 - 47
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SCORING
EC.02.06.01 EP 13 Maintains ventilation, temperature and humidity
levels suitable for care, treatment and services provided Ventilation:
• i.e. doors held open by air pressure; odors Temperature:
• Hot / Cold calls Humidity
• Primary concern is for areas >60%RH− Mold growth is possible
Department of Engineering 2012 - 48
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SCORING
EC.02.05.05 EP’s 4 & 5 EP 4: Infection Control systems are not
maintained i.e. an isolation room that should be
negative is positive EP 5: non-life support utility system
components are not inspected, tested or maintained Improper number of air changes results in
offensive odors in geriatric unit
Department of Engineering 2012 - 49
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GENERAL LIFE SAFETY INTERPRETATIONS
Rated doors must have legible labels on the door and jambsJambs prior to 1966 may not have a rating label
Are ILSM in place where non-compliant door assemblies are found?
Department of Engineering 2012 - 50
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NON FLAMMABLE MEDICAL GAS VOLUME & STORAGE: SCORING
Score EC.02.03.01 EP 1 …fire risk12 ‘E’ cylinders (<300ft³) per smoke compartment
(22,500ft²) may be open to the egress corridor in a rack or appropriate holders
Between 300 and 3000ft³ must be stored in a room that is limited construction with doors that can be locked
“In use” verses “in storage” Properly secured to a gurney is considered “in use” Properly racked is “in storage” Empty are NOT considered part of the 12 in storage Empty and full must be stored (racked) separately
Department of Engineering 2012 - 51
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NON-FLAMMABLE GAS STORAGE: NFPA 99-2005
NFPA 99-2005 edition has additional language regarding O2 storage requirements, specifically:
Storage of nonflammable gases:9.4.1 > 3000 cubic feet9.4.2 300 – 3000 cubic feet 9.4.3 0 - 300 cubic feetOther:5.1.3.3.2 design and construction5.1.3.3.3 ventilation of locations for manifolds5.1.3.3.3.2 ventilation for motor driven equipment5.1.3.3.3.3 ventilation for outdoors
NOTE: CMS also recognizes 9.4.3 reference
Department of Engineering 2012 - 52
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NON-FLAMMABLE MEDICAL GAS UNSAFE CONDITIONS: SCORING
Score EC.02.06.01 …unsafe condition Unsecured cylinders
Laying on top a gurney mattress; leaning against the wall Free standing Comingling of full and empty cylinders
Transfilling liquid oxygen Transfer of any gases from one cylinder to another in patient
care areas of health care facilities is prohibited. Transfilling of liquid oxygen only in an area that is:
• mechanically ventilated• sprinklered• ceramic or concrete flooring• separated with at least 1 hour construction from any patient
care areas
Department of Engineering 2012 - 53
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TANK FARM
EC.02.05.09 EP 1 states the hospital tests, inspects and maintains critical components of the piped medical gas systems. Tank Farm is included in this EP The bulk storage tank(s) and associated systems are
critical components of the piped medical gas system Tanks above ground, not on roofs No electrical service above tanks 10’ Clear from vehicles & sidewalks 50’ from wood frame buildings
• At least 1’-0” from other buildings• At least 10’ form any opening in wall of adjacent
structures• Concrete pads at all spill points (3’ min)
Permanent signage: OXYGEN – NO SMOKING – NO OPEN FLAMES
Access controlled (i.e. locked)
Department of Engineering 2012 - 54
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NFPA 110: EMERGENCY & STANDBY POWER SYSTEMS
Automatic Transfer Switches (ATS) are self-acting devices that have normal electrical power entering and leaving the ATS The power continues on to distribution panels
When a ATS senses a disruption in power it sends a signal to the alternative power source seeking power This start circuit initiates the emergency generator
starter The ATS is also equipped with a test switch to
simulate the power disruption Recommended practice is to rotate which ATS
initiates the start circuit to the emergency generator
Department of Engineering 2012 - 55
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FIRE EXTINGUISHER: DATING
Month, day year and initials of inspector as per NFPA 10-1998 EC.02.03.05 EP 15
4-3.4 Inspection Recordkeeping.4-3.4.1 Personnel making inspections shall keep records of all
fire extinguishers inspected, including those found to require corrective action.
4-3.4.2 At least monthly, the date the inspection was performed and the initials of the person performing the inspection shall be recorded.
4-3.4.3 Records shall be kept on a tag or label attached to the fire extinguisher, on an inspection checklist maintained on file, or in an electronic system (e.g., bar coding) that provides a permanent record.
DO NOT COUNT DAYS, BUT ENSURE MONTHLY INSPECTION
Department of Engineering 2012 - 56
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GENERAL LIFE SAFETY INTERPRETATIONS
Perimeter shelving and sprinkler provision:Are perimeter wall shelving that
extends to the ceiling required to be fastened to the wall?
NO Shelving is not required for storage There is no correlation between
• Shelving• Clearance • The need to secure any shelving
Department of Engineering 2012 - 57
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GENERAL LIFE SAFETY INTERPRETATIONS
Firestop: Existing application is acceptable
whenIt was installed in a manner
consistent with original design specifications
It is in acceptable condition currently If the firestop is cracking, etc, then it is to be removed and repaired using current technologies
Department of Engineering 2012 - 58
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GENERAL LIFE SAFETY INTERPRETATIONS
Expanding foam used for insulation purposes is NOT an acceptable firestop in any fire or smoke barrier This product does have a UL label: for insulation properties
Easily ignited Toxic gases may occur when burned
NOTE: There are several acceptable fire stop products that expand when installed
Department of Engineering 2012 - 59
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GENERAL LIFE SAFETY INTERPRETATIONS
ElectricalUnlocked distribution panels in patient
care areas Based on policy Consider risk assessment Score EC.02.01.06 EP 1
Open junction boxes Score at EC.02.03.01 EP 1
• Risk: arcing resulting in fire or loss of service
Department of Engineering 2012 - 60
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GENERAL LIFE SAFETY INTERPRETATIONS
Staff Safety EC.02.02.01
EP 3: Precautions & PPE EP 4: Spill procedures EPs 5 – 10: minimizes risk
EC.04.01.01 EP 1: Monitoring & Reporting EPs 2 – 11: Specifics
Manifests: EP 11DOT training for those signing
Department of Engineering 2012 - 61
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OUTDOOR SAFETY
EC.02.01.01 EP 5The hospital maintains all grounds and
equipment Grounds includes
SidewalksParking lotsPark waysPicnic and patio areasPlay structures
Department of Engineering 2012 - 62
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OUTDOOR SAFETY
EC.02.01.01 EP 5 The hospital maintains all grounds and
equipment Equipment includes
Lawn maintenance equipment Snow removal equipment Maintenance equipment
Paving Road repair
Lighting
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GENERAL LIFE SAFETY INTERPRETATIONS
Suite ExitingLS.02.01.20 EP 21 (18/19.2.5.1)
Suites have access to an “exit access corridor”
LS.02.01.20 EP 17(18/19.2.5.3) Suites must have at least two exits
remote from one another A stairwell may be allowed to be
substituted as an “exit access corridor”
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SURGICAL SITE FIRES
>50 million hospital & ASC surgeriesEstimated 100 surgery fires per year
20 Serious 1 – 2 deaths
Fire sites:34% airway28% head/face38% other
74% occurred in oxygen enriched environment
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SURGICAL SITE FIRES
Source: 68% electrosurgical equipment 13% lasers
Recommendations: Fire drills & Staff Education Review alarm procedures Review rescue techniques Review shut off locations
Joint Commission response: Life Safety Code Surveyors gown and survey
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CMS CONDITIONS OF PARTICIPATION
42 CFR 482.41 Hospital must maintain adequate facilities for its
services 42 CFR 482.41(c)(2)
Facilities, supplies and equipment must be maintained to ensure an acceptable level of safety and quality.
The CMS Interpretive Guideline states “the hospital must monitor, test, calibrate and maintain equipment periodically in accordance with the manufacturer’s recommendation and Fed and State law.”
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BACKGROUND
2007 two hospitals cited by state agents based on 42 CFR 482.41(c)(2)
2009 hospital system implemented EQ56 CMS Regional Office stated that any risk or
evidence based program conflicted with 42 CFR 482.41(c)(2)
Other CMS Regional Offices accepted the Joint Commission processes
The hospital system asked CMS why they were inconsistent with 42 CFR 482.41(c)(2)
1/2010 CMS instructed Joint Commission to comply with 42 CFR 482.41(c)(2)
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CMS RESPONSE
I am happy to inform you that the Joint Commission’s approach of utilizing a preventive maintenance schedule has been approved. Thank you for your cooperation and collaboration.
CMS Deputy Director July 26, 2010
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S&C: 12-07-HOSPITAL PUBLISHED 12/11
Allows non-life support to adjust frequencies Restricts non-life support from adjusting
maintenance activities Restricts life support from frequencies and
maintenance activity adjustments Restricts equipment maintenance methods Estimated financial impact to comply:
FTE & other re-occurring costs ($4 – 10 Billion): Clinical Equipment: $2 – 5 Billion Facilities Equipment: $2 – 5 Billion
New capital investment ($2 – 6 Billion): Clinical Equipment: $1 – 3 Billion Facilities Equipment: $1 – 3 Billion
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4/9/2012 DISCUSSION WITH CMS
Ad Hoc team began to meet every Monday to create united response to CMS Provided council and resources
Joint Commission leadership is supportive of discussing the issues with CMS Joint Commission met with CMS to discuss the S&C:
12-07 April 9, 2012
Restriction related to test equipment lifted Saving estimated as $2 – 6 Billion to healthcare
Collaborative discussion with the conclusion research would be of benefit
Research should be specific to reliability of the Joint Commission process in EC.02.04.01
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DISCUSSION, CONTINUED
Research Issues:How many organizations use the Joint
Commission process? What guidance is used to modify
frequency and maintenance activities?Have there been any adverse outcomes
based on solely on this process If so, what?
Self diagnostic equipment: How many devices with this feature?
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ACTION ITEMS
AAMI & ASHE hosted Survey Monkeys 5/18 AAMI, ASHE & JCR hosted free webinars
to review Joint Commission standards and make the field aware of the importance of the surveyAAMI had 526 sitesASHE had 216 sites JCR had 794 sites
Survey responses:AAMI had 1526 ASHE had 790
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QUESTION 1
How many acute care beds is your organization licensed or authorized for?
Range Percentages Responses
<100 27.1 221
100 – 200 15.7 123
201 – 350 23.5 183
351 – 500 12.8 100
>500 20.9 162
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QUESTION 2
How many pieces of equipment are in your inventory?
Range Percentages Responses
<500 20.1 158
500 – 1,000 19.1 150
1,000 – 2,500 22.8 180
2,500 – 5,000 17.4 135
>5,000 20.6 162
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QUESTION 3
Do you use the Joint Commission process identified in EC.02.05.01 EPs 2 – 4 (i.e. have an inventory based on risk and other criteria)?
Percentages Responses
Yes 90.9 714
No 9.1 70
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QUESTION 4
Do you use the Joint Commission process identified in EC.02.05.01 EP 3 to establish maintenance activities (i.e. preventive maintenance procedure)?
Percentage Responses
Yes 92.7 728
No 7.3 57
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QUESTION 5
Do you use the Joint Commission process identified in EC.02.05.01 EP 4 to establish maintenance frequencies?
Percentage Responses
Yes 90.9 711
No 9.1 71
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QUESTION 6
Have you had any adverse outcomes (i.e. patient injuries or deaths) because you have modified the PM procedures or frequencies from the manufacturer’s recommendations, using the Joint Commission process identified in EC.02.05.01 EPs 2 – 4?
Percentage Responses
Yes 1.0 8
No 99.0 782
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COMMENTS TO QUESTION 6
None of the 12 that answered YES to question 6 had an adverse event4 are not accredited by the Joint Commission 3 had comments that did not pertain to the topic4 were pro-Joint Commission process comments1 reported a bed brake failed to engage and a patient fell when leaning on the bed
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NEXT STEPS
The Ad Hoc committee has continued to actively help navigate this process
AAMI, ASHE and Joint Commission will be meeting with CMS to review the research results
Goal is to resolve the conflict with sound evidence provided by the research
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QUESTIONS?
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DEPARTMENT OF ENGINEERING630 792 5900
George Mills, MBA, FASHE, CEM, CHFM, CHSP
Director
Michael Chisholm, CPE, CHFM
Engineer
Anne Guglielmo, CFPS, LEED, A.P., CHSP
Engineer
John Maurer, CHFM, CHSP
Engineer
Bruce Boggan, MBA, CHFM
Engineer
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THE JOINT COMMISSION DISCLAIMER
These slides are current as of 6/21/2012. The Joint Commission reserves the right to change the content of the information, as appropriate.
These slides are only meant to be cue points, which were expounded upon verbally by the original presenter and are not meant to be comprehensive statements of standards interpretation or represent all the content of the presentation. Thus, care should be exercised in interpreting Joint Commission requirements based solely on the content of these slides.
These slides are copyrighted and may not be further used, shared or distributed without permission of the original presenter or The Joint Commission.
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EYE WASH STATION FEDERAL REQUIREMENTS: OSHA
Score Eye Wash issues at EC.02.02.01 EP 5 Risk assess location / application based on OSHA
recommendation to reduce the risk of injury from contact with caustic and
corrosive materials in areas such as Power Plant Lab
Placed so that the eyewash is within 10 seconds or 55 feet from where the corrosive chemicals is used
Weekly flush until clear is required Annual inspection to ensure the system is fully functional Mixing valve recommended to achieve tepid
Risk assess potential exposure to determine if cold water only would be acceptable
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EYE WASH STATION: RECOMMENDED LOCATIONS (I.E. OSHA)
Medical services and first aid 1910.151(c) The eyes or body of any person may be exposed to injurious
corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.
Formaldehyde 1910.1048(i)(3) If there is any possibility that an employee's eyes may be
splashed with solutions containing 0.1 percent or greater formaldehyde, the employer shall provide acceptable eyewash facilities within the immediate work area for emergency use.
Battery charging and changing 1917.157(i) Facilities for flushing the eyes, body and work area with
water shall be provided wherever electrolyte is handled, except that this requirement does not apply when employees are only checking battery electrolyte levels or adding water.
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