Oct 10 2017

Power Strips

Category: CMS,Power Strips,Questions and AnswersBKeyes @ 12:00 am
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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.


Aug 02 2017

Power Taps Connected to Carts

Category: Power Strips,Questions and AnswersBKeyes @ 12:00 am
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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.


Sep 03 2016

A Reader Speaks Out…

Category: Power Strips,Questions and AnswersBKeyes @ 12:00 am
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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.

 


Sep 02 2016

Q&A Information on Power Strips

Category: Power Strips,Questions and AnswersBKeyes @ 12:00 am
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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.


May 12 2014

Power Strips

Category: Power Strips,Questions and AnswersBKeyes @ 5:00 am
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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.