Locked Electrical Panels

Q: Is it required to keep electrical panels locked even if they are behind doors that are restricted by card-access readers? Does it depend on which AHJ is inspecting it?

A: According to NFPA 99-2012, section 6.3.2.2.1.3 (A), circuit breaker panels to Category 1 and Category 2 rooms must be secured against unauthorized access. If you can justify that only authorized individuals with approved badge readers can access the panels, then you should not have to lock the individual panels.

But section 1.3.2 of NFPA 99-2012 also says that construction and equipment requirements shall be applied only to new construction and new equipment. That means in existing conditions, relocating your circuit breaker panels to locked rooms is not a requirement.

This is one good reason to conduct the NFPA 99 Risk Assessment to determine what your Category ratings are for your electrical equipment and where they are located.

All AHJs should enforce this the same way… but we know that is not likely to happen.

Oxygen Therapy and Beauty Salons

Q: I am curious if you know of any regulations that deal specifically with LTC residents with oxygen supply and beauty salons. We have a salon in house, and the beautician comes twice a week and I have a sign up that says no oxygen allowed in salon. Do you know of any specific regulations that relate to the use of oxygen in a salon?

A: After reviewing sections 10.5.4.1 and 11.5.1.1.4 of NFPA 99-2012, I believe oxygen therapy would not be permitted to be administered around hot appliances. While beauty salon heating devices such as hair dryers and curling irons typically do not get much attention from surveyors, NFPA 99-2012 does prohibit the administration of oxygen therapy around hot appliances… and hair dryers and curling irons are hot appliances. I would recommend that you not allow the use of O2 therapy equipment in a beauty salon.

Daisy Chain

Q: What would be the appropriate standard for a daisy chain?

A: I’m not entirely sure of what you are asking…. But when you say “What would be the appropriate standard for a daisy chain” I’m assuming you are referring to an extension cord (or power strip) plugged into another extension cord (or power strip). The Code trail that would prohibit that, is:

2012 Life Safety Code, section 19.5.1.1 requires compliance with section 9.1 for utilities. Section 9.1.2 requires compliance with NFPA 70-2011 on all issues of electrical wiring and equipment. NFPA 70-2011, Article 400.8 (1) says: “…flexible cords and cables shall not be used …as a substitute for the fixed wiring of a structure”. So NFPA 70-2011, Article 400.8 (1) prohibits daisy chains, because the first extension cord (or power strip) is now acting as a substitute for the fixed wiring of a structure.

Also, NFPA 70-2011, Article 400.7 (B) says each flexible cords shall be equipped with an attachment plug and shall be energized from a receptacle outlet. That also prohibits a flexible cord (i.e. extension cord or power strip) from being plugged into another flexible cord.

Clothes Iron

Q: Our facility is a nursing home. I have been asked a question if a resident can have a clothes iron in their room? I said no and would check on it. What do you think?

A: While there is not a specific code or regulation preventing a nursing home resident to use a clothes iron, it does present a specific hazard since it can get very hot. If you allowed it, a surveyor could likely cite you for an unsafe environment, which does seem logical. But if you allowed the resident to use the clothes iron with supervision by one of your staff, that would seem to be acceptable (at least by me). Whatever you decide to do, you should have a policy and/or risk assessment on it.

Clearance in Front of Electrical Panels

Q: What is the clearance required in front of electrical distribution panels?

A: According to NFPA 70-2011, article 110.26, a minimum of 36 inches clearance is required in front of all electrical equipment, including controls and panels, extending from the floor to a height of 6 foot 6 inches or the height of the equipment whichever is higher. You must maintain clearance for the width of the equipment or 30 inches, whichever is greater, and all doors and panels must be able to be opened at least 90 degrees.

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.

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.

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.

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).

Hospital-Grade Receptacle Testing

Q: All of our receptacles in patient care rooms are hospital grade and therefore do not have to be tested annually, correct? What I don’t understand is section 6.3.4.1.2 of NFPA 99-2012, which states additional testing of hospital-grade receptacles in patient rooms shall be performed at intervals defined by document performance data. What is document performance data? How do I determine my testing intervals by document performance data?

A: You are correct: Hospital-grade receptacles are not required to be tested annually, but they are required to be tested at intervals determined by the healthcare facility. This is what the NFPA 99-2012 Handbook says about maintenance and testing of electrical receptacles under section 6.3.4.1 of NFPA 99-2012:

NFPA 99 prescribes no time between test intervals for hospital-grade receptacles. Hospital facility managers are permitted to determine appropriate test intervals for hospital-grade receptacles based on ‘documented performance data’. However, this paragraph requires that all non-hospital-grade receptacles within patient bed locations and anesthetizing locations must be tested at least every 12-months. This immediately raises the following question” “What is documented performance data?” There are two possible kinds of data that could meet this requirement. First, the manufacturer could provide data of this sort. Second, experiential data from other hospitals that have used similar devices and documented their failure rates could provide the kind of indication needed for appropriate testing intervals.

So, section 6.3.4.1.2 of NFPA 99-2012 does say additional testing of hospital-grade receptacles in patient care rooms shall be performed at intervals defined by the hospital using information that provides evidence that supports the testing interval decision. This information may come from the manufacturer, or it may come from your own experiences in testing these receptacles. According to NFPA 99-2012, you do not have to test hospital-grade receptacles annually that are located in patient rooms and anesthetizing locations, but you do have to determine what the testing frequency of these receptacles will be based ‘documented performance data’.

The testing requirements that you will need to do is found in NFPA 99-2012, section 6.3.3.2, and is summarized here:

  • The physical integrity of each receptacle shall be confirmed by visual inspection
  • The continuity of the grounding circuit in each electrical receptacle shall be verified
  • The correct polarity of the hot and neutral connections in each electrical receptacle shall be confirmed
  • The retention force of the grounding blade of each electrical receptacle (except locking-type receptacles) shall be not less that 4 oz (115 g).