Strange Observations – Part 16

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

Another storage room with a bunch of empty boxes obstructing access to the electrical panel.

Clearance needs to be maintained for 36 inches in front of the panel.

GFCI Receptacle Testing

Do you ever have the feeling for every step forward, you take two steps backward? Regulatory compliance in the healthcare industry is getting tougher and tougher each year with new interpretations by the authorities. Just when you learn about the latest new requirement, and make the necessary adjustments so you are in compliance, along comes a new interpretation that throws a wrench into your process and you have to re-boot again.

Take the example that a reader sent me last December: Their hospital was having an inspection by their state agency representing CMS and the surveyor for the state said they were going to cite the hospital for not testing their GFCI receptacles on a monthly basis. She wrote me an email and asked me if testing the GFCI receptacles on a monthly basis was a requirement. I looked it up in the NFPA 99-2012 code and could not find any requirement to test GFCI receptacles. I did find a requirement in NFPA 70-2011, Article 517.17 (D) that does require the GFCI receptacles to be tested upon the initial installation, but nothing was mentioned about monthly testing requirements.

The state agency eventually submitted their report and the hospital was cited under K-914 for not providing any documentation that monthly testing was conducted on the Ground Fault Circuit Interrupter (GFCI) receptacles at various locations in the hospital, in accordance with the manufacturer’s instructions on testing.

Even though NFPA does not require monthly testing of the GFCI receptacles, the manufacturer does recommend it, and the CMS surveyor cited the hospital for not following the manufacturer’s recommendations. The reader sent me a copy of the survey report and asked if this made sense to me. I replied that yes, it is a legitimate finding, because the hospital was not following the manufacturer’s recommendation for testing the GCFI receptacles. CMS Condition of Participation CFR §482.41 (c)(2) Interpretive Guidelines is clear that hospitals must follow the manufacturer’s recommendations for maintenance activities, or they must comply with the Alternate Equipment Management (AEM) program. But, in a larger picture, it does not make sense to me to start citing healthcare organizations for a little-known requirement without first providing some warning.

Why can’t CMS make an announcement and say they will start holding certified healthcare organizations accountable for monthly testing of their GFCI receptacles and provide a year’s moratorium until they begin enforcement? When I was a surveyor for Joint Commission, the accreditor used to do that. They would make an announcement that they would begin holding hospitals accountable for a new requirement, but would give the healthcare organization at least 6-months, and sometimes a year, to become compliant before that issue was enforced.

So… for now, the lesson we all need to learn from this, is to begin a monthly testing program of all your GFCI receptacles. Do your own survey of your facility and inventory the location where each GFCI receptacle is at. Purchase one of the GFCI testing devices (~$10) in the picture and have your technicians do the test on a monthly basis. Document each monthly test with the date, location, a “Pass” or “Fail” decision of the test, and a signature by the technician. There is a report template on my “Tools” webpage that you can down-load and use for free.

But that takes care of the this ‘flavor-of-the-month’. What will be the next surprise by the CMS surveyors that will catch most healthcare organizations off-guard? The way CMS is putting pressure on their state agency surveyors to find deficiencies that the accreditation organizations over-look, it makes the survey process more of an enforcement interrogation rather than a collaborative and educational event.

Strange Observations – Part 10

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

Access to this electrical panel was obstructed. Staff that was with me did not understand that 36 inches clearance needed to be maintained.

What was the person thinking when they built the shelves?

Coffee Pots

Q: What’s the standard to test small electrical appliances such as plastic coffee pots, etc. with no ground and the patients do not handle in a health care environment?

A: You may classify that as ‘consumer equipment’, and it would not have to be included in the plant equipment inventory. However, the expectation is the hospital does an initial equipment inspection that checks for continuity to ground… even if it is all plastic. The check should be recorded, and a sticker on the equipment is sufficient.

Strange Observations – Part 9

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

The odd thing about this situation is the receptacle has been changed out since the fire, but they didn’t do anything to repair the wall or to paint over the burn marks.

And this was in a very busy storage room with lots of boxes… the staff that was with me had no idea that this was there.

Cable Attached to the Outside of Conduit

Q: I am being told by a building engineer that low voltage cable cannot be attached (i.e. wire-tied) to existing conduits in the hospital. In ten-plus years in this business I have never heard of this being a problem. Is there any way to confirm this is a code violation?

A: Yes, I’m afraid this is true. Section 19.5.1.1 (section 18.5.1.1 for new healthcare occupancies) of the 2012 Life Safety Code requires compliance with section 9.1 which in turn requires compliance with NFPA 70 National Electrical Code, 2011 edition. Article 300.11 (B) of NFPA 70 does not permit anything to be attached to conduit, with one exception: Class 2 control cable may be attached to the conduit if it serves the circuit in the conduit.

Apparently, the concern that NFPA has is heat from the electrical conductors inside the conduit may not dissipate adequately if there are additional cables and wires tied to the outside of the conduit. While it is highly unlikely that a single low voltage cable that is wire-tied to a conduit would cause a problem, I guess it is logical that many wires and cables could be a problem. The question is where do you draw the line? I guess NFPA draws the line at one (1). So, I’m sorry to say, you will have to remove all the wires and cables from conduits in order to be compliant with the LSC. And by the way, do not attach those wires to your sprinkler pipes, either. That will cause a whole bunch of problems that you don’t need.

Power Strips

Q: There is so much discussion on the proper use of power strips that it can cause confusion amongst even the seasoned facility managers. There is absolutely no guarantee that the different power strips will remain in their ‘designated areas’. The OR is much easier to control, but as technology quickly progresses, the space between patient care vicinities and non-patient care vicinities quickly losing the defined lines. What’s your thoughts on the power strip issue?

A: I do see your point that power strips may be difficult to control as they may move around the hospital, in and out of patient care vicinities. And I respect your comment that there is confusion on the proper use of power strips. But I find CMS’ explanation regarding power strips under their K-Tag 920 to be refreshingly simple:

  • Power strips in a patient care vicinity are only used on movable patient-care related electrical equipment and are permanently attached to the equipment, and are UL 1363A or UL 60601-1.
  • Power strips in a patient care vicinity may not be used for non-patient-care related electrical equipment, such as personal electronics, except in long-term care resident rooms that do not use patient-care related electrical equipment.
  • Power strips for patient-care related electrical equipment must meet UL 1363A or UL 60601-1.
  • Power strips for non-patient-care related electrical equipment in the patient care rooms, but outside of the patient care vicinity, must meet UL 1363.
  • In non-patient care rooms, power strips meet other UL standards.

Section 3.3.139 defines “patient care vicinity” as a space, within a location intended for the examination and treatment of patients, extending 6 feet beyond the normal location of the bed, chair, table, treadmill, or other device that supports the patient during examination and treatment and extending vertically to 7-foot 6-inches above the floor.

It appears K-Tag 920 is permitting qualified personnel to permanently attach UL 1363A or UL 60601-1 power strips to movable patient-care related electrical equipment, provided it meets section 10.2.3.6 of NFPA 99-2012, which is:

  • The power strip is permanently attached to the equipment assembly;
  • The sum of the ampacity of all appliances connected to the outlets does not exceed 75% of the ampacity of the flexible cord supplying the outlets;
  • The ampacity of the flexible cord is in accordance with NFPA 70-2011, National Electrical Code.
  • The electrical and mechanical integrity of the assembly is regularly verified and documented.

This section does not explain what makes one “qualified”, so that determination should be left to the AHJ and the healthcare facility. While NFPA 99-2012 does not specify how frequent “regularly verified” means, the general consensus is annually, based on annual receptacle inspection requirements in Chapter 6.

You will note that section 10.2.3.6. (5) was deleted per Tentative Interim Amendment (TIA) 12-5.

K-Tag 920 is also clear that outside of a non-patient care room (i.e. OR, PACU, procedure room, patient sleeping room, etc.) CMS no longer regulates which UL power strip to use on non-patient-care related electrical equipment, other than it must be UL listed. That means a power strip used at a nurse station on office equipment, or in an office environment does not have to be UL 1363, UL 1363A, or UL 60601-1; it just has to be UL listed.

Power Taps Connected to Carts

Q: As always I enjoy reading your articles and appreciate your opinions. My question this time focuses on special relocatable power taps and is centered around the AIV PowerMate special purpose relocatable power taps (Product No. 1020026). This product is listed as UL 1363 A and is attached to an I.V. pole by way of a thumb-screw. Our operating room leadership would prefer this product, but reading the UL 1363A standard it states that the UL 1363A SRPT must be permanently attached. The word ‘permanently’ is causing the controversy. One part contends that this power tap IS permanently mounted by means of the thumb screw, while the other party takes the stance that the thumb-screw does not constitute a permanently mounted device as no tool is needed to connect or disconnect the power tap. What is your position?

A: I looked up the section in NFPA 99 that addresses this requirement (see NFPA 99-2012, 10.2.3.6) and there is no guidance on what constitutes a “permanently attached” power tap. I looked up the official NFPA 99 Handbook andt they said this under 10.2.3.6:

“Cart mounting of equipment has now been added to the types of examples listed for movable equipment assemblies. It has become a common practice to organize and mount equipment that is used in a variety of treatment areas, including operating rooms and special procedure rooms. All the testing conditions in 10.3.6 still apply, and the outlets must be permanently attached to the cart.”

 It is important to note two things regarding the commentary in the handbook:

  1. They re-iterated that the power tap must be permanently attached to the cart; and
  2. They did not offer an explanation what “permanently attached” means.

So, my take from these passages are NFPA 99 meant the power tap is attached to the cart in such a way it cannot be easily removed. So my way of thinking would agree with the contending party that the thumb screw does not constitute ‘permanently attached’.

But it doesn’t matter what I think… it only matters what the AHJ believes ‘permanently attached’ means. I was at a conference where I heard a representative from Joint Commission saying a power tap that is screwed to the cart constitutes ‘permanently attached’. But that’s just Joint Commission… what about the other AHJs you have inspecting your facility, such as the state agency on behalf of CMS? There is a possibility they will not agree with the Joint Commission’s interpretation.

My suggestion is to take the more conservation approach and since it does not require a tool to remove, it does not qualify as being permanently attached.

Electrical Safety Program

Q: I work in a psychiatric hospital. One of the therapies used here involves our clients doing their own personal laundry, so we have multiple laundry rooms off the units with residential grade laundry equipment. Our staff supervises the use of the equipment, but the clients operate the appliances themselves. When I arrived here, there was no electrical safety program in place. Is a program required, and how extensive?

A: Yes… every hospital must have a program for electrical safety, but the codes and standards are not real specific on the matter. If you are Joint Commission accredited, you are required by EC.01.01.01, EP 8 to have a written Utility Management program, and EC.02.05.01 requires the hospital to manage the risks associated with the utility systems. Electrical safety is considered part of the Utility Management plan and needs to be addressed in the written plan. Also, EC.02.06.01 requires the hospital to establish and maintain a safe, functional environment. If a surveyor were to observe any unsafe activity involving electrical safety, he/she could cite a finding under any of these standards.

The accreditation organizations expect hospitals to comply with other regulatory agencies, such as OSHA, state regulations and local ordinances. OSHA expects compliance with NFPA 70E on electrical safety which may involve all of your maintenance staff. In addition, section 9.1.2 of the 2012 Life Safety Code requires compliance with NFPA 70 for all issues requiring electrical wiring and equipment. So, there are multiple regulations and standards that require healthcare organizations to have a safe electrical environment, and the accreditation organization requires that to be included in the written form of the Utility Management plan. How specific you want to make your electrical safety program is up to you and the regulations enforced by the other authorities.

Restricted Access to Electrical Closets

Q: My questions are in relation to access control into electrical closets and life safety equipment closets. We have several electrical closets “locked down” by our IT department because they have installed network switches in these closets. One closet in particular also has an ATS switch and our fire alarm panel for that building. This closet is locked down to those who have “card access”. There are several closets that have life safety equipment inside that are also locked down with only card access. My questions are:

  1. Are there any compliance codes to refer to in accordance with life safety that states directly to our issue?
  2. Are there compliances that state “qualified persons” for access to electrical closets?
  3. Access to these electrical closets is limited. What codes or compliance regulation could this be violating?

A: From a Life Safety Code perspective the only compliance regulation that may apply concerns doors locked in the path of egress, which is section 19.2.2.2.4 of the 2012 Life Safety Code. It is permissible to lock the door going into the closet, but once you’re in the closet you cannot lock the door getting out of the closet. There are exceptions, and for closet it is rare to see any of the exceptions used under 19.2.2.2.4. Otherwise, I am not aware of any Life Safety Code issues that would prevent the locking of doors. In fact, HIPAA regulations would require the locking of closets that contain access to health information, so that is why the IT people want the doors to the intermediate distribution frame servers locked.

There are no regulations in the NFPA standards that state ‘qualified persons’ only for access to electrical closets

In an emergency, authorized individuals need to have access to electrical circuit breaker panels, disconnect controls, and the fire alarm panel. As long as the IT people allow unlimited access to certain Engineering-type staff (i.e. maintenance people) to the electrical equipment in these closets, I don’t see any problems.