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.

A Reader Speaks Out…

A reader has an objection to one of the answers I provided in yesterday’s blog concerning Power Strips…

Brad:

In the Sept. 2, 2016 article on Power Strips the following Q & A appeared.

Question: Can IT electronic health record equipment use an RPT within the patient care vicinity?

Answer: No. “Patient-care-related electrical equipment” is defined as electrical equipment that is intended to be used for diagnostic, therapeutic, or monitoring purposes in the patient care vicinity. IT electronic health record equipment does not meet this definition. Since it is non-patient care related electrical equipment, it is not permitted to be connected to a power strip in the patient care vicinity.

I had asked George Mills from The Joint Commission at the 2015 ASHE Convention if bedside IT electronic health record equipment met the definition of ““Patient-care-related electrical equipment”. He said it did. I agree with this since these units are being used to do things such as display x-rays and act as a gate keeping prior to a patient being given medication. I feel that this equipment is an integral and direct component in patient care. The ability to adjust the workstation permanently mounted next to the bed depends on the wires from the various components (monitor, CPU, barcode reader) being plugged into an RPT and the single wire from the RPT being routed through the workstation and out to a wall outlet.

My question is: Has TJC or CMS placed anything in writing that states that these devices do or do not meet the definition of patient care equipment?

 

A: No… TJC and CMS has not placed anything in writing that’ states these devices do or do not meet the definition of patient care equipment. But, you make a good point.

By your description, the traditional electronic health record equipment is now serving as “monitoring” equipment for patient care. You and George have changed the traditional use of the equipment from just storing and retrieving healthcare records, to a patient care related use. This meets the definition of patient care related electrical equipment and would then be permitted to be used in the patient care vicinity.

I suggest you perform a risk assessment and get that documented so a surveyor in the future will not cite you for that. Because, from the traditional use of the equipment, it does not appear to meet the definition of patient care related electrical equipment.

 

Q&A Information on Power Strips

A client of mine sent me the following questions regarding power strips. The answers were taken from the CMS S&C memo 14-46 regarding the use of power strips in accordance with NFPA 99-2012.

 

Question:

Within the patient care vicinity, can non-patient care related electrical equipment be plugged into a RPT instead of a SPRPT?

Answer:

No. Power strips providing power to non-patient care electrical equipment have to be a RPT (UL 1363)… and not a SPRPT (UL 1363A). However, power strips may not be used in a patient care vicinity to power non-patient care-related electrical equipment such as personal electronics. So, even if connected to a RPT (UL 1363), it would not be permitted within a patient care vicinity.

 

Question:

Can IT electronic health record equipment use an RPT within the patient care vicinity?

Answer:

No. “Patient-care-related electrical equipment” is defined as electrical equipment that is intended to be used for diagnostic, therapeutic, or monitoring purposes in the patient care vicinity. IT electronic health record equipment does not meet this definition. Since it is non-patient care related electrical equipment, it is not permitted to be connected to a power strip in the patient care vicinity.

 

Question:

Is it also correct to say patient equipment cannot share a SPRPT with non-patient care related electrical equipment?

Answer:

Yes.

 

Question:

Has Joint Commission or others defined the extent of “Patient Care Related Electrical Equipment” definition?

Answer:

Yes. According to section 3.3.137 of NFPA 99-2012, “patient-care-related electrical equipment” is defined as electrical equipment that is intended to be used for diagnostic, therapeutic, or monitoring purposes in the patient care vicinity

 

Question:

Is there a source to define and guide SPRPT/RPT electrical safety expectations for non-patient care related electrical equipment like a workstation on wheels or a computer that is in the patient are vicinity?

Answer:

Yes. See the CMS S&C memo 14-46. You can find it by searching “CMS S&C memo 14-46” on your internet search engine.

 

Question:

If the medical equipment is just being charged outside of the patient care vicinity and not being used on a patient, does it have to be connected to a SPRPT or can it be connected to a RPT?

Answer:

Power strips providing power to patient-care related electrical equipment must be SPRPT (UL 1363A). Patient care related equipment cannot be connected to a RPT (UL 1363) power strip.

More on the CMS S&C Memo Concerning Power Strips

12-120-878-TS[1]I received a question from a reader that I was unable to immediately answer. The question dealt with the use of power strips in a business occupancy: Did the categorical waiver to allow the use of power strips described in the  S&C memo 14-46-LSC, issued September 26, 2014 apply to business occupancies? The reader explained that the physician office building where he worked did not have hospital grade receptacles so it did not make sense to him that using UL listed power strips was necessary.

My immediate thought was the CMS issued categorical waiver would only apply to healthcare occupancies because NFPA 99 (2012 edition) does not apply to business occupancies. NFPA 99 is referenced by the healthcare occupancy chapter in section 18.5.1.3 of the 2012 LSC, but it is not referenced by the business occupancy chapters in the same LSC.

But, since I was not sure, I asked the question of a reliable source at CMS and they said the 2012 NFPA 99 Section 3-3.2.1.2(d)2 pertains to the minimum number of receptacles in all Patient Care Rooms.  Patient Care Rooms is defined as any room of a health care facility wherein patients are intended to be examined or treated.  In addition, the 2012 NFPA 99 Section 10.2.3.6 pertains performance criteria and testing for patient-care-related electrical appliances and equipment.  Patient-care-related electrical equipment is defined as electrical equipment that is intended to be used for diagnostic, therapeutic, or monitoring purposes in the patient care vicinity.

As these definitions do not make a differentiation based on occupancy,  it is CMS’s understanding that 2012 NFPA 99 power strip requirements would be applicable in all health care facilities in rooms where patients are intended to be examined or treated regardless of occupancy classification.

So, the answer to the question is the categorical waiver applies to all patient care rooms, regardless of the occupancy classification. This means if you want to use power strips in a physician exam room in a medical office building that is a business occupancy, you need to follow the guidelines in the S&C memo and only use UL listed power strips. However, for other areas of the business occupancy that are not considered patient care rooms, the NFPA 99 requirements concerning UL listed power strips do not apply. But it is wise to purchase only UL listed power strips since you cannot control where they may end up.

CMS Issues Categorical Waiver on Power Strips

12-120-878-TS[1]CMS issued a new S&C memo 14-46 in late September that made allowances for healthcare organizations to utilize power strips in patient care areas.

CMS has determined that the 2000 edition of the Life Safety Code contains provisions on the use of power strips in health care facilities that may result in unreasonable hardship for providers or suppliers. Further, CMS says an adequate alternative level of protection may be achieved by compliance with the 2012 edition of the Life Safety Code, which has extended allowances on the use of power strips in patient care areas.

CMS has determined that the 1999 edition of NFPA 99 Standard for Health Care Facilities, section 3-3.2.1.2 (d)(2) which requires a sufficient number of receptacles located so as to avoid the need for extension cords or multiple outlet adapters, is outmoded and unduly burdensome. NFPA 99 is referenced in part by the Life Safety Code. Power strips are also known as multiple outlet adapters, multiple-plug adapters, and relocatable power taps.

CMS says by contrast, the 2012 edition of NFPA 99 has extended allowances for use of power strips in ‘patient care rooms’, which replaces the term ‘patient care areas’.

The requirement in the 1999 edition of NFPA 99 for sufficient receptacles to be located in all patient care areas as to avoid the need for power strips has been removed in the 2012 edition. In place, the 2012 edition has increased the minimum number of receptacles in patient care rooms for new construction.

Effective immediately, CMS is permitting a categorical waiver to allow for the use of power strips in existing and new health care facility patient care areas/rooms, if the provider/supplier complies with all applicable 2012 NFPA 99 power strip requirements and with all other 1999 NFPA 99 and 2000 Life Safety Code electrical system and equipment provisions. NOTE: This applies to patient care rooms in all occupancies; not just healthcare occupancy. So does apply to patient care rooms in business occupancies as well as ambulatory care occupancies.

A patient care room is defined as any room in a health care facility wherein patients are intended to be examined or treated. This definition appears to include operating rooms and procedure rooms as well and is not limited to just healthcare occupancies.

The CMS S&C memo 14-46 describes basic requirements that health care facilities must comply with in order to use the new categorical waiver.

  • Patient bed locations in new health care facilities, or in existing facilities that undergo renovation or a change in occupancy, shall be provided with the minimum number of receptacles as required by section 6.3.2.2.6.2 of the 2012 NFPA 99.
  • Power strips may be used in a patient care vicinity to power rack-mounted, table-mounted, pedestal-mounted or cart-mounted patient care related electrical equipment assemblies, provided all of the conditions are met in section 10.2.3.6. They do not have to be an integral component of manufacturer tested equipment.
  • Power strips may not be used in a patient care vicinity to power non-patient care-related electrical equipment, such as personal electronics.
  • Power strips may be used outside of the patient care vicinity for both patient care-related equipment and non-patient care-related equipment.
  • Power strips providing power to patient care-related electrical equipment must be Special Purpose Relocatable Power Taps (SPRPT) listed as UL 1363A or UL 60601-1.
  • Power strips providing power to non-patient care-related electrical equipment must be Relocatable Power taps (RPT) listed as UL 1363.

The categorical waiver is available to all health care providers and suppliers and need only to document their decision to use the waiver, stating that they comply with all of the requirements to do so. This document must be provided to the surveyor team at the entrance conference. Organizations wishing to use the categorical waiver need not apply for them or wait until they are cited to use them.

To review the CMS S&C 14-46 memo, follow this link:  http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-14-46.pdf

Relocatable Power Taps (Power Strips)

12-120-878-TS[1]There has been a lot of discussion about power strips (or relcoatable power taps, as some authorities call them) lately, and most of it is not to our advantage. None of the discussion is actually news to us, it’s just a re-hash of existing positions.

During the recent NFPA Annual Conference in Las Vegas earlier this month, George Mills, the Director of Engineering for The Joint Commission said he approached the NFPA Healthcare Interpretation Task Force (HITF) back in 2007 and asked them to make a ruling on whether power strips are acceptable for use in patient care areas. George said after much discussion, the HITF did not come to a consensus, and therefore no interpretation was issued.

Since then, The Joint Commission surveyors have been allowing power strips in patient care areas, and some surveyors even required the devices to be UL listed for the application. Then, earlier this year, the leadership at The Joint Commission asked George what the accreditor’s official position was on the use of power strips, so he decided to contact the CMS home office in Baltimore to see what they allow.

George reported at the May AAMI Annual Conference in Philadelphia that CMS is taking the hard line of saying power strips (relocatable power taps) are not to be used in anesthesia areas and on medical equipment. This is based on NFPA 99 (1999 edition), section 7-5.1.2.5 which only allows relocatable power taps provided they are an integral part of the equipment assembly and permanently attached; and the sum of the ampacity of all appliances connected to the relocatable power tap shall not exceed 75% of the ampacity of the relocatable power tap. A regular program to verify the integrity of the above permanently attached relocatable power taps is required.

This piece of information was picked up by a lot of different healthcare news outlets, blogs and online notification services (including yours truly) and re-distributed to the point where CMS had to make an unofficial email announcement to their deemed accredited organizations (and presumably to their state agencies) that in fact no new issuance of a policy or an announcement was made concerning power strips, and they referred to NFPA 99 as their standard. Now ASHE has made an announcement acknowledging CMS’ position, and to say they are working to convince CMS to consider issuing a categorical waiver to allow the immediate use of NFPA 99 2012, which seems to have a more user friendly approach to power strips.

But, the bottom line is The Joint Commission (and the other accreditors) do not have any option but to follow this difficult interpretation of the standard as dictated by CMS. George Mills unofficially said they will enforce no power strips in patient care areas, and no power strips on medical equipment, unless it meets the requirement of NFPA 99 7-5.1.2.5 and it is integrated with the medical equipment, and this is all regardless of the UL listing. So power strips like UL 1363A which are listed for use in anesthetizing locations would not be acceptable to the accreditors.

For the record, the HITF wrestled with the issue of power strips once more this year in Las Vegas but again did not arrive at a conclusive interpretation. Chad Beebe representing ASHE said he wants to take this issue to CMS to attempt them to change their minds on the rigid interpretation.  I guess you need to stay tuned to see what transpires next…

Power Strips

Q: I read the June, 2012 article in HLSC about power strips in healthcare facilities and we have been hesitant to use power strips in patient care areas because the manufacturer’s instructions specifically spell out that they should not be used for life support equipment – and there is no way to know if the power strip will inadvertently be used for life support equipment. I would be interested in your response to this.

A: My response would be to follow the manufacturer’s recommendation. Your concern is valid: You purchased the power strips for a non-life support situation; then unbeknownst to you they could be moved to an area for use in a life support situation. When actual standards that regulate devices are not written, authorities having jurisdiction (AHJs) will resort to other sources; such as UL listings, manufacturer’s recommendations, and the risk associated with the use of the device when determining their appropriateness. It is always best to take a very conservative approach in determining the use of these (and any other medical) devices, not only for accreditation compliance purposes, but also for the safety of patients and staff.