Illuminated Pumpkin – CORRECTION

On October 23, 2018, I posted a picture of this illuminated pumpkin and wrote that the extension cord could not be used since Article 400.8 (3) of NFPA 70-2011 says flexible cords could not be used as a substitute for fixed wiring. But just recently, a reader asked why this illuminated pumpkin would not qualify for Article 590.3(B) that permits extension cords on holiday decorations for up to 90-days.

After reviewing NFPA 70-2011, I discovered I was incorrect in my original posting and thanked the reader for bringing this to my attention. I then made changes to the original posting to ensure the correct code interpretation was stated.

To be sure, NFPA 70-2011, Article 590.3(B), says extension cords are permitted to be used for holiday decorations up to 90-days. But Article 590.2(A) does say all other requirements of the code would have to be met. implying the extension cord would have to be listed by a national listing agency (i.e. UL). Also, Article 590.2(B) says temporary wiring is acceptable if it is approved based on the conditions of use. So, you would not be able to abuse the concept of an extension cord used on holiday decorations.

This also means that individual organizations could have policies specific to their staff that limit or prohibit the use of extension cords on holiday decorations beyond what NFPA 70-2011 provides.

I apologize for this error, and appreciate the reader for bringing this to my attention.

Extension Cords

Q: Under CMS, is it possible to use a UL listed power cord (extension cord), permanently attached to the equipment assembly providing it meets the ampacity requirements? If yes, what UL listing? UL 1363 A and UL 60601-1 are only power strips and I’m looking for a single outlet configuration that meets the UL requirements.

A: No…. According to NFPA 70-2011, Article 400.8, flexible cords cannot be used as a substitute for fixed wiring.

Strange Observations – Part 47

Continuing in a series of strange things that I have seen while consulting at hospitals…

Clearance to all electrical equipment (i.e. panels and disconnect switches) must be maintained for 36 inches in front of the panels from the floor to a point 6-feet 6-inches above the panels, or to the top of the panels whichever is higher.

That means the table and shelving unit need to be removed.

Strange Observations – Part 37

Continuing in a series of strange things that I have seen while consulting at hospitals…

See anything unsafe about this electrical panel…?

Here is another example that equipment rooms are really not all that safe.

The inner safety panel is missing from this electrical circuit breaker panel, thereby allowing access to the 480 volt buss bars.

Take a close look at your mechanical rooms, and do monthly inspections in them.

Strange Observations – Part 33

Continuing in a series of strange things that I have seen while consulting at hospitals…

Equipment rooms can be a major source of findings for surveyors.

Mostly because equipment rooms are often out-of-sight / out-of-mind. And because often times no-one is assigned to maintain the equipment rooms in safe condition.

Here we have a trash cart and a water machine obstructing access to electrical panels and a fire extinguisher.

Receptacle Testing

Q: Is there a code in the 2012 LSC about testing electrical receptacles around hospital beds?

A: Well… actually, that would be in the NFPA 99-2012 code/standard, and the answer is yes, all receptacles in patient care rooms must be tested. But the frequency of that test is different, depending on whether the receptacle is a hospital-grade receptacle or not.

Section 6.3.4.1.1 says hospital-grade receptacles must be tested after initial installation, replacement, or servicing of the device.

Then section 6.3.4.1.3 says receptacles not listed as hospital-grade, at patient bed locations and in locations where deep sedation or general anesthesia is administered, must be tested at intervals not exceeding 12 months.

But section 6.3.4.1.2 does say additional testing of receptacles (including hospital-grade receptacles) in patient care rooms shall be performed at intervals defined by documented performance data. This means you do have to test hospital-grade receptacles at a frequency determined by the healthcare organization based on information such as historical data, risk assessments, or manufacturer’s recommendation.

So, if you do install hospital-grade receptacles in the above locations, then you do have to test them after the initial installation, but at intervals that you get to determine.

Non-Patient Care Electrical Equipment

Q: What required inspections are needed for non-patient care electrical equipment and at what intervals should they be completed in. I cannot find anything definitive in NFPA 99 – 2012.

A: CMS will expect that you conduct the maintenance activities (i.e. PM’s) as recommended by the manufacturer, for all electrical equipment regardless if it is considered patient care or non-patient care equipment. In addition, this electrical equipment must be on the facility’s inventory of equipment.

This is based on CFR §482.41(c)(2) which is also known as A-0724 in the State Operations Manual (SOM) Appendix A. This document is available at no charge by searching “CMS SOM Hospitals”. Since it is a CMS standard, then all of the accreditation organizations and state agencies must have standards that are equal to that.

So, the answer to your question is: Whatever the manufacturer recommends, you must comply. And this is based on a CMS requirement, not an NFPA 99 requirement.

CMS does offer an Alternative Equipment Management (AEM) program that would allow you to conduct PM activities that differ from the manufacturer’s recommendations, but there are a lot of challenges to this AEM program and it is not for everyone. You can read all about it in CFR §482.41(c)(2).

Receptacle Testing

Q: What are the requirements for receptacle testing for hospital grade receptacles for existing and new health care facility?

A: Section 6.3.4.1.3 of NFPA 99-2012 addresses this issue by saying receptacles not listed as hospital-grade, at patient bed locations and in locations where deep sedation or general anesthesia is administered, must be tested at intervals not exceeding 12 months.

However, as mentioned in yesterday’s posting, section 6.3.4.1.2 of NFPA 99-2012, does state additional testing of hospital-grade receptacles in patient rooms shall be performed at intervals defined by document performance data.

Whether the building is considered new occupancy or existing occupancy, these requirement apply to all applicable locations in all healthcare facilities, and is not limited to just hospitals.

Hospital-Grade Receptacle Testing

Q: All of our receptacles in patient care rooms are hospital grade and therefore do not have to be tested annually, correct? What I don’t understand is section 6.3.4.1.2 of NFPA 99-2012, which states additional testing of hospital-grade receptacles in patient rooms shall be performed at intervals defined by document performance data. What is document performance data? How do I determine my testing intervals by document performance data?

A: You are correct: Hospital-grade receptacles are not required to be tested annually, but they are required to be tested at intervals determined by the healthcare facility. This is what the NFPA 99-2012 Handbook says about maintenance and testing of electrical receptacles under section 6.3.4.1 of NFPA 99-2012:

NFPA 99 prescribes no time between test intervals for hospital-grade receptacles. Hospital facility managers are permitted to determine appropriate test intervals for hospital-grade receptacles based on ‘documented performance data’. However, this paragraph requires that all non-hospital-grade receptacles within patient bed locations and anesthetizing locations must be tested at least every 12-months. This immediately raises the following question” “What is documented performance data?” There are two possible kinds of data that could meet this requirement. First, the manufacturer could provide data of this sort. Second, experiential data from other hospitals that have used similar devices and documented their failure rates could provide the kind of indication needed for appropriate testing intervals.

So, section 6.3.4.1.2 of NFPA 99-2012 does say additional testing of hospital-grade receptacles in patient care rooms shall be performed at intervals defined by the hospital using information that provides evidence that supports the testing interval decision. This information may come from the manufacturer, or it may come from your own experiences in testing these receptacles. According to NFPA 99-2012, you do not have to test hospital-grade receptacles annually that are located in patient rooms and anesthetizing locations, but you do have to determine what the testing frequency of these receptacles will be based ‘documented performance data’.

The testing requirements that you will need to do is found in NFPA 99-2012, section 6.3.3.2, and is summarized here:

  • The physical integrity of each receptacle shall be confirmed by visual inspection
  • The continuity of the grounding circuit in each electrical receptacle shall be verified
  • The correct polarity of the hot and neutral connections in each electrical receptacle shall be confirmed
  • The retention force of the grounding blade of each electrical receptacle (except locking-type receptacles) shall be not less that 4 oz (115 g).

Electrical Room Storage

Q: Are ladders allowed to be stored in electrical closets as long as the egress path is maintained and the 3ft clearance is applied? We had an inspector site 1910.303(g)(1)(ii) “Working space required by this standard may not be used for storage.” I referenced NFPA 70-2011 section 110.26 regarding the clearance which permits ladder storage but the surveyor ignored it. All our rooms are sprinklered and 1-hour fire rated.

A: The most restrictive requirement applies… You are correct that NFPA would permit storage of ladders in the electrical closet provided clearance to all electrical equipment is maintained. But this particular surveyor knew the OSHA requirements, and section 1910.303(g)(1)(ii) does prohibit storage in the electrical room.

It’s frustrating when you work hard to be in compliance with all NFPA codes and standards just to find out you are out of compliance with OSHA. If this was a CMS state agency survey or an accreditation survey, then I would say this finding is legitimate because 4.6.1.2 of the 2012 LSC says any requirements that are essential for the safety of the building occupants and that are not specifically provided for in this LSC, shall be determined by the AHJ. The surveyor, who is the AHJ, apparently did determined that the OSHA standard 1910.303(g)(1)(ii) is essential for your safety, and therefore it applies.

I guess you will have to deal with it and find a new home for ladders. Also, better post signs inside your electrical room advising everyone to not store anything in the room.

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NOTE: Since this article was posted, I have received numerous comments from people much smarter than I on OSHA requirements, stating they believe the surveyor was incorrect in his citation. According to the readers, OSHA says if the ladder is not in the working space then they think that it should be permitted.

Please use your own best judgement when considering any changes to storage in electrical rooms.