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2014 Twin state seminar. July 18, 2014. 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.
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2014 Twin state seminar July 18, 2014 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 construction • How 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:
S&C 13-58 • Issued August 30th, 2013 • Covers several “categorical waivers”
Medical Gas Master Alarms • Allows substitution of a centralized computer system for (one) Category 1 medical gas master alarm.
Openings in Exit Enclosures • Permits existing openings in exit enclosures to mechanical equipment spaces if they are protected by fire-rated door assemblies.
Emergency Generators and Standby Power Systems • Reduces the annual diesel-powered generator exercising requirement from two (2) continuous hours to one hour and 30 minutes.
Doors • 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.
Suites • Allows: • Suite to suite egress • Allows one of the two required exits to enter an exit stair • Increase the sleeping room suite size up to 10,000 sq. ft.
Extinguishing Requirements • Allows: • Reduction in the testing frequencies for sprinkler system vane-type and pressure switch type waterflow alarm devices to semiannual, • Electric motor-driven pump assemblies to monthly.
Clean Waste & Patient Record Recycling Containers • 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
S&C 12-21 • Corridor Width • New “Effective” Corridor width • Fixed furniture allowed • Rolling carts, equipment and movement aids allowed Bench c.c. 8’-0” 5’-0”
Decorations • 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)
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 waiver • Document 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
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: • Performance • Maintenance, Testing and Inspection • Safe 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 sedation • General anesthesia • Minimal sedation • Moderate 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.
Electrical Systems(Chapter 6) • “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) • Increases minimum number of receptacles • General Care – From 4 to 8 • Critical Care – From 6 to 14 • Operating Rooms – New requirement of 36
Electrical Systems(Chapter 6) • 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) • Monthly Generator Testing - 10 second transfer not required • (Annual Confirmation)
Electrical Systems(Chapter 6) • 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) • 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 Safety • Critical • Equipment