Q: I currently serve as plant operations director at a nursing home in east Tennessee. State surveys questioned the locking arrangement on bathroom doors used both by the public and the patients in the facility. Looking in the 2012 Life Safety Code, I cannot find anything that prohibits locks on patient room doors. Will you please help with this issue?
A: If you are asking if the LSC prohibits locking of doors to bathrooms used by patients and/or visitors, then I would say the code is very silent on the subject. When the code does not prohibit something, then the AHJ can interpret this as meaning the code permits it.
But the issue of locking bathroom doors for patients is considered a patient safety issue, and is subject to surveyor discretion in accordance to the CMS Condition of Participation §483.70 Physical Environment for maintaining a safe environment. Conceivably, a patient could lock themselves in a bathroom and then become incapacitated and need assistance. If staff does not have an immediate method to gain access to the bathroom, then the patient is placed in an unsafe environment.
Some facilities resolve this issue by providing keys to each healthcare worker and expect them to carry them on their person at all times. This way, any healthcare worker can gain access to a patient bathroom in the event of an emergency. What code or standard did the state surveyors reference when they mentioned they had a problem with this arrangement? Get that code or standard reference from them and follow-up and see if you actually comply with that requirement.