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And the wind blew the echoes of long faded voices: Some Emergency Management thoughts…

While the year seemed to start out relatively quietly on the emergency front (relative being a completely relative and arbitrary term—and perhaps never more so than at the moment), it appears that the various and sundry forces of nature (and un-nature) are conspiring to send 2018 out with a bang. From wildfires out West to curiously damp weather patterns in the East to some funky temperature swings in the middle, it seems preparedness levels are as critical an undertaking as ever (and frequently coming nowhere close to being over-resourced, but I guess there’s no reason that the “do more with less” mantra wouldn’t extend to the EM world), with a likely follow-up of focus by the accreditation preparedness panjandrums (more this than this, but I’m fine with either). And one area of vulnerability that I see if the regulatory noggins should swivel in this direction relates to improvements in educating folks on an ongoing basis (the Final Rule says annual, so that determines a baseline for frequency), including some sort of evidence that what you’re doing is effective. (I see lots and lots of annual evaluations that track activities/widgets without getting down to a means of determining effectiveness—another improvement opportunity!) The other “shoe” that I fear might drop is the inclusion of all those care sites you have out in the community. There are very (very, very) few healthcare organizations that are comprised of a single standalone facility; over time, acquisitions of physician practices and other community-based healthcare delivery settings have increased the complexity of physical environment compliance, including emergency management stuff. I don’t know that I’ve run into anyone who couldn’t somehow, to one degree or another, point to participation of the offsite care locations. But it typically comes as, if not quite an afterthought, then a scenario that kind of “grafts” the offsites into the exercise. And, much as I wish community exercises would include testing of response activities in which the hospital acts in a diminished or non-capacity (there’s always this sense that we’ll just keep bringing folks to the local ED), some of the events of this year have really impacted ready access to hospital services for communities. At any rate, if you have thoughts on how you are (or could be) doing a good/better job at testing preparedness across your whole healthcare network, I am all ears and I suspect that there might be some other attentive ears as well.

In closing for this week (a little late, but this truly shouldn’t be tied to just one day or week), my thanks to all that have served in the armed forces: past, present, and future. Your sacrifices continue to mean so much to our lives and I cannot thank you enough (but with the annual Day of Thanks coming up next week, I will surely try)!

Odds and Sods: Clearing out the Safety Brain

Once again, I come face-to-face with my depository for blog postings and the like, so we have something of a mixed bag this week, with very little in the way of a common theme…

I’m sure folks saw the news story regarding the dead woman found in a stairwell of a hospital power plant and it got me to thinking about the increasing importance of ensuring that all your unmonitored perimeter points are as secure as they can be. It appears that the woman was able to gain access to the stairwell and was either too confused or otherwise compromised to make her way back out. The hospital has since hardened the perimeter of the power plant, but I think this points out that you really need to encourage folks to be on the lookout (security rounds can really only go so far) for unusual circumstances/ folks in their environments. It may be that there was nothing that could be done to prevent this tragedy, but I think it serves as a reminder that you really can’t be too secure.

As something of a parallel pursuit, HCPro recently re-aired a webinar presented my good friend and colleague Ken Rohde on the topic of occurrence reporting and its impact on operations, including the safety realm. Ken is an awesome presenter with a completely useful take on how safety operations impact, and are impacted, by how we manage occurrence reporting, particularly as a source of data for making improvements. If you have some monies in your budget for education, I really encourage you to check out the On-Demand presentation and let Ken help you improve your safety program.

In other parts of my noggin, I was looking at the crosswalk that TJC provides in the online version of their accreditation manual and was contemplating what is referenced as the applicable CMS requirement that “drives” the documentation requirements under EC.02.03.05 EP #28. In all candor, what prompted me to look was this nagging feeling that there are a lot of other required process documentation elements in other parts of the Environment of Care standards and whether there is a likelihood of those documentation requirements being carried over to things like generator testing, medical gas and vacuum system testing, etc. (for you pop culture enthusiasts, I consulted the magic 8 ball and it says “signs point to yes”; for those of you not yet familiar with the amazing technology that is the Magic 8 Ball, find more here). And when I looked at the TJC/CMS crosswalk, I noted that not only is the Life Safety Code® invoked as a referenced requirement, but also the Emergency Preparedness Condition as a function of the provision of alternate sources of energy for maintaining fire detection, extinguishing, and alarm systems. It may not be an imminent shift, but I think you would do well to consider adopting the documentation format outlined under EC.02.03.05 EP #28—it will help organize compliance and maybe, just maybe, keep you a half-step ahead of the sheriff…

On a closing note, I have (yet another) summer reading recommendation for folks: I think we can all agree that the use of effective communications is one of the most powerful tools that we can bring to our safety practices. As you all know every well (I’ve been inflicting this on you all for many, many…), I do tend towards more florid descriptors (that’s one there; I mean who uses “florid” anymore?), which can make comprehension difficult across a multi-faceted audience if you do not take into consideration the entirety of the audience. At any rate, I recently finished Alan Alda’s latest If I Understood You, Would I Have This Look on My Face?, which deals with the science of communications and provides a lot of thought-provoking suggestions on how we might improve the effectiveness of interpersonal communications at every level of life. For me, the most compelling insight was the notion that is the responsibility of the person doing the communicating to make sure that the audience is comprehending what is being communicated. That prompted me to reflect on any number of conversations I’ve had over the years, more or less revolving around the frustration with an audience that “just doesn’t get it” and the thought that perhaps the audience (in all its parameters) merits more consideration when things don’t work out in the way it was planned. At any rate, I found a lot of interesting perspectives on communications and (it’s a pretty quick read) I think you might find a nugget or two for your own use.

With a purposeful grimace and a terrible sound: Even more emergency management!

As much as I keep promising myself that I’ll poke at something more varied, the news of the day keeps turning back in the direction of emergency preparedness, in this case, just a little bit more on the subject of continuity of operations planning (COOP).

Late last week, our friends in Chicago proffered the latest (#41) in their series of Quick Safety (QS) tips, which focuses on elements of preparedness relating to COOPs (nobody here but us chickens). Within the QS tip (small pun intended), our Chicagoan overlords indicate that “continuity of operations planning has emerged as one of the issues that…need to address better in order to be more resilient during and after the occurrence of disasters and emergencies.” The QS also indicates a couple of best practice focus areas for COOPs:

  • Continuity of facilities and communications to support organizational functions.
  • A succession plan that lists who replaces the key leader(s) during an emergency if the leader is not available to carry out his or her duties.
  • A delegation of authority plan that describes the decisions and policies that can be implemented by authorized successors.

Now, I will freely admit that I always thought that this could be accomplished by adopting a scalable incident command structure, with appropriate monitoring of critical functions, inclusive of contact information for folks, etc. And, to be honest, I’m not really sure that having to re-jigger what you already have into something that’s easy for surveyors to discern at the 30,000-foot survey level is going to make each organization better prepared. I do know that folks have been cited for not having COOPs, particularly as a function of succession planning and delegation of authority (again, a properly structured HICS should get you most of the way there). So, I guess my advice for today is to figure out what pieces of your current EOP represent the COOP requirements and highlight them within the document (I really, really, really don’t want you to have to extract that stuff and create a standalone COOP, but if that helps you present the materials, then I guess that’s what you’d have to do…but I really don’t like that we’ve gotten to this point). At any rate, the QS has lots of info, some of it potentially useful, so please check it out here.

As a closing thought: I know folks are working really diligently towards getting an active shooter drill on the books, with varying degrees of progress. As I was perusing various media offerings, I saw an article outlining the potential downsides of active shooter-type drills. While the piece is aimed at the school environment, I think it’s kind of an interesting perspective as it relates to the practical impact of planning and conducting these types of exercises. It’s a pretty quick read and may generate some good discussion in your “house.”

There’s always someone looking at you: More emergency preparedness!

Once again, we tread the halls of emergency preparedness in search of context for some recent developments. I guess it is not inappropriate that this has become a more frequently touched upon subject, but I am hopeful that the weather patterns of last summer remain a distant memory, though the current situation in Hawaii does give one pause as a function of shifting likelihoods. At any rate, sending positive thoughts and vibrations to the folks in our 50th state in hopes that the tectonic manifestations will slow to a reasonable level.

First up, a couple of words about the recent unveiling of NFPA 3000 Standard for an Active Shooter/Hostile Event Response (ASHER) Program. I have no doubt that any number of you have been working very diligently towards establishment of an ASHER Program within your organizations. And I suspect that you have encountered some of the same resistors when it comes time to try and actually conduct a practical exercise to see how effective (or not) the response might be (I can’t think of too many other exercise scenarios that could be more potentially disruptive to normal operations, but I think therein lies the most compelling reasons for wanting/needing to exercise this scenario). I’ve participated in/monitored a couple of these exercises and I will tell you firsthand that it’s tough to get really good results on that first try. Folks are nervous and tentative and there’ll be a whole host of folks who won’t be as inclined to participate in the exercise as you might want (and really don’t seem too concerned when they fall victim to the shooter—there is nothing quite like the indifference that can be experienced during these types of exercises), but you really must forge on. To my mind, beyond the likely survey scrutiny driven by the Sentinel Event Alert, this type of scenario falls squarely in the realm of “most likely to experience, least well prepared to respond” and the longer it takes to begin making substantive changes to your response plan—based on actual data generated through exercises—the further behind the curve it will be if there is an event in your community (an event that has become increasingly likely, pretty much no matter where you are).

As to the standard, I don’t know that NFPA 3000 brings anything particularly new to the party, but it does provide a codified reference point for a lot of the work we’re already doing. You need only to check out the table of contents for the standard to see some familiar concepts—risk assessment, planning/coordination, resource management, incident management, training, etc. I do think that where this will become most useful as a means of further integration of our preparedness and planning activities with those of our local community(ies). We need to be/get better prepared to respond to the chaos that is integral to such an event and hopefully this will provide common ground for continued program growth.

As an aside relative to all things EM, there is an indication that our friends from Chicago are starting to kick the tires a little more frequently when it comes to ensuring that all the required plan elements are in place. There is a truism that the survey tends to focus more on what has changed than on what has remained the same, as we’ve noted in the past, TJC has added a few things to the mix, so you want to make sure you have:

  • Continuity of operations planning, including succession planning and delegation of authority during emergencies
  • A process for requesting (and managing) an 1135 waiver to address care and treatment at an alternate care site
  • A plan/process for sheltering patients, staff, and visitors during an emergency, as applicable
  • Evidence that all your outlying clinic, etc., settings have participated in your emergency response exercises or actual events

I know there are instances in which some of these might not apply, but you need to be very diligent in outlining how and why these elements would not be applicable to your organization. I think the only one noted above that really could be dependent on your organization is if you don’t have any care locations outside of your main campus. But beyond that, all those other elements need to be in a place that the surveyors can find them. And don’t be afraid to reiterate the language in the applicable individual performance elements—fleshing out the process is a good idea, but you want them to be able to “see” how what you have in your plan reflects what is being required. I continue to maintain that hospitals do a very good job when it comes to emergency management, but there is also always room for improvement. I don’t want our improvement processes to get derailed by a draconian survey result, so make sure the “new” stuff has been captured and added to your Emergency Operations Plan (EOP).

’Tis the season…for more emergency management goodness!

Recognizing the somewhat hyperbolic nature of this week’s headline (you need only listen to current news/weather feeds to be able to determine that emergencies are not quite as seasonal as perhaps they once were…), I did want to share one more emergency management-related nugget with you (I do try to mix things up, but until I start seeing some “hard” survey results—or some regulatory panjandrum makes some sort of announcement, I’m going to keep seeding this space with various and sundry bits of stuff), this coming to us from the left coast, aka California.

While I have little doubt that you Californians in the audience are familiar with the California Department of Public Health (CDPH—four scary letters, though perhaps not as scary as OSHPD for the facilities folks in Cali) requirements for workplace emergency plans (which is highlighted in this month’s CDPH Occupational Health Watch), I think that there might well be some useful information for folks in other parts of the country (I have found, over some few years of experience, that regulatory tsunamis can start in California and find their way to all manner of locales). To be honest (and why else would we be here?), the plan elements required (or at least the ones the surveyors want to see) by the usual regulatorily-inclined suspects, are frequently not quite as useful from an operational preparedness/mitigation/response/recovery standpoint (they provide a useful structure for the aforementioned quartet, but when it comes down to doing the do, again, sometimes not so much).

At any rate, the Cal/OSHA Emergency Action Plan requirements, provide (at least in my mind—feel free to disagree) a good basic sense of the pieces to have in place that are not necessarily as patient-focused. When the fecal matters starts impacting the rapidly rotation turbine blades, it’s important to have a structure in place that addresses the employee aspect, particularly for those of you with offsite non-clinical operations (billing, finance, HR, etc.: a lot of folks don’t have enough space at the main campus for all the moving pieces that constitute a healthcare organization). So, here’s the California stuff (and please feel free to share any good stuff your state might have on the books—this is all about getting prepared and staying prepared—every little bit helps):

(b) Elements. The following elements, at a minimum, shall be included in the plan:

(1) Procedures for emergency evacuation, including type of evacuation and exit route assignments;

(2) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate;

(3) Procedures to account for all employees after emergency evacuation has been completed;

(4) Procedures to be followed by employees performing rescue or medical duties;

(5) The preferred means of reporting fires and other emergencies; and

(6) Names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan.

(c) Alarm System.

(1) The employer shall establish an employee alarm system which complies with Article 165 (link to that info here).

(2) If the employee alarm system is used for alerting fire brigade members, or for other purposes, a distinctive signal for each purpose shall be used.

(d) Evacuation. The employer shall establish in the emergency action plan the types of evacuation to be used in emergency circumstances.

(e) Training.

(1) Before implementing the emergency action plan, the employer shall designate and train a sufficient number of persons to assist in the safe and orderly emergency evacuation of employees.

(2) The employer shall advise each employee of his/her responsibility under the plan at the following times:

(A) Initially when the plan is developed,

(B) Whenever the employee’s responsibilities or designated actions under the plan change, and

(C) Whenever the plan is changed.

(3) The employer shall review with each employee upon initial assignment those parts of the plan which the employee must know to protect the employee in the event of an emergency. The written plan shall be kept at the workplace and made available for employee review. For those employers with 10 or fewer employees the plan may be communicated orally to employees and the employer need not maintain a written plan.

 

I hope this provides you with some useful (and perhaps even thoughtful) information as we roll through emergency year 2018. I am hoping for a time of minimal impact for communities this year (I think we had just about enough last year), but the oddness of the weather patterns over the past couple of months gives me pause. (I live in the Boston area and Houston and its environs had snow before we did!)

Emergency Management Monkeyshines: All Things Must Pass…

Sometimes like a kidney stone, but nonetheless…

Before we dive into this week’s “content,” I have a thought for you to ponder as to the nature of basing future survey results on the results of surveys past (rather Dickensian, the results of surveys past): Recognizing that authorities having jurisdiction (AHJ) always reserve the right to disagree with any decision you’ve ever made or, indeed, anything they (or any other AHJ) have told you in the past, how long are existing waivers and/or equivalencies good for? Hopefully this ponderable will not visit itself upon you or your organization, but one must be prepared for any (and every) eventuality. Which neatly brings us to:

In digging around past emails and such, I noticed that I had not visited the Department of Health and Human Services Healthcare Emergency Preparedness Gateway in rather a while and what to my wondering eyes should appear but some updated info and a link to CMS that I think you’ll find useful. So, the current headlines/topics:

  • Considerations for the Use of Temporary Care Locations for Managing Seasonal Patient Surge
  • Pediatric Issues in Disasters Webinar
  • 2017 Hurricane Response – Resources for Children with Special Health Care Needs
  • Supporting Non-resident/Foreign Citizen Patients
  • A new issue of The Exchange newsletter
  • A link to the CMS Emergency Preparedness Final Rule surveyor training (you can find the information available to providers here). Unfortunately, the post-test is not available to providers, but sometimes it’s like that.

It is my intent over the next little while to check out the education package, so I will let you know if I have any grave reservations about the content, etc., or if I think you need to earmark it for priority viewing.

So, kind of brief this week, but I’m sure there’ll be more to discuss in the not too distant future. And so, with the end of wintah on the horizon, I wish you a moderately temperate week!

Oh, what fresh hell is this?

Much as 2016 has laid waste to the pantheon of pop culture, so has it decimated the status quo in the realm of facilities and safety management. While this year has brought “pleasures” expected (adoption of the 2012 edition of the Life Safety Code®) and unexpected (the demise of the Plan for Improvement process), it appears that the wheels (gears?) that drive this regulatory machine are not yet done churning out new stuff for us to ponder.

As you’ve probably heard by now, last week CMS finally dropped the mike on the federal requirements relating to emergency management and the healthcare world. (Press release can be found here; link to the final rule–the hospital requirements start on p. 584 of this oh so fabulous 651-page document. Monsieur Needle, please meet Monsieur Haystack…zut alors!)

Let’s do a quick run-through of the four primary components:

  • You have to have an emergency preparedness plan that must be reviewed and updated at least annually.
    • The plan must be based on, and include, a documented facility-based and community-based risk assessment, utilizing an all-hazards approach.
    • The plan must include strategies for addressing emergency events identified by the risk assessment, utilizing an all-hazards approach.
    • The plan must address patient population, including, but not limited to, persons at-risk; the type of services the hospital has ability to provide in an emergency; and continuity of operations, including delegations of authority and succession plans.
    • The plan must include a process for cooperation with the various AHJs’ efforts to maintain an integrated response during a disaster or emergency situation, including documentation of the hospital’s efforts to contact such officials, and when applicable, its participation in collaborative and cooperative planning efforts.
  • Develop emergency preparedness policies and procedures that must be reviewed and updated at least annually. The policies and procedures must address the following:
    • The provision of subsistence needs for staff and patients, whether they evacuate or shelter in place, include, but are not limited to the following:
      • Food, water, medical, and pharmaceutical supplies.
      • Alternate sources of energy to maintain the following:
        • Temperatures to protect patient health and safety and for the safe and sanitary storage of provisions.
        • Emergency lighting.
        • Fire detection, extinguishing, and alarm systems.
        • Sewage and waste disposal.
        • A system to track the location of on-duty staff and sheltered patients in the hospital’s care during an emergency. If on-duty staff and sheltered patients are relocated during the emergency, the hospital must document the specific name and location of the receiving facility or other location.
        • Safe evacuation from the hospital, which includes consideration of care and treatment needs of evacuees; staff responsibilities; transportation; identification of evacuation location(s); and primary and alternate means of communication with external sources of assistance.
        • A means to shelter in place for patients, staff, and volunteers who remain in the facility.
        • A system of medical documentation that preserves patient information, protects confidentiality of patient information, and secures and maintains the availability of records.
        • The use of volunteers in an emergency and other emergency staffing strategies, including the process and role for integration of State and Federally designated healthcare professionals to address surge needs during an emergency.
        • The development of arrangements with other hospitals and other providers to receive patients in the event of limitations or cessation of operations to maintain the continuity of services to hospital patients.
        • The role of the hospital under a waiver declared by the Secretary, in accordance with section 1135 of the Act, in the provision of care and treatment at an alternate care site identified by emergency management officials.
      • Develop and maintain an emergency preparedness communication plan that must be reviewed and updated at least annually, which includes names and contact information for the following:
        • Staff
        • Entities providing services under arrangement
        • Patients’ physicians
        • Other hospitals and CAHs
        • Volunteers
      • The communications plan must also include contact information for the following:
        • Federal, state, tribal, regional, and local emergency preparedness staff
        • Other sources of assistance
      • The communications plan must identify primary and alternate means for communicating with the following:
        • Hospital’s staff
        • Federal, state, tribal, regional, and local emergency management agencies
      • The communications plan must provide a method for sharing information and medical documentation for patients under the hospital’s care, as necessary, with other healthcare providers to maintain the continuity of care.
      • The communications plan must provide a means, in the event of an evacuation, to release patient information as permitted under 45 CFR 164.510(b)(1)(ii).
      • The communications plan must provide a means of providing information about the general condition and location of patients under the facility’s care as permitted under 45 CFR 164.510(b)(4).
      • The communications plan must provide a means of providing information about the hospital’s occupancy, needs, and its ability to provide assistance, to the authority having jurisdiction, the Incident Command Center, or designee.
    • Develop and maintain an emergency preparedness training and testing program that is reviewed and updated at least annually.
      • The training program must provide for:
        • Initial training in emergency preparedness policies and procedures to all new and existing staff, individuals providing services under arrangement, and volunteers, consistent with their expected role
        • Emergency preparedness training at least annually
        • Maintenance of documentation of the training
        • Demonstration of staff knowledge of emergency procedures
      • The testing program must provide for:
        • Participation in a full-scale exercise that is community-based or when a community-based exercise is not accessible, an individual, facility-based. If the hospital experiences an actual natural or man-made emergency that requires activation of the emergency plan, the hospital is exempt from engaging in a community-based or individual, facility-based full-scale exercise for one year following the onset of the actual event.
      • Conduction of an additional exercise that may include, but is not limited to the following:
        • A second full-scale exercise that is community-based or individual, facility-based
        • A tabletop exercise that includes a group discussion led by a facilitator, using a narrated, clinically-relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan
      • Analysis of the hospital’s response to and maintain documentation of all drills, tabletop exercises, and emergency events, and revise the hospital’s emergency plan, as needed.

To be honest, at first blush, I don’t see anything of particularly dire consequence (feel free to disagree; I’m always up for some civil—or uncivil—discourse) unless you’ve done a less-than-complete job of documenting your communications with the various and sundry AHJs (“The plan must include a process for cooperation with the various AHJs’ efforts to maintain an integrated response during a disaster or emergency situation, including documentation of the hospital’s efforts to contact such officials, and when applicable, its participation in collaborative and cooperative planning efforts.”). In fact, it will be interesting to see if TJC backs off of their caveat that tabletops don’t count towards the annual exercise requirement though, as you can see, the tabletop must include some very specific elements.

There is some additional language relating to provisions for stand-by and emergency power that includes providing for generator locations when you build new or renovate (who wants an emergency generator that could end up under water?); maintaining fuel sources during an emergency; testing components in accordance with requirements, etc., but, again, I’m not seeing a lot of indigestion-inciting language. I suppose it is possible that, at the end of all this (I mean, what’s left to tweak), there will be enough certainty in the regulatory fabric to promote a consistent application of the standards, etc. during surveys. Wouldn’t that be nice…

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.

Get the heck out of there!

Touching back on the proposed CMS rule regarding emergency preparedness and hospitals, within the torrent of verbiage, the Federal Register information refers to a hospital evacuation decision guide that’s available through the AHRQ website (just so you know, there is a fairly gloomy caution that the information may be out of date, etc. I’m extremely glad that CMS is using potentially outdated information to promulgate new requirements. Perhaps that’s a wee bit too ironic…). In looking over the materials, I don’t know that the contents are so woefully out of date as to be useless. On the contrary, I think there’s a lot of helpful stuff; while there have been some evacuation-worthy events since June 2011 when this information was last vetted for currency, I’m thinking that the historical precedents in place at the time (Katrina, etc.) would drive a refinement of planning and preparedness as opposed to a wholesale revamping of concepts relating to evacuation of hospitals in response to emergencies.

Have folks out there been using this information? If so, has it been of particular use? Inquiring minds want to know!

It was the worst of times, it was the worst of times—or perhaps not

It appears that we are soon to be basking in the presence of an interesting confluence. It appears that CMS is looking very closely at requiring hospitals to conduct four-hour generator tests every year. Don’t know that that is a particularly surprising development given the focus on the reliability of emergency power, though I’m not sure how much the brain trust for NFPA 110 was consulted in this regard. At any rate, you will definitely want to take a look at the Federal Register for December 27, 2013 for the proposed rules (the emergency generator piece can be found on pages 79173-4, but the whole proposed rule has to do with hospitals and emergency preparedness; I suspect we’ll be chatting about this stuff for a while). Go to the Federal Register webpage where you can download the PDF of the proposed rule (and get yourself some snacks, it’s 120 pages long). The comment period ends on February 25, so you might want to get in on the action, the options for commenting are on the webpage.

Moving on to the other piece of this lovely regulatory (governmental?) maelstrom, we have the EPA, which is enacting fairly significant requirements for emergency generator emissions (you can find a story on this topic from Health Facilities Management magazine). You can find more information about the specifics of the emissions requirements at the EPA website.

It appears that we will be looking at additional generator testing with stricter emissions requirements—sounds like way too much fun!