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It was a fine idea at the time: Safety story of the week!

Now it’s a brilliant…

I think we’ve hung out together long enough for you to recognize that I have some geeky tendencies when it comes to safety and related things, sometimes straying beyond the realm of health care. And this is (pretty much definitely) one of those instances.

Over the weekend, while listening to NPR, I happened upon a story regarding safety concerns at the Tesla factory out in California and how operating at the brink (cusp?) of what’s possible can still fall victim to some time-honored realities of the workplace. The story, coordinated by The Center for Investigative Reporting, and aired on their program Reveal (you can find the story, and a link to the podcast of the story here) aims at shedding some light on some folks injured while employed at Tesla. While I can’t say that there’s the figurative “smoking gun” relative to decisions made, but it does seem to fall under the category of “you can make the numbers dance to whatever tune you’d care to play.” I thought it was a very well-done piece and while there may not be specific application to your workplace, I figure you can always learn from what others are (or aren’t) doing. At any rate, I can’t tell the story as well as they have (the podcast lasts about 55 minutes; the SoundCloud link is about halfway down the page), so I would encourage you to give it a listen.

One other quick item for your consideration: We chatted a few weeks ago about the shifting sands of compliance relative to emergency generator equipment and I wanted to note that I think it would be a pretty good idea to pick up a copy of the 2010 edition of NFPA 110 (it’s not that large a tome) or at the very least, go online and use NFPA’s free access to their code library, and familiarize yourself with the contents. Much as I “fear” will be the case with NFPA 99, I think there are probably some subtleties in 110 that might get lost in the shuffle, particularly when it comes to the contractors and vendors with whom we do business. Recently, I was checking out an emergency generator set that was designed and installed in the last couple of years and, lo and behold, found that the remote stop had not been installed in a location outside of the generator enclosure. Now I know that one of the things you’re paying for is a reasonably intimate knowledge of the applicable code and regulation, and emergency power stuff would be no exception (by any stretch of the imagination) and it perturbed me that the folks doing the install (not naming names, but trust me, this was no mom & pop operation that might not have known better) failed to ensure compliance with the code. Fortunately, it was identified before any “official” survey visits, but it’s still going to require some doing to get things up to snuff.

I have no reason to think that there aren’t other “easter eggs” lurking in the pages of the various and sundry codified elements brought on by the adoption of the 2012 Life Safety Code®, so if you happen to find any, feel free to give us all a shout.

I understand all destructive urges

It seems so perfect…

A couple of somewhat disparate, but important, items for your consideration this week. I’m still somewhat fixated on how the survey process is going to manifest itself (regardless of which accrediting organization is doing the checking—including the feds). There are one or two clues to be had at the moment and I am most hopeful that the reason there is so little information coming out of the survey trenches is because there have been minimal change of a drastic nature/impact.

So, on to the discussion. As noted above, while the topics of conversation are indeed somewhat disparate, they do share a common theme—perhaps the most common theme of recent years (not to mention the most common theme of this space): the hegemony of the risk assessment. The topics: management of the behavioral health physical environment, and the risk assessment of systems and equipment indicated by NFPA 99-2012 Health Care Facilities Code. Fortunately, there are resources available to assist you in these endeavors—more on those in a moment.

For the management of the behavioral health physical environment, it does appear that our good friends in Chicago are making the most use of their bully pulpit in this regard. Health Facilities Management had an interesting article outlining the focus that would be well worth your time to check out if you have not already done so. I can tell you with absolute certainty that you need to have all your ducks in a row relative to this issue: risks identified, mitigation strategies implemented, staff educated, maybe some data analysis. As near as I can tell, not having had an “event” in this regard is probably not going to be enough to dissuade a surveyor if they think that they’ve found a risk you either missed or they feel is not being properly managed. If I have said this once, I couldn’t tell you how many times I’ve said it (if I had a dollar for every time…): It is, for all intents and purposes, impossible to provide a completely risk-free environment, so there will always be risks to be managed. It is the nature of the places in which we care for patients that there is a never-ending supply of risky things for which we need to have appropriate management strategies. And I guess one risk we need to add to the mix are those pesky surveyors that somehow have gotten it in to their heads that there is such a thing as a risk-free environment. Appropriate care is a proactive/interactive undertaking. We don’t wait for things to happen; we manage things as we go, which is (really) all we can do.

As to the risk assessment of systems and equipment, as we near the first anniversary of the adoption of the 2012 edition of the Life Safety Code® (LSC) (inclusive of the 2012 edition of NFPA 99), the question is starting to be raised during CMS surveys relative to the risk assessment process (and work product) indicated in Chapter 4 Fundamentals (4.2 is the reference point) and speaks of “a defined risk assessment procedure.” I would imagine that there’s going to be some self-determination going on as to how often one would have to revisit the assessment, but it does appear that folks would be well-served by completing the initial go-through before we get too much closer to July. But good news if you’ve been dawdling or otherwise unsure of how best to proceed: our friends at the American Society for Healthcare Engineering have developed a tool to assist in managing the risk assessment process and you can find it here. I think you will find that the initial run-through (as is frequently the case with new stuff) may take a little bit of time to get through. (In your heart of hearts, you know how complex your building is, so think of this as an opportunity to help educate your organization as to how all those moving parts work together to result in a cohesive whole.)


These things have a habit of spreading very quickly in the survey world, so I would encourage you to keep at it if you’ve already started or get going if you haven’t. Even if you don’t have an immediately pending survey, a lot of this stuff is going to be traceable back to your previous survey and with that first anniversary of the LSC adoption rapidly approaching, better to have this done than not.

Do you know the way to TIA?

Last week we touched upon the official adoption of a handful of the Tentative Interim Agreements (TIA) issued through NFPA as a function of the ongoing evolution of the 2012 edition of the Life Safety Code® (LSC). At this point, it is really difficult to figure out what is going to be important relative to compliance survey activities and what is not, so I think a brief description of each makes (almost too much) sense. So, in no particular order (other than numerical…):

  • TIA #1 basically updates the table that provides the specifications for the Minimum Fire Protection Ratings for Opening Protectives in Fire Resistance-Rated Assemblies and Fire-Rated Glazing Markings (you can find the TIA here). I think it’s worth studying up on the specific elements—and perhaps worth sharing with the folks “managing” your life safety drawings if you’ve contracted with somebody external to the organization. I can tell you from personal experience that architects are sometimes not as familiar with the intricacies of the LSC—particularly the stuff that can cause heartburn during surveys. I think we can reasonably anticipate a little more attention being paid to the opening protectives and the like (what, you thought it couldn’t get any worse?), and I suspect that this is going to be valuable information to have in your pocket.
  • TIA #2 mostly covers cooking facilities that are open to the corridor; there are a lot of interesting elements and I think a lot of you will have every reason to be thankful that this doesn’t apply to staff break rooms and lounges, though it could potentially be a source of angst around the holidays, depending on where folks are preparing food. If you get a literalist surveyor, those pesky slow cookers, portable grills, and other buffet equipment could become a point of contention unless they are in a space off the corridor. You can find the whole chapter and verse here.
  • Finally, TIA #4 (there are other TIAs for the 2012 LSC, but these are the three specific to healthcare) appears to provide a little bit of flexibility relative to special locking arrangements based on protective safety measures for patients as a function of protection throughout the building by an approved, supervised automatic sprinkler system in accordance with Originally, this section of the LSC referenced which doesn’t provide much in the way of consideration for those instances (in Type I and Type II construction) where an AHJ has prohibited sprinklers. In that case, approved alternative protection measures shall be permitted to be substituted for sprinkler protection in specified areas without causing a building to be classified as non-sprinklered. You can find the details of the TIA here.


I suppose before I move on, I should note that you’re probably going to want to dig out your copy of the 2012 LSC when looking these over.

As a quick wrap-up, last week The Joint Commission issued Sentinel Event Alert #57 regarding the essential role of leadership in developing a safety culture (some initial info can be found here). While I would be the last person to accuse anyone of belaboring the obvious (being a virtual Rhodes Scholar in that type of endeavor myself), I cannot help but think that this might not be quite as earth-shattering an issuance as might be supposed by the folks in Chicago. At the very least, I guess this represents at least one more opportunity to drag organizational leadership into the safety fray. So, my question for you today (and I suspect I will have more to say on this subject over the next little while—especially as we start to see this issue monitored/validated during survey) is what steps has your organization taken to reduce intimidation and punitive aspects of the culture. I’m reasonably certain that everyone is working on this to one degree or another, but I am curious as to what type of stuff is being experienced in the field. Again, more to come, I’m sure…

Doo doo doo, lookin’ out my back (fire) door…

Something old and something new(ish): old rant, new requirement.

As we move ever onwards toward the close of our first year “under” the 2012 Life Safety Code® (talk about a brave new world), there was one item of deadline that I wanted to touch upon before it got too, too much further into the year. And that, my friends, is the requirement for an annual inspection of fire and smoke door assemblies—for those of you keeping track, this activity falls under the EOC chapter under the standard with all those other pesky life safety-related inspection, testing, and maintenance activities (don’t forget to make sure that your WRITTEN documentation of the door assembly inspection includes the appropriate NFPA standards reference—in this case, you have quite a few to track: NFPA 101-2012 for the general requirements; NFPA 80-2010 for the fire door assemblies; and, NFPA 105-2010 for the smoke door assemblies). Also, please, please, please make sure that the individual(s) conducting these activities can “demonstrate knowledge and understanding of the operating components of the door being tested” (if this sounds like it might be a competency that might need to be included in a position description and performance evaluation, I think you just might be barking up the correct tree). The testing is supposed to begin with a pre-test visual inspection, with the testing to include both sides of the opening. Also, if you are thinking that this is yet another task that will be well-served by having an inventory, by location, of the door assemblies, you would indeed be correct (to the best of my knowledge). As a caveat for this one, please also keep in mind that this would include shaft access doors, linen and trash chute—while not exactly endless, the list can be pretty extensive. At the moment, from all I can gather, fire-rated access panels are optional for inclusion, though I don’t know that I wouldn’t be inclined to have a risk assessment in one’s back pocket outlining the decision to include or not to include (that is the question!?!) the access panels in the program.

I’m thinking you will probably want to capture this as a recurring activity in your work order system, as well as developing a documentation form. Make sure the following items are covered in the inspection/testing activity:


  • No open holes or breaks in the surfaces of either the door or the frame
  • Door clearances are in compliance (no more than ¾ inch for fire doors; no more than 1 inch for corridor doors; no more than ¾ inch for smoke barrier doors in new buildings)
  • No unapproved protective plates greater than 16 inches from the bottom of the door
  • Making sure the latching hardware works properly
  • If the door has a coordinator, making sure that the inactive door leaf closes before the active leaf
  • Making sure meeting edge protection, gasketing, and edge seals (if they are required—depends on the door) are inspected to make sure they are in place and intact


I think the other piece of the equation here is that you need to keep in mind that “annual” is a minimum frequency for this activity; ultimately, the purpose of this whole exercise is to develop performance data that will allow you to determine the inspection frequency that makes the most sense for compliance and overall life safety. Some doors (and I suspect that you could rattle off a pretty good list of them without even thinking about it too much) are going to need a little more attention because they “catch” more than their fair share of abuse (crash, bang boom!). Now that this isn’t an optional activity (ah, those days of the BMP…), you might as well make the most of it.


Putting on my rant-cap, I’d like to steal just a few moments to lament the continuing decline of decency (it used to be common; now, not so much) when it comes to interactions with strangers (and who knows, maybe it’s extending into familial and friendial interactions as well—I sure hope not!) I firmly believe that any and every kindness should be acknowledged, even if it’s something that they were supposed to do! My favorite example is stopping for pedestrians (and if you’ve been behind me, yes that was me stopping to let someone complete the walk); yes, I know that in many, if not most, places, the law requires you to stop for pedestrians in a crosswalk, but I think the law should also require acknowledgement from the pedestrians. Positive reinforcement can’t possibly hurt in these types of encounters. Allowing merging traffic to move forward (signaling is a desirable approach to this, but you should also signal the person who let you in). I’m not sure if we’re just out of practice or what, but I’d ask you to just try a little more to say “hi” or “thanks” or give somebody a wave when they aren’t jerks (and just so we’re straight, a wave includes more than just the middle digit). Maybe I’m going a little Pollyanna here, but the world is just not nice enough lately. Hopefully we can make an incremental improvement…

History shows again and again how standards (and EPs) point out the folly of men…

It’s beginning to look like the proofreaders in Chicago must be enduring some late nights watching the Cubs! I don’t know about you folks, but I rely rather heavily on the regular missives from The Joint Commission, collectively known as Joint Commission E-Alerts. The E-Alerts deliver regular packages of yummy goodness to my email box (okay, that may be a little hyperbolic) and yesterday’s missive was no exception. Well, actually, there was an exception—more on that in a moment.

While it did not get top billing in the Alert (which seems kind of odd given what’s been going on this year), the pre-publication changes to the Life Safety chapter of the accreditation manual have been revealed, including comparison tables between what we had in January 2016 and what we can expect in January 2017. Interestingly enough, the comparison tables include the Environment of Care (EC) chapter stuff as well (though the EC chapter did not merit a mention in the E-Alert), so there’s lots of information to consider (which we will be doing over the course of the next little while) and some subtle alterations to the standards/EP language. For example (and this is the first “change” that I noted in reviewing the 112 pages of standards/EPs), the note for EC.02.02.01, EP 9 (the management of risks associated with hazardous gases and vapors) expands the “reach” to specifically include waste anesthetic gas disposal and laboratory rooftop exhaust (yes, I know…very sexy stuff!). It does appear that at least some of the changes (tough to figure out the split between what is truly “new” and what is merely a clarification of existing stuff—check out the note under EC.02.03.05, EP 1 regarding supervisory signal devices because it provides a better sense of what could be included in the mix). Another interesting change occurs under EC.02.03.05 (and this applies to all the testing EPs) is that where previously the requirement was for the completion dates of the testing to be documented, now the requirement actually states that the results of the testing are to be documented in addition to the completion dates. Again, a subtle change in the language and certainly nothing that they haven’t been surveying to. Oh, and one addition to the canon is the annual inspection and testing of door assemblies “by individuals who can demonstrate knowledge and understanding of the operating components of the door being tested. Testing begins with a pre-test visual inspection; testing includes both sides of the opening.” At any rate, I will keep plowing through the comparison table. (Remember in the old days, it would be called a crosswalk. Has the 21st century moved so far ahead that folks don’t know what a crosswalk is anymore?)

The top billing in yesterday’s All Hallows Eve E-Alert (making it an Eve-Alert, I suppose) went to the latest installment in that peppiest of undertakings, the Physical Environment Portal. Where the proofreaders comment comes into play is that the Alert mentions the posting of the information relative to LS.02.01.30, (which happened back in August) but when you click on the link, it takes you to the update page, where the new material is identified as covering LS.02.01.35, so there is updated material, though you couldn’t really tell by the Alert. So, we have general compliance information for the physical environment folks, some kicky advice and information for organizational leadership, and (Bonus! Bonus! Bonus!) information regarding the clinical impact of appropriately maintaining fire suppression systems (there is mention of sprinkler systems, but also portable fire extinguishers). I’d be interested to see if anyone finds the clinical impact information to be of particular use/effectiveness. I don’t know that compliance out in the field (or, more appropriately, noncompliance) is based on how knowledgeable folks are about what to do and what not to do, though perhaps it is the importance of the fire suppression systems and the reasons for having such systems (Can you imagine having to evacuate every time the fire alarm activates? That would be very stinky.) that is getting lost in the translation. I have no reason to think that the number of findings is going to be decreasing in this area (if you’re particularly interested, the comparison table section on LS.02.01.35 begins on p. 80 of that document—any changes that I can see do appear likely to make compliance easier), so I guess we’ll have to keep an eye on the final pages of survey year 2016 and the opening of the 2017 survey season. Be still my beating heart!

Everybody here comes from somewhere else…

First off, just wanted to wrap up on the missives coming forth from our compadres at The Joint Commission and ASHE relative to the adoption of the 2012 Life Safety Code® (LSC) by CMS. The word on the street would seem to be rather more positive than not, which is generally a good thing. Check out the statements from TJC and ASHE; also, it is useful to note that the ASHE page includes links to additional materials, including a comparison of the 2000 and 2012 editions of the LSC, so worth checking out.

At this point, it’s tough to say how much fodder there will for future fireside chats. It does appear that the adoption of the 2012, while making things somewhat simpler in terms of the practical designation of sleeping and non-sleeping suites (Don’t you wish they had “bumped” up the allowable square footage of the non-sleeping suites? Wouldn’t that have been nice.), combustible decorations and some of the other areas covered by the previously issued CMS categorical waivers (If you need a refresher, these should do you pretty well: ASHE waiver chart and Joint Commission), isn’t necessarily going to result in a significant change in the numbers and types of findings being generated during Joint Commission surveys. From my careful observation of all the data I can lay hands on, the stuff that they’re finding is still going to be the stuff that they are likely to continue to find as they are the “deficiencies” most likely to occur (going back to the “no perfect buildings” concept—a lovely goal, but pretty much as unattainable as Neverland). I’m not entirely certain what will have to occur to actually bring about a change in EC/LS concerns predominance on the Top 10 list; it’s the stuff I can pretty much always find (and folks usually know when I’m coming, so I’ve pretty much lost the element of surprise on the consulting trail). Now, it may be that the new matrix scoring methodology will reduce the amount of trouble you can get into as the result of existing deficiencies—that’s the piece of this whole thing that interests me the most—but I see no reason to think that those vulnerabilities will somehow eradicate themselves. I suppose there is an analogy relative to the annual review of our hazard vulnerability analysis (HVA)—the vulnerabilities will always exist—what changes (or should change) is our preparedness to appropriately manager those vulnerabilities. Makes me wonder if it would be worth doing an EC/LS HVA kind of thing—perhaps some sage individual has already tackled that—sing out if you have. At any rate, I’ll be keeping a close eye on developments and will share anything I encounter, so please stay tuned.

Hopping over to the bully pulpit for a moment, I just want to rant a bit on what I think should be on the endangered species list—that most uncommon of beasties—the kind and decent person. I know that everyone is nice to folks they know (more or less), but there seems to be a run on a certain indifference to politeness, etc., that, to be honest, makes me see a little read from time to time. But then I think to myself that it is probably just as rude to overreact to someone else’s rudeness, so take some deep cleansing breaths and let it go. Now I would love to hear from folks that they haven’t noticed this shift and that their encounters with folks are graced with tolerance, kindness, etc.; it would do my heart good. Maybe it’s just me…but somehow I’m thinking maybe not.

Please enjoy your week responsibly and we’ll see what mischief we can get into next week.

News flash: Vacuum cleaner sucks up budgie! Is you is or is you ain’t my baby?

As we continue our crawl (albeit an accelerated one) towards CMS adoption of the 2012 edition of NFPA 101 Life Safety Code® (LSC), we come face to face with what may very well be the final step (or in this case, leap) in the compliance walkway. While there is some language contained in the final rule (and in the press release) that I feel is a little contradictory (but after all, it is the feds), the summary section of the final rule does indeed indicate that “(f)urther, this final rule will adopt the 2012 edition of the Life Safety Code (LSC) and eliminate references in our regulations to all earlier editions of the Life Safety Code. It will also adopt the 2012 edition of the Health Care Facilities Code, with some exceptions.” I suspect that there will be multiple machinations in the wake of this, but it does appear that (cue the white smoke) we have a new pope, er, Life Safety Code®! You can find all 130+ pages here.

Interestingly enough, the information release focuses on some of the previously issued categorical waivers seemingly aimed at increasing the “homeyness” (as opposed to homeliness) of healthcare facilities (primarily long-term care facilities) to aid in promoting a more healing environment. It also highlights a couple of elements that would seem to lean towards a continuation of the piecemeal approach used to get us to this point, so (and again, it’s the feds), it’s not quite framed as the earth-shattering announcement that it appears to be:

  • Healthcare facilities located in buildings that are taller than 75 feet are required to install automatic sprinkler systems within 12 years after the rule’s effective date. So, the clock is ticking for you folks in unsprinklered tall buildings
  • Healthcare facilities are required to have a fire watch or building evacuation if their sprinkler system is out of service for more than 10 hours. So, a little more flexibility on the ILSM side of things, though that building evacuation element seems a little funky (not necessarily in a bad way).
  • For ambulatory surgery centers (ASC), all doors to hazardous areas must be self-closing or must close automatically. To be honest, I always considered the requirements of NFPA 101-2000: to be applicable regardless of occupancy classification, but hey, I guess it’s all in the eye of the beholder.
  • Also, for ASCs, you can have alcohol-based hand rub dispensers in the corridors. Woo hoo!

I guess it will be interesting to see what happens in the wake of this final rule. I guess this means we’ll have to find something else upon which to fret…

As a related aside, if you folks don’t currently subscribe to CMS News, you can sign up for e-mail updates by going to the CMS homepage and scrolling down to the bottom of the page. I will tell you that there’s a lot of stuff that is issued, pretty much on a daily basis, much of it not particularly germane to the safety community, but every once in a while…

It’s a new dawn, it’s a new day, it’s a new life for you. What do you plan on doing now?

News flash: Vacuum cleaner sucks up budgie!

Actually, the news is even bigger than that: it appears that the CMS machine is churning inexorably towards adoption of the 2012 edition of NFPA 101, Life Safety Code. While the last year or so has seen plenty of tidbits (in the form of waivers) tossed our way, the day we’ve been waiting for is finally upon us. There will be plenty of opportunities for in-depth analysis (minimally, TJC is going to have to reconfigure the accreditation manuals to reflect the changes; just when I had memorized the standard and EP numbers…drat!), but I think the main focus for folks is to weigh in on how this is all going to shake out over the next 12 to 18 months.

Fortunately, the powers that be are allowing a two-month comment period that is scheduled to end on June 16, 2014 (everything should be finalized for CMS in about a nine to 12-month timeframe following the close of the comment period). The proposed rule is available for viewing, at which point you can download the proposed rule in its entirety (and it is, as one might suspect, a pretty entire entirety, which is not so very far from decomposing composers, but I digress). There is much information to digest, and again, we’ll have some time to watch how this whole thing comes to fruition. But once again, it’s important to do the reading ahead of time. Confab with your engineering colleagues at the local, state, regional, and national levels; this may very well be the most sweeping change we’re likely to see in the practical application of the Life Safety Code in our hospitals and other healthcare facilities. Make sure everyone with a voice can be heard in the discussion!