Feb 19 2015

Electrical Panels

Category: BlogBKeyes @ 6:00 am
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imagesCATTF4OXThere are quite of few issues concerning electrical panels that need to be addressed during a survey. Hospitals frequently take electrical panels for granted and overlook some of the more obvious requirements. Surveyors are better educated and prepared to evaluate your electrical panels during the survey.

Access to electrical panels must not be obstructed. There must be at least 36 inches clearance in front of the electrical panels and at least 30 inches clearance to one side of the electrical panel. The width of the electrical panel is included in the 30 inch side clearance.

While there are no direct standards that say the electrical panels must be locked, the risk of unauthorized access by unscrupulous individuals who could turn off circuit breakers controlling vital functions is a risk that must be addressed. In other words; access to the electrical panels should be secure, unless the healthcare organization has conducted a risk assessment that addresses the risk of unauthorized access. An example where a risk assessment may indicate an unlocked electrical panel is acceptable is where the circuit breakers in the panel do not serve a vital function of safety.

Circuit breakers are required to be labeled as to the circuits that they serve, or are required to be labeled as “Spares”. In older healthcare facilities this may be a problem since renovations may change what is served by the circuits and the breaker schedule may not be up to date. A breaker turned “Off” because it is a spare still needs to be labeled as such.

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Oct 09 2014

Tamper Resistant Electrical Receptacles

Category: BlogBKeyes @ 6:00 am
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images[5]Every surveyor has his/her own specialty that they like to look for during a survey. I know of one surveyor that writes up every hospital he surveys if the fire alarm panel is not marked with the electrical panel number and circuit that feeds the power to the fire alarm system. It’s a requirement, but he’s the only surveyor that I know who is writing it.

Another surveyor that I know is very astute on construction type to the point where he wrote up a hospital for having combustible siding on the exterior of the building. The hospital was 20 years old and the plywood siding was original. They were upset because for two decades the siding was never an issue, then all of a sudden ‘Boom’; it’s a problem. The hospital contacted the architect who originally designed the hospital, and he wrote a thundering letter of protest. That one I checked with NFPA and it turns out the surveyor was correct. The hospital will have to remove the combustible siding or submit an equivalency or a waiver request.

When I surveyed for The Joint Commission, I remember paying special attention to how fire dampers were installed at the hospitals I surveyed. I did this because the hospital where I worked got cited for improperly installed fire dampers by the state agency conducting a validation survey on behalf of CMS. I learned the hard way on the proper method of installing fire dampers, and used that newly gained knowledge when I surveyed.

Which leads me to the issue concerning tamper resistant electrical outlets. I don’t think you will see any specific standard in a Joint Commission, HFAP or DNV, manual (or in a CMS CoP for that matter) on tamper resistant electrical outlets, but this issue is being observed on more and more survey reports. Apparently, some surveyors have a strong background in the National Electric Code (NFPA 70) and uses that knowledge during surveys.

If you are not already doing so, please be checking the electrical receptacles in pediatric areas to be sure they are the tamper resistant type. Section 19.5.1 of the 2000 Life Safety Code requires compliance with section 9.1, and section 9.1.2 requires compliance with NFPA 70 National Electric Code (1999 edition). Article 517-18(c) of NFPA 70 says the receptacles rated for 15 or 20 amps, 125 volts, intended to supply patient care areas of pediatric wards, rooms, or areas in healthcare facilities, shall be listed tamper resistant or shall employ a listed tamper resistant cover.

 The areas where tamper resistant receptacles are required are areas where children are likely to found; which include areas outside of a pediatric unit such as the cafeteria, main lobby, waiting rooms, and play areas. The tamper resistant receptacles would not be required in adult patient rooms, corridors, physician consultation rooms, etc., as these areas, even if children are present, would have supervising adults present.

It is not wrong, or unethical for a surveyor to cite an organization on an issue just because he/she has special knowledge about that issue. After all; the hospital is required to comply with that issue, right? What’s frustrating is there usually is no warning that some surveyors are looking for a particular issue and it surprises facility managers when it happens. No one likes those kinds of surprises.

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Jun 30 2014

Relocatable Power Taps (Power Strips)

Category: BlogBKeyes @ 6:30 am
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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…

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Mar 28 2013

Locks on Electrical Panels

Category: BlogBKeyes @ 6:00 am
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imagesCATTF4OXI am often asked if locks on electrical panels are required, or where in the world does it say in the Life Safety Code that we need to lock our electrical panels? Well, the quick and short answer, is: As far as I know, there is no direct NFPA standard or Life Safety Code reference that requires electrical panels to be locked. However, that does not mean hospitals cannot be cited for unlocked electrical circuit breaker panels, in some applications. In fact… If left unlocked, it most likely will draw the attention of a surveyor and may lead to a finding.

Section 4.6.1.2 of the 2000 edition of the LSC says any requirements that are essential for the safety of building occupants and that are not specifically provided for in the LSC can be determined by the AHJ. So, Joint Commission has determined that electric circuit breakers for critical equipment, that can be deactivated by unauthorized individuals is a safety risk, and if not addressed with either a lock or a risk assessment, most likely will be written up under EC.02.01.01., EP 1.

 

Joint Commission has addressed this in their FAQ’s found online at www.jointcommission.org under ‘Standards- FAQ’:

Environment of Care (CAMH / Hospitals)

Locking of Electrical Panels

Current | November 24, 2008

Q. Are electrical panels in patient areas required to be locked?

A. While there are no requirements for electrical panels to be locked, the organization should conduct a risk assessment. Generally, electrical panels in certain patient care areas, such as pediatrics, geriatrics and behavioral health units, or public spaces and corridors not under direct supervision should be assessed with consideration given to keeping them locked. Electrical panels located in secure areas that are accessible to authorized staff may not need to be locked.

If you’re looking for suggestions, I would recommend a risk assessment be made of any electrical panel that is not secure from unauthorized access, for two reasons:

  1. The risk assessment will provide the organization a clear course of action to take concerning locking the panels; and:
  2. The risk assessment will provide the organization with paperwork (documentation) that should protect them from any findings in the future.

I would also suggest that you walk your facility, locating those electrical panels that could be accessed by unauthorized individuals, or panels that are not directly supervised, and lock them. If they cannot be locked, or if you believe there is a sufficient safety reason why to not lock them, then write up a simple risk assessment evaluating them and run the assessment by your safety committee.

I will have a post coming up that discusses risk assessments and a sample risk assessment form to use as a template.

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Oct 04 2012

Electrical Appliances Not Located in the Patient Care Vicinity

Category: BlogBKeyes @ 5:00 am
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I was recently asked how Joint Commission and other authorities look at  electrical items used by staff that do not come into contact with patients, such as refrigerators, fans, coffee pots and lamps.  Do hospitals have to remove all of these personal use appliances? The short and quick answer is No, but there are some things you need to be aware of.

When they do not have a direct standard which addresses the issue, Joint Commission will refer to NFPA 99 on the use and testing requirements for electrical equipment. They are permitted in the hospital, but they must be checked before they are placed into service. Take a look at section 7-5.2.2.1 of NFPA 99 (1999 edition) which says:

Patient Care Area: The leakage current for facility owned appliances (e.g. housekeeping or maintenance appliances) that are used in a patient care vicinity and are likely to contact the patient shall be measured. The leakage current shall be less than 500 microamperes. Tests shall be made with Switch A in Figure 7-5.1.3.5 in the open position for two-wire equipment that is not double-insulated. Household or office appliances not commonly equipped with grounding conductors in their power cords shall be permitted provided they are not located within the patient care vicinity. For example, electric typewriters, pencil sharpeners, and clocks at nurses’ stations, or electric clocks or TVs that are normally outside the patient care vicinity but might be in a patient’s room, shall not be required to have grounding conductors in their power cords.”

Note: Patient care vicinity is defined as a space for the examination and treatment of patients which extends 6 feet beyond the normal location of the bed, table, chair, treadmill, or other device that supports the patient during examination and treatment, and extends to 7 feet 6 inches above the floor.

As you may deduce, there is not a clear and simple standard that directly regulates electric appliances (such as lamps, refrigerators, fans and coffee pots) when they are not used in patient care vicinities. Here is what I believe Joint Commission and other authorities will expect from your organization in regards to electrical appliances that are away from the patient care vicinity:

1. Write into your Safety Management Plan (or it can be a separate policy referenced into your management plan) the organization’s plan of action concerning electrical devices that are not to be used within the patient care vicinity.

2. Upon initial installation (or before initial installation when the equipment is received at the hospital) conduct a current leakage test on the device, and document same. No further testing is required. If the device is removed and relocated, then a visual examination of the electrical cord needs to be conducted. No record of this visual examination is required.

3. Include language prohibiting the use of extension cords, power strips, adapters from 3-prong to 2-prong, and three-way adapters without the consent and permission of the Facilities department.

Having a policy on an issue when there is not a clear standard governing the issue, is an excellent way to demonstrate to the Joint Commission that you recognize the potential risk involved with the use of the device, and you have a plan to address it. If an electrical appliance shows up that doesn’t exactly fit into this policy, then conduct a risk assessment identifying all of the potential risks to patients, visitors and staff, and have it reviewed and approved by your safety committee.

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