Electrical Safety Program

Q: I work in a psychiatric hospital. One of the therapies used here involves our clients doing their own personal laundry, so we have multiple laundry rooms off the units with residential grade laundry equipment. Our staff supervises the use of the equipment, but the clients operate the appliances themselves. When I arrived here, there was no electrical safety program in place. Is a program required, and how extensive?

A: Yes… every hospital must have a program for electrical safety, but the codes and standards are not real specific on the matter. If you are Joint Commission accredited, you are required by EC.01.01.01, EP 8 to have a written Utility Management program, and EC.02.05.01 requires the hospital to manage the risks associated with the utility systems. Electrical safety is considered part of the Utility Management plan and needs to be addressed in the written plan. Also, EC.02.06.01 requires the hospital to establish and maintain a safe, functional environment. If a surveyor were to observe any unsafe activity involving electrical safety, he/she could cite a finding under any of these standards.

The accreditation organizations expect hospitals to comply with other regulatory agencies, such as OSHA, state regulations and local ordinances. OSHA expects compliance with NFPA 70E on electrical safety which may involve all of your maintenance staff. In addition, section 9.1.2 of the 2012 Life Safety Code requires compliance with NFPA 70 for all issues requiring electrical wiring and equipment. So, there are multiple regulations and standards that require healthcare organizations to have a safe electrical environment, and the accreditation organization requires that to be included in the written form of the Utility Management plan. How specific you want to make your electrical safety program is up to you and the regulations enforced by the other authorities.

Restricted Access to Electrical Closets

Q: My questions are in relation to access control into electrical closets and life safety equipment closets. We have several electrical closets “locked down” by our IT department because they have installed network switches in these closets. One closet in particular also has an ATS switch and our fire alarm panel for that building. This closet is locked down to those who have “card access”. There are several closets that have life safety equipment inside that are also locked down with only card access. My questions are:

  1. Are there any compliance codes to refer to in accordance with life safety that states directly to our issue?
  2. Are there compliances that state “qualified persons” for access to electrical closets?
  3. Access to these electrical closets is limited. What codes or compliance regulation could this be violating?

A: From a Life Safety Code perspective the only compliance regulation that may apply concerns doors locked in the path of egress, which is section 19.2.2.2.4 of the 2012 Life Safety Code. It is permissible to lock the door going into the closet, but once you’re in the closet you cannot lock the door getting out of the closet. There are exceptions, and for closet it is rare to see any of the exceptions used under 19.2.2.2.4. Otherwise, I am not aware of any Life Safety Code issues that would prevent the locking of doors. In fact, HIPAA regulations would require the locking of closets that contain access to health information, so that is why the IT people want the doors to the intermediate distribution frame servers locked.

There are no regulations in the NFPA standards that state ‘qualified persons’ only for access to electrical closets

In an emergency, authorized individuals need to have access to electrical circuit breaker panels, disconnect controls, and the fire alarm panel. As long as the IT people allow unlimited access to certain Engineering-type staff (i.e. maintenance people) to the electrical equipment in these closets, I don’t see any problems.

Emergency Outlet Locations

Q: We are in the process of designing a new building for our ASC. I have been asked to mark the building plans with where I want the red outlets to be. What are the requirements for placement and number of red emergency power outlets?

A: If you are not an architect or an engineer, then I suggest you do not mark the drawings indicating where the red (emergency power) outlets should be. The location of red outlets is defined in NFPA 99 and the requirements to identify their location is the responsibility of the design professional in charge of the new facility. NFPA 99 is very specific as to where the red outlets should be, and how many. The 2012 edition of NFPA 99 has increasingly more requirements for the location of red outlets compared to previous editions, so it would be best that the professional who is in charge of the design be responsible to provide the locations of the red outlets.

I suggest you return this request back to the design professional without any locations identified by you, and inform the design professional that he/she is the person who is responsible to ensure the design of the new facility meets all of the requirements of the applicable codes and standards, which includes the locations of the red outlets.

Now, if the design professional is asking you to identify the location of red outlets in addition to those that are required by NFPA 99, then that is a different issue. But, that’s not what your question implied.

Electric Blanket in Nursing Home

Q: My mother suffers from a syndrome which causes her feet to turn white and feel extremely icy. She is not allowed to use an electric blanket which allows her to sleep since moving to a nursing facility. Can the doctor write a prescription to supersede the rule?

A: I’m sorry to hear about your mother… If you go to my website and type in “Electric blanket” in the search engine, you will get this response which I wrote 2 years ago:

Q: Are electric blankets permitted to be used by patients in long term care facilities? I cannot find any references to electric blankets in any NFPA codes or standard.

A: Technically, you are correct: There is no specific NFPA code or standard that prohibits the use of electric blankets in healthcare. However, there are significant risks to the patient and staff if you do use them, and before you allow the use of electric blankets, you need to conduct a risk assessment. At a minimum, the risk assessment needs to address to following issues:

  • Could the heat generated from the blanket cause epidermal damage to the patient?
  • Could the electrical portion of the blanket become damaged due to abuse or spillage, and cause harm to the patient?
  • Could the electrical cord become damaged (frayed) by other wheeled equipment rolling on top of the cord?
  • Could the electrical cord become a tripping hazard to the patient or staff?
  • Could the patient accidentally set the temperature control too high and cause damage to their body?
  • How will the electric blankets be maintained and inspected, and who will perform this task?

Another issue that you need to address… Why do you want to use electric blankets? Is the patient room too cool for the patient’s comfort level? There are minimum temperature levels that the organization must meet. If a surveyor observes the use of electric blankets, they have the right to investigate to determine if you did a risk assessment that addresses all of the above issues, and more. They have the right to review your risk assessment and they have the right to disagree with the conclusions in the risk assessment. In other words, no matter how you justify their use, a surveyor can still cite you for an unsafe environment for using electric blankets if they want.

My advice: Stay away from electric blankets, and do not allow them. They become more problems than they are worth. Check with your state and local authorities to determine if they have regulations that would prohibit their use.

To answer your question directly… no, a physician doe snot have the power to write an order that supersedes the Life Safety Code, or any other regulatory requirement. However, healthcare organizations may take Interim Life Safety Measures (ILSM) when situations require the non-compliance of a code or standard.

While electric blankets are not prohibited from use in healthcare organizations, they do present a certain level of risk. If administration wants to re-evaluate that risk and take special precautions to accommodate your mother, that would be permitted.

Cables Strapped to Conduit and LIM Testing

Q: Can fiber optic and low voltage cables be attached or strapped to conduit? Also, what certification is needed for individuals who perform the annual line isolation monitor (LIM) tests in operating rooms?

A: No, cables and wires are not permitted to be strapped to conduit, unless the cables or wires control the circuit inside the conduit. This is a huge problem in many hospitals as many facilities did not adhere to article 300-11(B) of the 2011 NFPA 70 National Electric Code requirement for many years.

To answer your second question, I reviewed article 517-160 of NFPA 70-2011, on Isolated Power Systems for healthcare, and I did not see anything that required any level of training, certification or licensure for individuals conducting tests on LIM.

I also examined NFPA 99 Health Care Facilities Code, 2012 edition, and according to sections 6.3.3.3.2 and 6.3.4.1.4, LIM must be tested after installation, then monthly; or every 12 months if the LIM is equipped with automated self-test and self-calibration capabilities. Nowhere in this document does it discuss the requirements for the individual performing this test.

Perhaps there may be another code or standard that specifies the requirements for testing, but I did not find it. I suggest you ask your state or local AHJs to see if they have any requirements that must be adhered to.

A Reader Speaks Out…

A reader has an objection to one of the answers I provided in yesterday’s blog concerning Power Strips…

Brad:

In the Sept. 2, 2016 article on Power Strips the following Q & A appeared.

Question: Can IT electronic health record equipment use an RPT within the patient care vicinity?

Answer: No. “Patient-care-related electrical equipment” is defined as electrical equipment that is intended to be used for diagnostic, therapeutic, or monitoring purposes in the patient care vicinity. IT electronic health record equipment does not meet this definition. Since it is non-patient care related electrical equipment, it is not permitted to be connected to a power strip in the patient care vicinity.

I had asked George Mills from The Joint Commission at the 2015 ASHE Convention if bedside IT electronic health record equipment met the definition of ““Patient-care-related electrical equipment”. He said it did. I agree with this since these units are being used to do things such as display x-rays and act as a gate keeping prior to a patient being given medication. I feel that this equipment is an integral and direct component in patient care. The ability to adjust the workstation permanently mounted next to the bed depends on the wires from the various components (monitor, CPU, barcode reader) being plugged into an RPT and the single wire from the RPT being routed through the workstation and out to a wall outlet.

My question is: Has TJC or CMS placed anything in writing that states that these devices do or do not meet the definition of patient care equipment?

 

A: No… TJC and CMS has not placed anything in writing that’ states these devices do or do not meet the definition of patient care equipment. But, you make a good point.

By your description, the traditional electronic health record equipment is now serving as “monitoring” equipment for patient care. You and George have changed the traditional use of the equipment from just storing and retrieving healthcare records, to a patient care related use. This meets the definition of patient care related electrical equipment and would then be permitted to be used in the patient care vicinity.

I suggest you perform a risk assessment and get that documented so a surveyor in the future will not cite you for that. Because, from the traditional use of the equipment, it does not appear to meet the definition of patient care related electrical equipment.

 

Q&A Information on Power Strips

A client of mine sent me the following questions regarding power strips. The answers were taken from the CMS S&C memo 14-46 regarding the use of power strips in accordance with NFPA 99-2012.

 

Question:

Within the patient care vicinity, can non-patient care related electrical equipment be plugged into a RPT instead of a SPRPT?

Answer:

No. Power strips providing power to non-patient care electrical equipment have to be a RPT (UL 1363)… and not a SPRPT (UL 1363A). However, power strips may not be used in a patient care vicinity to power non-patient care-related electrical equipment such as personal electronics. So, even if connected to a RPT (UL 1363), it would not be permitted within a patient care vicinity.

 

Question:

Can IT electronic health record equipment use an RPT within the patient care vicinity?

Answer:

No. “Patient-care-related electrical equipment” is defined as electrical equipment that is intended to be used for diagnostic, therapeutic, or monitoring purposes in the patient care vicinity. IT electronic health record equipment does not meet this definition. Since it is non-patient care related electrical equipment, it is not permitted to be connected to a power strip in the patient care vicinity.

 

Question:

Is it also correct to say patient equipment cannot share a SPRPT with non-patient care related electrical equipment?

Answer:

Yes.

 

Question:

Has Joint Commission or others defined the extent of “Patient Care Related Electrical Equipment” definition?

Answer:

Yes. According to section 3.3.137 of NFPA 99-2012, “patient-care-related electrical equipment” is defined as electrical equipment that is intended to be used for diagnostic, therapeutic, or monitoring purposes in the patient care vicinity

 

Question:

Is there a source to define and guide SPRPT/RPT electrical safety expectations for non-patient care related electrical equipment like a workstation on wheels or a computer that is in the patient are vicinity?

Answer:

Yes. See the CMS S&C memo 14-46. You can find it by searching “CMS S&C memo 14-46” on your internet search engine.

 

Question:

If the medical equipment is just being charged outside of the patient care vicinity and not being used on a patient, does it have to be connected to a SPRPT or can it be connected to a RPT?

Answer:

Power strips providing power to patient-care related electrical equipment must be SPRPT (UL 1363A). Patient care related equipment cannot be connected to a RPT (UL 1363) power strip.

Locked Electrical Panels

Q: Can you give me a code reference for the need for electrical panels to be locked? We were cited by a surveyor for not locking our electrical panels.

A: As far as I know, there is no direct standard or 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. 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 most accreditors have determined that electric circuit circuits on 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. Joint Commission has addressed this in their FAQ’s and says 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 suggest 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.

Electrical Panels

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.

More on the CMS S&C Memo Concerning Power Strips

12-120-878-TS[1]I received a question from a reader that I was unable to immediately answer. The question dealt with the use of power strips in a business occupancy: Did the categorical waiver to allow the use of power strips described in the  S&C memo 14-46-LSC, issued September 26, 2014 apply to business occupancies? The reader explained that the physician office building where he worked did not have hospital grade receptacles so it did not make sense to him that using UL listed power strips was necessary.

My immediate thought was the CMS issued categorical waiver would only apply to healthcare occupancies because NFPA 99 (2012 edition) does not apply to business occupancies. NFPA 99 is referenced by the healthcare occupancy chapter in section 18.5.1.3 of the 2012 LSC, but it is not referenced by the business occupancy chapters in the same LSC.

But, since I was not sure, I asked the question of a reliable source at CMS and they said the 2012 NFPA 99 Section 3-3.2.1.2(d)2 pertains to the minimum number of receptacles in all Patient Care Rooms.  Patient Care Rooms is defined as any room of a health care facility wherein patients are intended to be examined or treated.  In addition, the 2012 NFPA 99 Section 10.2.3.6 pertains performance criteria and testing for patient-care-related electrical appliances and equipment.  Patient-care-related electrical equipment is defined as electrical equipment that is intended to be used for diagnostic, therapeutic, or monitoring purposes in the patient care vicinity.

As these definitions do not make a differentiation based on occupancy,  it is CMS’s understanding that 2012 NFPA 99 power strip requirements would be applicable in all health care facilities in rooms where patients are intended to be examined or treated regardless of occupancy classification.

So, the answer to the question is the categorical waiver applies to all patient care rooms, regardless of the occupancy classification. This means if you want to use power strips in a physician exam room in a medical office building that is a business occupancy, you need to follow the guidelines in the S&C memo and only use UL listed power strips. However, for other areas of the business occupancy that are not considered patient care rooms, the NFPA 99 requirements concerning UL listed power strips do not apply. But it is wise to purchase only UL listed power strips since you cannot control where they may end up.