RSSAll Entries Tagged With: "emergency power"

Waste not, want not: The rest of the CMS Emergency Preparedness picture

Moving on to the rest of the guidance document (it still lives here), I did want to note one last item relative to emergency power: There is an expectation that “as part of the cooperation and collaboration with emergency preparedness officials,” organizations should confer with health department and emergency management officials, as well as healthcare coalitions to “determine the types and duration of energy sources that could be available to assist them in providing care to their patient population. As part of the risk assessment planning, facilities should determine the feasibility of relying on these sources and plan accordingly.

“NOTE: Hospitals, CAHs and LTC facilities are required to base their emergency power and stand-by systems on their emergency plans and risk assessments and including the policies and procedures for hospitals. The determination of the appropriate alternate energy source should be made through the development of the facility’s risk assessment and emergency plan. If these facilities determine that a permanent generator is not required to meet the emergency power and stand-by systems requirements for this emergency preparedness regulation, then §§482.15(e)(1) and (2), §483.73(e)(1) and (2),

  • 485.625(e)(1) and (2), would not apply. However, these facility types must continue to meet the existing emergency power provisions and requirements for their provider/supplier types under physical environment CoPs or any existing LSC guidance.”

“If a Hospital, CAH or LTC facility determines that the use of a portable and mobile generator would be the best way to accommodate for additional electrical loads necessary to meet subsistence needs required by emergency preparedness plans, policies and procedures, then NFPA requirements on emergency and standby power systems such as generator installation, location, inspection and testing, and fuel would not be applicable to the portable generator and associated distribution system, except for NFPA 70 – National Electrical Code.”

I think it is very clear that hospitals, et al., are going to be able to plot their own course relative to providing power during emergency conditions, but what’s not so clear is to what depth surveyors will be looking for you to “take” the risk assessment. I suspect that most folks would run with their permanently installed emergency generators and call it a day, but as healthcare organizations become healthcare networks become healthcare systems, the degree of complexity is going to drive some level of flexibility that can’t always be attained using fixed generator equipment. If anyone has any stories to share on this front (either recent or future), I hope you’re inclined to share (and you can reach out directly to me and I will anonymize your story, if you like).

Wrapping up the rest of the changes/additions, you’ll be pleased to hear that you are not required to provide on-site treatment of sewage or waste, but you need to have provisions for maintaining “necessary services.” Of course, the memo indicates that they are not specifying what “necessary services for sewage or waste management” might be, so a little self-definition would appear to be in order.

If your organization has a home health agency, then you need to make sure that the communication plan includes all the following: (1) Names and contact information for the following: (i) Staff. (ii) Entities providing services under arrangement. (iii) Patients’ physicians. (iv) Volunteers. I think that one’s pretty self-evident but may be worth a little verification.

Next up are some thoughts about providing education to folks working as contracted staff who provide services in multiple surrounding areas; the guidance indicates that it may not be feasible for these folks to receive formal training for each of the facilities emergency response plan/program. The expectation is that each individual (and this applies equally to everyone else in the mix) knows the emergency response program and their role during emergencies, but each organization can determine how that happens, including what constitutes appropriate evidence that the training was completed. Additionally, if a surveyor asks one of these folks what their role is during a disaster, then the expectation would be for them to be able to describe the plan and their role(s). No big surprise there (I suspect that validating the competency of point-of-care/service staff is going to be playing a greater role in the survey process—how many folks would they have to ask before somebody “fumbles”?)

The last item relates to the use of real emergency response events in place of the required exercises; I would have thought that this was (relatively) self-evident, but I guess there were enough questions from the field for them to specify that you can indeed use a real event in place of an exercise. Just make sure you have the documentation in order (I know I didn’t “have” to say that, but I figure if it’s important enough for CMS to say it, then who am I…). The timing would be one year from the actual response activation, so make sure you keep a close eye on those calendars (unless, of course, you have numerous real-life opportunities…).

I do think the overarching sense of this is positive, at least in terms of limiting the prescriptive elements. As is sometimes the case, the “responsibility” falls to each organization to be prepared to educate the surveyors as to what preparedness looks like—it has many similar components, but how things integrate can have great variability. Don’t be afraid to do a little hand-holding if the surveyors are looking for something to be done a certain or to look a certain way. You know what works best in your “house,” better than any surveyor!

Power Up: When your generator doesn’t carry a 30% load

Particularly for smaller facilities (or, I suppose, big places with multiple generators), consistently meeting the requirement for a 30% load during monthly generator testing activities can be a bit of a chore. And it can result in having to consider performing an annual load test at increasing loads, which usually means that you have to contract out that extra load test (and they ain’t cheap, all things being equal).

But if you look at NFPA 110-2010, it does provide another means of complying with the monthly requirements. Section 8.4.2 indicates that “(d)iesel generator sets in service shall be exercised at least once monthly, for a minimum of 30 minutes, using one of the following methods:

  1. Loading that maintains the minimum exhaust gas temperatures as recommended by the manufacturer
  2. Under operating temperature conditions and at not less than 30 percent of the EPS standby nameplate KW rating

Note: The 2019 edition of NFPA 110 removes the word “diesel” for the text, which opens things up a bit for folks who don’t have diesel generators.

So, the trick becomes how best to capture the exhaust gas temperatures, so you are assured of a compliant test and not being at risk for wet-stacking during the generator test. Fortunately, when it comes to emergency power system information, there is no better source than the good folks at Motor & Generator Institute (MGI). Dan Chisholm and the folks at MGI have just the thing to get you started and even if you’re an experienced generator owner/operator, I would encourage you to check out the information here.

It might just give you a leg up on the survey process!

Do you miss the safety professional you once had time to be?

I think we can agree that things in the safety world are moving along at a pretty good clip, particularly when it comes down to ensuring ongoing compliance with the various and sundry nuances that are flowing forth from the regulatory firehose. Now I’m sure are those of you that would like nothing better than to pore over the various and sundry code handbooks to figure out best to apply the latest changes to your practices/organizations. But I can tell you this: That’s getting to be very close to a full-time job all on its own—and too many of the current generation of survey findings have as much to do with managing the behaviors of staff at point of care and point of service as they do in figuring out what interpretation is going to win the day going forward. So, as I hear of some findings that I would tend to characterize as “frequently cited,” I want to make sure that I share them with you. This week, here’s a couple of items relating to emergency power:

Under the standard dealing with the setup of your emergency power system, there is a “new” performance element that requires a remote manual stoop station (with identifying label) “to prevent inadvertent or unintentional operation.” The performance element also points toward having a remote annunciator (powered by a storage battery) outside the EPS location. Anecdotally, I understand this is coming up with a fair frequency out in California, so probably worth a look-see for your gen sets.

Under the standard dealing with the inspection, testing, and maintenance of emergency power systems, the weekly inspection (and associated documentation) finally shows up as a specific performance expectation, as does the annual fuel quality test (to ASTM standards, so please make sure that your documentation of those activities is up to date).

As a final note for this week; some updates to the behavioral healthcare Life Safety chapter considerations, mostly shifting the Life Safety Code® chapter references from Chapter 26 (Lodging or Rooming Houses) in the 2000 edition to Chapter 32/33 (new and Existing Residential Board and Care occupancies). The changes impact “small” facilities that provide sleeping arrangements for four to 16 individuals. I don’t see anything particularly substantive, or indeed troubling, in the new stuff, but if you feel otherwise after checking it out, then please sing out loud and clear.

Can one be too resourceful? I think not…

I generally don’t use this space as a means of promotion/marketing, but every once in a while, I like to share information on resources that I think could be really useful to the safety community. Certainly those of you who’ve been “with me” since the start of this journey in the blogosphere (way back in June 2007—oh, the places we have seen!) will have learned about resources, met some folks (my esteemed former Greeley colleague Brother Brad Keyes being a notable) and hopefully found various kernels of knowledge and insight that have somehow fostered a greater understanding and sense of community.

So, this posting I wanted to chat a bit about some gents in Florida who I have come to rely on for information and insight in the realms of emergency power and life safety compliance: Messrs. Dan Chisholm, Sr. and Dan Chisholm, Jr. I would encourage you all to visit their respective websites and sign up for email updates—always good stuff. The latest missives involve discussion of confusion over diesel fuel testing requirements on the emergency power side of things; and discussion of the conversion of patient rooms into combustible storage rooms and some considerations that can be expected with the adoption of the 2012 Life Safety Code® (Dean Samet of TSIG being a guest contributor for that article—way to go, Dean!)

All too frequently, compliance comes down to being able to account for the various and sundry interpretations of the codified landscape—and it never hurts to have a little expertise in your back pocket! So if you haven’t yet made their acquaintance, please check out Dan, Sr. and Dan, Jr. and bring their expertise into your practice. You’ll be glad you did!

Where will you be when the lights go out?

Now I don’t think that there’s any here among us who would be inclined to disagree with that as a going concern. The question I have is how might these requirements come into play when CMS adopts the 2012 edition of the Life Safety Code®? We know that CMS is looking very carefully at all things relating to emergency management/preparedness, including a fair amount of focus on the subject of emergency power. I think we can safely intuit that the broad-ish concept of grandfathering is fast becoming extinct. Thus, the question becomes (or perhaps this is really representative of two questions) what could be done now (and perhaps mandated to be done now) to reduce any existing EPSS installations that could be considered at risk (I’m presuming that you’ve all completed your risk assessments in this regard—if you haven’t, I think it would be a wicked swell idea to be jumping on that bandwagon ASAP)? The second prong being, what due diligence has been brought to bear in relation to any pending installations? I’m pretty certain that I would not want to have a brand spanking new generator get flooded out during the next deluge. At any rate, I am interested in finding out more about what you folks have been up to in this regard. I can’t imagine any endeavors in this realm having an inexpensive price tag, so I’m thinking about how folks might have had to, or will have to, sell these “ideas” to organizational leadership.

How long has this been going on?

We’re rounding the turn and headed for home – no squeeze play at the plate this time…I hope!

EC.02.05.09 – Inspection, testing and maintenance of medical gas and vacuum systems (#16, with 24% of hospitals having been cited)

It seems to me that we’ve discussed this in the past as well, but it appears that, in this survey year, everything bears repeating.

Anything that your medical gas and vacuum testing activities generate as deficiencies/recommendations/hints from Heloise/etc. needs to be accounted for somehow. Maybe your medical air intake is right next to an isolation exhaust, or it’s nothing more than a leaky outlet, or the issue is non-compliant construction (a favorite is the medical gas zone shutoff valve in the PACU with no intervening wall) that can wait until you do a remodel/renovation project. Whatever it is, you need to say, “This is what we’re doing about that, based on our assessment of the involved risks.” And don’t wait to get ahead of the curve on the fixes: As soon as the activity is completed you are on the hook for the fixes, so you need to know what’s on that list even before you get the pretty report. The clock starts ticking upon identification of the condition, so if you have to wait a month or 45 days for the report, you (and more importantly, your patients) are at some level of risk.

The other thing to do is make sure that your vendor is not using this process to drum up work; I can’t tell you how many times I look at multiple years of testing documentation and find the same “deficiency” over and over again – and then find out, well, it’s not really a deficiency at all. You will get slapped during a survey for this – if it’s a critical fix, then fix it, if it’s not a critical fix, then dot the “I’s” and cross the “t’s” and make sure they are accounted for.

Another component of this is obstructed access to zone shutoff valves, as well as making sure that the labeling of valves is accurate (areas served, contents of piping – labels have to be accurate, accurate, accurate). Also, make sure that what you are calling the area of coverage is in some sort of accordance with what the staff calls the area. I can’t tell you how many times that I’ve seen zone valves labeled in accordance with the architectural drawings and find out that front line staff really doesn’t know which areas are served by the valves. Knowledge is very powerful, and certain knowledge is an invaluable commodity during surveys.

EC.02.05.07 – Inspection, testing and maintenance of emergency power systems (#17, with 23% of hospitals having been cited)

Emergency generators and automatic transfer switches have to be tested in accordance with the requirements of EC.02.05.07 – if you need me to tell you what those are at this point, you may be in the wrong line of work. However, I am more than happy to answer any questions you might have regarding this most important subject. 30%, 30 minutes, no closer than 20, no greater than 40 between tests, run it for 4 hours at a minimum 30% load every 36 months – these are a few of my favorite things.

EC.02.03.01 – Management of fire risks (#20, with 19% of hospitals having been cited)

Breathing a sigh of relief, we’re near the end of our little journey through time and (interstitial) space.

This is another of those findings that it becomes a question of how far one must look before one can encounter enough deficiencies to drive an RFI (the answer in this case being 2). The question I have for you is this – how many junction boxes do you have in your facility. 100? 1,000? 10,000? So, the follow-up question is: How many would an individual (say, a Joint Commission Life Safety surveyor) have to look at before they found two that didn’t have a cover? There are so many opportunities to drop the ball on this one – mechanical spaces, comms closets (it’s very rare that I find an open j-box in an electrical closet – but not impossible). You know they’re going to look above the ceiling – and they’re not just looking for penetrations – and cabling on sprinkler piping – and, and…

You need to enlist the efforts of everyone who does work above the ceiling in your facility; they don’t necessarily have to fix it, but if you know where it is, then you have a shot at being able to address it before it gets ID’d during a survey. The proactive approach works unbelievably well for stuff like this.

And on the horizon looms the specter of a return to focus for the prevention of surgical fires – including the participation of physicians. Too many (and my stance is that one surgical fire is too many) surgical fires occur for my (or anyone’s) liking, so it’s time to kick this process into high gear. I know they’re busy, and may not always seem to be the most cooperative bunch on the planet, but this I see as a moral imperative (and it appears that TJC is similarly inclined – so if you won’t do it for me, do it for them). We can do a better job of educating folks about the risks of surgical fires – and so, we must do just that.

One other related thought is to make sure that you are appropriately managing amounts of compressed gas – don’t go over 12 e-cylinders in an unprotected area. And make sure that your gas storage rooms (for amounts greater than 300 cubic feet of gas) are appropriately fire-safe, etc.

This concludes our test of the emergency survey broadcasting system – this was only a test. We now return you to our regular programming, which is already in progress. If you have any questions or concerns about this or any other topic, you know where I am…

Is there any leeway to not test automatic transfer switches monthly?

I was asked whether there was any flexibility to test transfer switches at intervals less than normally prescribed. For example, might you be able to test low-risk transfer switches, such as those serving the kitchen, less frequently?

Let’s start with Joint Commission environment of care standard EC.02.05.07. EP 6 requires that, “Twelve times a year at intervals of not less than 20 days and not more than 40 days, the hospital tests all automatic transfer switches. The completion date of the test is documented.”

The key word here is “all,” and the key pain in the posterior is that [more]