Magnetic Locks

Q: Is there a code requirement for testing magnetic-locking devices, for a facility maintenance director?

A: There is a requirement in NFPA 72-2010, section 14.4.5 that all interface devices (i.e. relays, control modules) be tested once per year. Since the magnetic locks in access-control and delayed egress locks are connected to the fire alarm system via an interface relay, then the magnetic lock needs to be tested once per year to ensure it disconnects during a fire alarm signal. This test is required to be conducted by someone who is certified in accordance with NFPA 72.

If you are CMS certified or accredited by any of the major accreditation organizations then you would be expected to comply with the manufacturer’s recommendations on preventive maintenance. Most manufacturers of magnetic locks requires periodic maintenance to ensure they are functioning correctly.

GFCI Receptacles on Ice Machines

Q: We had our Joint Commission inspection today and they cited us for water coolers and ice machines not being plugged into GFCI (ground-fault circuit interrupter) receptacles. One of our buildings was built in 1972 and the other was 2008. They cited NFPA 99-2012 Chapters 6 and 9, under EC 02.05.05 EP 8. Do you believe that was a correct finding? Thanks

A: Yes… that is a legitimate finding.

NFPA 99-2012, section 6.3.2.1 says the electrical installation must be in accordance with NFPA 70 National Electrical Code. Article 210.8(B) of NFPA 70-2011 says ground-fault circuit-interruption for personnel protection shall be provided as required in 210.8(A) through (C). The ground-fault circuit-interrupter shall be installed in a readily accessible location.

Sub-section (B) “Other Than Dwelling Units” says all 125-volt, single-phase, 15- and 20-ampere receptacles installed in the locations specified in 210.8(B)(1) through (8) shall have ground-fault circuit-interrupter protection for personnel:

(1) Bathrooms

(2) Kitchens

(3) Rooftops

(4) Outdoors

(5) Sinks — where receptacles are installed within 6 ft of the outside edge of the sink.

(6) Indoor wet locations

(7) Locker rooms with associated showering facilities

(8) Garages, service bays, and similar areas where electrical diagnostic equipment, electrical hand tools, or portable lighting equipment are to be used

So, item #6 ‘wet locations’ is the kicker on this issue. The AHJs are now interpreting anything that holds water to be a wet location, and therefore must have a GFCI receptacle. Another issue that you need to be aware of, is all GFCI receptacles need to be tested monthly. Ouch. More labor and documentation.

I don’t see where NFPA 99-2012 Chapter 9 (HVAC) applies in this issue, but it is a legitimate finding through chapter 6.

Receptacle Adapters

Q: There seems to be some confusion on the use of multiplug outlet adaptors such as changing the receptacle from 2 outlet to 6 in our hospital. I have been told that they have to have a reset, while some have said they only need a surge protector. I cannot seem to find anything in the Life Safety Code. Do you have a comment on this?

A: Yes I do… NFPA 99-2012, section 10.2.4 discusses this to some detail:

  • Three-prong to two-prong adapters are not permitted
  • All adapters must be UL listed for their purpose

So, while this section seems to allow three-to-one receptacle adapters (or 2-to-6 adapters in your case), I would not be in a hurry to implement them. Most surveyors will cite an organization for using these three-to-one adapters because it implies there are not a sufficient number of receptacles in that area, and creates an unsafe environment. According to the NFPA 99-2012 Handbook, it says this about section 10.2.4:

“Any use of adapters or extension cords within healthcare facilities, while permitted subject to the conditions listed in 10.2.4.1 through 10.2.4.3, should be used with caution. The nature of this caution includes attention of the introduction of trip hazards for patients, staff, or visitors; the increased possibility of damage to cords that are lying on the floor; the ease with which grounding resistances or power cord ampacity can be exceeded; and the possibility of incorrect polarization.”

So, my advice is to NOT use these adapters for the reasons stated above. Take the time to increase the number of properly installed receptacles in that area.

Extension Cords

Q: Are there any life safety rules regarding the use of extension cords in the operating room?

A: According to NFPA 70-2011, Article 400.8 (1), extension cords are permitted as long as they are temporary and not used in lieu of fixed wiring such as a wall receptacle. From a safe environment perspective, the cord cannot present a trip hazard or any other safety-related hazard, and NFPA 99-2012, section 10.2.4.2 says extension cord adapters and fittings must be listed (i.e. UL listed) for the purpose that they serve.  Additionally, CMS K-Tag 920 says equipment that is connected to the extension cords should not over-load the current draw for the extension cord.

So, in a surgery room, an extension cord could be used for the temporary use of equipment, provided it meets all of the above requirements. But an extension cord cannot be used for equipment that is used over and over for multiple events, days, weeks, etc.

An extension cord is only permitted for temporary use, such as a housekeeper would use an extension cord for a vacuum cleaner, or a maintenance technician would use an extension cord for a power tool. Another example of a temporary use would be a temporary workstation set up for a vendor working for a day or two in your facility. But you cannot set up an extension cord in your office to operate your computer or printer because that would not be considered temporary. Similarly, you cannot set up an extension cord in a surgery room to power some medical equipment that is used for multiple cases, over and over. If the medical equipment is used only once, or used only once in a great while, then an extension cord would be permitted, provided it met all the other requirements.

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.