Heated Massaging Seat

Q: I work at an ICF facility. We have a person with arthritis and I was just asked if a heated pad massaging seat could be purchased for them. I know we can’t have heated blankets, personal heaters, etc. With this item having heat, I would assume it would probably not be approved either. Can I get your input??

A: There are no CMS codes or standards that would prohibit this type of device. Actually, there are no codes or standards that would prohibit electric heating blankets, but the perceived risk of danger usually disqualifies them from use.

There will be risks in using this heated, massaging seat that you need to address, such as:

  • Trip hazard with the electrical cord
  • Something heavy rolling on the electrical cord creating a pinch-point, thereby causing a short-circuit over time
  • The seat becoming too hot for the patient

If you address these risks in a risk assessment and mitigate them to the satisfaction of the surveyor, you should be fine.

Emergency Management

Q: Regarding the new CMS rule on emergency preparedness, are they telling us that we must have full heating and cooling support for the entire hospital during a power outage up to and including adding more generators?

A: No… I don’t believe it is. Section 482.15 (b)(1)(ii)(A) says, “The hospital must develop and implement emergency preparedness policies and procedures … that must address temperatures to protect patient health and safety”. This does not say or mean that you need to add equipment to maintain temperatures (other than what the Life Safety code and NFPA 99 requires). It’s saying you must have a policy and a procedure that must address temperatures to protect the health and safety of patients.

So, your policies must reflect a plan on how you are going to accomplish this. If you lose fuel for the heating appliances, then what is your back-up plan? If you lose normal power and then emergency power, what is your back-up plan? Ultimately, your plan should recognize that you must evacuate the building if you can no longer maintain safe temperatures for your patients and staff.

Strange Observations – Sprinkler Pipe Supported From Ductwork

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

This is another picture of sprinkler pipe supported from HVAC ductwork, similar to last week’s Strange Observations.

I include it here to emphasize that sprinkler pipe cannot be supported from anything except the building structure itself.

I suspect I see this problem in 75% of the hospital where I consult… but then, I’m looking for it.

There is one exception to that rule… Sprinkler pipe may be suspended from a hanger that also supports ductwork, provided the hanger is designed to support the weight of the duct, the pipe, the water in the pipe, and an additional 250 lbs. (see NFPA 13-2010, 9.2.1.5). If you ever see sprinkler pipe suspended from the same hanger that supports ductwork, ask the installer to provide documentation that the hanger can support that weight.

Probe Cleaning Room

Q: We have two small processing rooms in a hospital where they clean and reprocess vaginal probes, using the chemical RESERT. Should these rooms be held to the same standard as an Endoscope cleaning room (negative pressure, 10 ACH and exhausted directly to the outdoors, per FGI Guidelines)?

A: I would think so… The Life Safety Code does not comment on this, so it ends up being an issue that the Infection Control people should be consulted. Also, since it is a design issue, please check with your state and local authorities to see if they have a comment.

Portable Space Heaters

Q: Could you please clear up a concern related to section 19.7.8 of the 2012 Life Safety Code, that addresses Portable Space-Heating Devices? Section 19.7.8 (1) states such devices are used only in non-sleeping staff and employee areas. Does this mean that the approved space heaters are allowed at nurse stations or offices that are located in the same smoke compartment as patient care rooms?

A: It really depends on the AHJ’s interpretation of the term “non-sleeping staff and employee areas”. I know Joint Commission interprets this to mean approved space heaters cannot be used in any smoke compartment that contains patient sleeping or treatment activities. Other AHJ’s may not be as definitive, and leave it up to the surveyor to decide.

Personally, I suggest you go with Joint Commission interpretation (see LS.02.01.70, EP 8) as that seems to me to be the more restrictive. You should be safe with most other AHJs if you follow that interpretation.

Strange Observations – Sprinkler Pipe Suspended From Ductwork

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

Some organizations fail to install sprinklers underneath the ductwork that is 48-inches wide or wider. This facility did not forget, but the sprinkler-fitter who installed this pipe for the sprinkler head attached it to the ductwork, which is not permitted.

The sprinkler pipe can only be suspended from the building itself (i.e. structural beams, joists, etc.), and not from anything else.

There is one exception to that rule… Sprinkler pipe may be suspended from a hanger that also supports ductwork, provided the hanger is designed to support the weight of the duct, the pipe, the water in the pipe, and an additional 250 lbs. (see NFPA 13-2010, 9.2.1.5). If you ever see sprinkler pipe suspended from the same hanger that supports ductwork, ask the installer to provide documentation that the hanger can support that weight.

Strange Observations – Rusty Electrical Box

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

Ah…  This is plain ugly.

As you can see, water ran into this electrical junction-box and eventually rusted out the metal box.

I don’t remember the whole story and quite honestly, it really isn’t my business, but I can’t for the life of me figure out why the facility department did not take appropriate action to resolve the water leak to prevent this from happening.

This is a type of deficiency that can lead to a Condition Level finding, if the surveyor believes the staff failed to properly maintain their utilities… which it appears to be so.

Duct Detectors

Q: With regard to testing duct detectors in a hospital, I understand that on an annual basis the automatic shutdown of the AHU’s must be verified when duct detectors are activated. I am unclear if there is also an annual requirement to verify damper (pneumatic and/or electric type but excluding fused links) operation at the same time. Also, is there a requirement to test smoke dampers annually?

A: No… there is not. Even though NFPA 72-2010 does require confirmation of all interface relays tested on an annual basis, and does imply that actuation of the dampers are required, NFPA 72-2010 cannot regulate the testing of fire or smoke dampers. Only NFPA 80-2010 and NFPA 105-2010 can regulate testing requirements for fire and smoke dampers respectfully.

You still have to test the interface relays (modules) on an annual basis, but you are not required to confirm that the smoke dampers did close on an annual basis.

But be aware, that some surveyors may require that you do confirm the smoke dampers closed on an annual interface relay test… That would be an incorrect interpretation on their part, and you may want to point out that NFPA 4 was created (in part) to eliminate these conflicting cross-testing requirements.

Separation Between Hospital and Parking Structure

Q: We have a three-story parking structure attached to a hospital. The top floor of the parking structure is not covered and is open to the atmosphere. Is the exterior wall of the hospital adjacent to the top floor of the parking structure required to be fire-rated? Our original drawings show the wall as not rated.

A: Yes… I would say so. According to section 3.3.188.15 of the 2012 LSC, a parking garage would be considered a Storage Occupancy, and since this is contiguous to the hospital (which is a healthcare occupancy) section 19.1.3.3 (2) would require that you need a 2-hour fire-rated barrier separating the healthcare occupancy from the storage occupancy.

Technically speaking, the entire parking garage is open to the atmosphere, so the only difference between the top deck of the parking garage and the lower decks is there is no roof on the top deck. The top deck is still a storage occupancy just like the lower decks. The LSC does not allow any exceptions to not provide a 2-hour fire rated barrier between the healthcare occupancy and any other occupancy just because it does not have a roof.

Air Pressure Requirements for OR Suite

Q: I have a small 28 bed hospital with one OR suite. Within the OR suite are sterile rooms, a soiled room, and of course the Operating Room, etc. We are rebalancing the air flows for the entire floor which is all health care occupancy. I am aware that the rooms mentioned above, all have air pressure relationship requirements to adjacent areas per the Guidelines for Design & Construction of Hospitals and ASHRAE 170. However, some are questioning the need to have a positive air pressure relationship between the OR suite and other areas. That is, they measure the pressure from the OR suite door to other side which is the in-patient corridor. Is there any pressure relationship requirement in this location?

A: None that I’m aware of. Since surgery departments may or may not be suites, the ASHRAE 170 ventilation Table 7-1 in the FGI Guidelines does not address that. You are correct that the actual operating room has to have a positive air pressure relationship to its surrounding areas. But I am not aware of any ventilation air-pressure requirement for the Surgery suite as measured at the suite entrance door.