Low Voltage Wiring

Q: We recently underwent a mock survey in preparation for a full survey soon. The Life Safety mock surveyor cited us for failure to cover low voltage junction boxes. We had differing opinions about the requirement. A member of our team feels that the NEC requirements do not apply in Montana. I was not able to verify that statement. My question is twofold: 1. What experience & opinion do you have about the treatment of low voltage under the same code as high voltage? 2. Are you aware of state (or other codes) which are less stringent taking precedence over more stringent codes?

A: You can never take a less stringent code or standard, over a more stringent code or standard. You always have to comply with the most restrictive requirement. And yes, the National Electrical Code (NEC) NFPA 70-2011 does apply at your facility, regardless if your state requires it or not. This is because you are required to comply with the 2012 Life Safety Code and sections 18.5.1 and 9.1.2 require that you to comply with NFPA 70-2011.

In regards to low-voltage electrical wiring NFPA 70-2011 has many different Articles, depending on the application. Article 300.2 (A) says the requirements in chapter 3 apply to all voltages 600 volts or less. Article 411 is a standard on low-voltage lighting systems operating on 30 volts or less. But Article 517.80 is the one that you will be interested in: It says in healthcare patient care areas, low voltage wiring for communication systems and fire alarm systems less than 120 nominal volts, have to have an equivalent level of insulation and isolation to that required for electrical distribution systems in patient care areas, but the Class 2 and Class 3 signaling and communication systems do not have to comply with the grounding requirements or with the mechanical protection requirements, including raceways.

So, according to the NEC, you are not required to cover low voltage wiring junction boxes… But I advise that you do. Most surveyors will not know be able to tell low voltage qualifying under Article 517.80 when they see it, and will likely cite you for non-compliance.

Strange Observations – Electrical Panel Clearance

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

Remember I have been saying that clearance must be maintained in front of electrical panels for 36 inches, from the floor to the top of the electrical equipment? No?

Well, it does, and it applies to electrical panels such as this.

Illuminated Pumpkin – CORRECTION

On October 23, 2018, I posted a picture of this illuminated pumpkin and wrote that the extension cord could not be used since Article 400.8 (3) of NFPA 70-2011 says flexible cords could not be used as a substitute for fixed wiring. But just recently, a reader asked why this illuminated pumpkin would not qualify for Article 590.3(B) that permits extension cords on holiday decorations for up to 90-days.

After reviewing NFPA 70-2011, I discovered I was incorrect in my original posting and thanked the reader for bringing this to my attention. I then made changes to the original posting to ensure the correct code interpretation was stated.

To be sure, NFPA 70-2011, Article 590.3(B), says extension cords are permitted to be used for holiday decorations up to 90-days. But Article 590.2(A) does say all other requirements of the code would have to be met. implying the extension cord would have to be listed by a national listing agency (i.e. UL). Also, Article 590.2(B) says temporary wiring is acceptable if it is approved based on the conditions of use. So, you would not be able to abuse the concept of an extension cord used on holiday decorations.

This also means that individual organizations could have policies specific to their staff that limit or prohibit the use of extension cords on holiday decorations beyond what NFPA 70-2011 provides.

I apologize for this error, and appreciate the reader for bringing this to my attention.

Extension Cords

Q: Under CMS, is it possible to use a UL listed power cord (extension cord), permanently attached to the equipment assembly providing it meets the ampacity requirements? If yes, what UL listing? UL 1363 A and UL 60601-1 are only power strips and I’m looking for a single outlet configuration that meets the UL requirements.

A: No…. According to NFPA 70-2011, Article 400.8, flexible cords cannot be used as a substitute for fixed wiring.

Strange Observations – Part 47

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

Clearance to all electrical equipment (i.e. panels and disconnect switches) must be maintained for 36 inches in front of the panels from the floor to a point 6-feet 6-inches above the panels, or to the top of the panels whichever is higher.

That means the table and shelving unit need to be removed.

Strange Observations – Part 37

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

See anything unsafe about this electrical panel…?

Here is another example that equipment rooms are really not all that safe.

The inner safety panel is missing from this electrical circuit breaker panel, thereby allowing access to the 480 volt buss bars.

Take a close look at your mechanical rooms, and do monthly inspections in them.

Strange Observations – Part 33

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

Equipment rooms can be a major source of findings for surveyors.

Mostly because equipment rooms are often out-of-sight / out-of-mind. And because often times no-one is assigned to maintain the equipment rooms in safe condition.

Here we have a trash cart and a water machine obstructing access to electrical panels and a fire extinguisher.

Receptacle Testing

Q: Is there a code in the 2012 LSC about testing electrical receptacles around hospital beds?

A: Well… actually, that would be in the NFPA 99-2012 code/standard, and the answer is yes, all receptacles in patient care rooms must be tested. But the frequency of that test is different, depending on whether the receptacle is a hospital-grade receptacle or not.

Section 6.3.4.1.1 says hospital-grade receptacles must be tested after initial installation, replacement, or servicing of the device.

Then section 6.3.4.1.3 says receptacles not listed as hospital-grade, at patient bed locations and in locations where deep sedation or general anesthesia is administered, must be tested at intervals not exceeding 12 months.

But section 6.3.4.1.2 does say additional testing of receptacles (including hospital-grade receptacles) in patient care rooms shall be performed at intervals defined by documented performance data. This means you do have to test hospital-grade receptacles at a frequency determined by the healthcare organization based on information such as historical data, risk assessments, or manufacturer’s recommendation.

So, if you do install hospital-grade receptacles in the above locations, then you do have to test them after the initial installation, but at intervals that you get to determine.

Non-Patient Care Electrical Equipment

Q: What required inspections are needed for non-patient care electrical equipment and at what intervals should they be completed in. I cannot find anything definitive in NFPA 99 – 2012.

A: CMS will expect that you conduct the maintenance activities (i.e. PM’s) as recommended by the manufacturer, for all electrical equipment regardless if it is considered patient care or non-patient care equipment. In addition, this electrical equipment must be on the facility’s inventory of equipment.

This is based on CFR §482.41(c)(2) which is also known as A-0724 in the State Operations Manual (SOM) Appendix A. This document is available at no charge by searching “CMS SOM Hospitals”. Since it is a CMS standard, then all of the accreditation organizations and state agencies must have standards that are equal to that.

So, the answer to your question is: Whatever the manufacturer recommends, you must comply. And this is based on a CMS requirement, not an NFPA 99 requirement.

CMS does offer an Alternative Equipment Management (AEM) program that would allow you to conduct PM activities that differ from the manufacturer’s recommendations, but there are a lot of challenges to this AEM program and it is not for everyone. You can read all about it in CFR §482.41(c)(2).

Receptacle Testing

Q: What are the requirements for receptacle testing for hospital grade receptacles for existing and new health care facility?

A: Section 6.3.4.1.3 of NFPA 99-2012 addresses this issue by saying receptacles not listed as hospital-grade, at patient bed locations and in locations where deep sedation or general anesthesia is administered, must be tested at intervals not exceeding 12 months.

However, as mentioned in yesterday’s posting, section 6.3.4.1.2 of NFPA 99-2012, does state additional testing of hospital-grade receptacles in patient rooms shall be performed at intervals defined by document performance data.

Whether the building is considered new occupancy or existing occupancy, these requirement apply to all applicable locations in all healthcare facilities, and is not limited to just hospitals.