November 01, 2017 | | Comments 0
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ADA vs. LSC: Projecting into the Future—Are You Ready to Rumble?

One of the nagging things (at least for me) that’s been looming in the background is CMS’ statement (and restatement, with a side of reiteration) emphasizing that the Life Safety Code® (LSC) is not an accessibility code and, thus, does not ensure compliance with the Americans With Disabilities Act (ADA). You can find that statement and some other funky stuff here.

The web page also includes some specific considerations that I suspect that you will find of considerable interest (well, it did for me) in that it appears to represent some sense of how the ADA vs. LSC joust is going to manifest itself in the field. The following are the relevant sections, with a link to the individual paragraphs from the Federal Register:

SECTIONS 18.2.3.4(2) AND 19.2.3.4(2)—CORRIDOR PROJECTIONS

This provision requires noncontinuous projections to be no more than 6 inches from the corridor wall. In addition to following the requirements of the LSC, healthcare facilities must comply with the requirements of the ADA, including the requirements for protruding objects. The 2010 Standards for Accessible Design (2010 Standards) generally limit the protrusion of wall-mounted objects into corridors to no more than 4 inches from the wall when the object’s leading edge is located more than 27 inches, but not more than 80 inches, above the floor. See Sections 204.1 and 307 of the 2010 Standards, available at http://www.ada.gov/​regs2010/​2010ADAStandards/​Guidance2010ADAstandards.htm [2] (“2010 Standards”). This requirement protects persons who are blind or have low vision from being injured by bumping into a protruding object that they cannot detect with a cane. (https://www.federalregister.gov/d/2016-10043/p-78)

Although the LSC allows 6-inch projections, under the ADA, objects mounted above 27 inches and no more than 80 inches high can only protrude a maximum of 4 inches into the corridor beyond a detectable surface mounted less than 27 inches above the floor (except for certain handrails which may protrude up to 41/2″). See section 307 of the 2010 standards for requirements for handrails and post-mounted objects. CMS intends to provide technical assistance regarding strategies for how to avoid noncompliance with the ADA’s protruding objects requirement, as well as how to modify non-compliant protruding objects.) (https://www.federalregister.gov/d/2016-10043/p-80)

SECTIONS 18.2.3.4 AND 19.2.3.4—CORRIDORS

This provision allows for wheeled equipment that is in use, medical emergency equipment not in use, and patient lift and transportation equipment be permitted to be kept in the corridors for more timely patient care. This provision also allows facilities to place fixed furniture in the corridors, although the placement of furniture or equipment must not obstruct accessible routes required by the ADA. See section 403.5 of the 2010 Standards. (https://www.federalregister.gov/d/2016-10043/p-88)

So, it appears that we may be looking at some changes of fixtures, etc. (including fire extinguishers—lots of those wall-mounted lovelies floating around, not to mention hand sanitizer dispensers) and a re-think of how we’re positioning furniture in corridors—should be an interesting ride. A hearty thanks to Kevin Kozlowski, president of Oval Brand Fire Products for planting the seed that germinated into this week’s missive. Among other things, Kevin and his folks manufacture a fire extinguisher that meets ADA requirements for wall projections.

If you’d like me to discuss a particular topic, please feel free to kick something my way. I figure any question one person has, the likelihood of others having the same or similar question it pretty strong, so don’t be afraid.

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Filed Under: CMSLife Safety Code

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Steve MacArthur About the Author: Steve MacArthur is a safety consultant based in Bridgewater, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Briefings on Hospital Safety. Contact Steve at stevemacsafetyspace@gmail.com.

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