Presenters Victor Hunt Sally Kimbrough-McAuley Tony Dunklin - - PDF document

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Presenters Victor Hunt Sally Kimbrough-McAuley Tony Dunklin - - PDF document

Jul 03, 2023 414 likes •723 views

2012 Life Safety Code Update June 20, 2016 REVISED CMS REGULATIONS AND THE 2012 NFPA CODES FIRE SAFETY REQUIREMENTS FOR NURSING HOMES Alabama Department of Public Health T echnical Services Unit Presenters Victor Hunt Sally

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 1

REVISED CMS REGULATIONS AND THE 2012 NFPA CODES

FIRE SAFETY REQUIREMENTS FOR NURSING HOMES

Alabama Department of Public Health T echnical Services Unit

Presenters

Victor Hunt Sally Kimbrough-McAuley Tony Dunklin

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 2

Change from 2000 Codes to 2012 Codes

  • The Centers for Medicare and Medicaid

Services (CMS) published announcement

  • n May 4, 2016
  • Adoption of National Fire Protection

Association (NFPA) codes and referenced standards

  • Adoption of 2012 Life Safety Code includes

T entative Interim Amendments (TIA) 12-1 through 12-4.

  • Adoption of 2012 NFPA 99 Health Care

Facilities Code, excluding chapters 7, 8, 12, and 13. Includes TIAs 12-2 through 12-6. www .nfpa.org, “Codes and Standards,” “List of Codes and Standards,” select code, “Editions,” 2012

2000 Codes to 2012 Codes 2000 Codes to 2012 Codes

  • Compliance required on July 5, 2016
  • Chapter 18, New Healthcare Occupancies

– Plan approval by ADPH on or after July 5

  • Chapter 19, Existing Healthcare

Occupancies

– All facilities constructed prior to July 5 – Plan approval by ADPH prior to July 5

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 3

Building Rehabilitation

  • 2000 LSC – Alterations, renovations,

additions, and new equipment meet requirements for NEW (paragraph 4.6.7)

  • 2012 LSC – Comply with Chapter 43,

Building Rehabilitation

Building Rehabilitation

Chapter 43 Work Categories

  • Repair
  • Renovation
  • Modification
  • Reconstruction
  • Change of use or occupancy classification
  • Addition

Means of Egress

Comply with Chapter 7 Applies to New and Existing Buildings, per 7.1.1

Construction Projects

LSC 19.7.9.2 Not new Means of egress in construction areas shall be inspected daily for availability for full instant use in case of an emergency.

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 4

Emergency Hardware

  • Fire Exit Hardware only on fire-rated doors

– Latch holding device never permitted (dogging, or dogged down)

  • Panic Hardware only on doors not fire-

rated

– Dogging, or dogged down, is permitted

Per LSC 7.2.1.7

Electric Hardware

  • n Egress Doors

New , per LSC 7.2.1.5.6

Electric hardware permitted in means of egress:

  • 1. Hardware mounted on door leaf
  • 2. Obvious operation in direction of egress (panic)
  • 3. Operable with one hand in direction of egress
  • 4. Hardware operation interrupts power to electric

lock

  • 5. Loss of power to hardware unlocks door
  • 6. Hardware listed per ANSI/UL 294

Key, key pad, or card reader not allowed on egress side of door.

Stairway Identification

LSC 7.2.2.5.4

  • Requirements for special stair signage

apply to -

– Existing enclosed stairs serving 5 or more stories – New enclosed stairs serving 3 or more stories “Story” includes basement level.

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 5

Stairway Identification

See LSC 7.2.2.5.4.

  • 13 Requirements
  • Additional contents
  • Lettering minimum heights
  • Illumination by emergency

lighting

  • T

actile designation (Braille) for floor level number

Means of Egress Lighting

LSC 7.8.1.2 and 7.8.1.2.2

  • Illumination must be continuous during

periods when needed.

  • Can be controlled by automatic motion

sensor-type switches.

  • 5 conditions are listed (3 conditions in 2000

Life Safety Code)

Delayed-Egress Locks

LSC 19.2.2.2.4

  • 2000 LSC – “not more than one . . . in any

egress path” Deleted in 2012 LSC. Comply with Section 7.2.1.6.1

  • Emergency lighting on egress side of the

door (new requirement)

  • Accurately reflect delay time on the sign

(not new)

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 6

Door Locking for Security

LSC 19.2.2.2.5.1

  • Patients require specialized security
  • r pose a security threat.
  • LSC Handbook: “addresses the locking of

sleeping room doors”

  • Doors released manually by staff

– Remote control (kill switch), or – Keying locks to keys carried by staff

  • No change from 2000 Life Safety Code

Staff and Locked Doors

LSC 19.7.3.2 Requires “adequate staff qualified to release locks and direct occupants from the immediate danger area”

Door Locking for Safety

LSC 19.2.2.2.5.2

  • Patients require specialized protective

measures for their safety.

  • New provision, not in 2000 Life Safety

Code

  • Corresponds to ADPH “Exit Door Locking

Arrangements” article

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 7

Door Locking for Safety

LSC 19.2.2.2.5.2

  • 1. Staff can readily unlock doors at all times.
  • 2. Emergency release switch (kill switch).

ADPH requires sign at each switch, and restricted resetting of switch.

  • 3. Complete sprinkler system required
  • 4. Fail-safe electrical locks. ADPH allows

10-second unlocking delay for power failure to fire alarm.

Door Locking for Safety

LSC 19.2.2.2.5.2

  • 5. Locks release automatically upon:
  • 1. Smoke detection system activation, or
  • 2. Sprinkler system water flow, or
  • 3. Disablement of fire alarm system (ADPH)
  • 6. Release switch at each locked door

(ADPH)

  • 7. Written justification (ADPH)

Sliding Doors

LSC 19.2.2.2.10.2

  • New section containing 5 requirements
  • Emergency break-away swing feature not

required when the door serves fewer than 10 occupants. (New)

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 8

Projections Into Corridors

LSC 19.2.3.4(2) Corridors 6 feet or more wide

  • New LSC provision for 6 inch projections

from wall above handrail height

  • ADA Accessibility Guidelines (ADAAG)

allows 4 inch projections into circulation path.

  • ADAAG allows 4-1/2 inch handrail

projections.

  • CMS – T

echnical assistance regarding how to avoid noncompliance with ADA requirement.

Projections Into Corridors

2012 LSC 19.2.3.4(2)

  • Allowed in corridors

at least 6 feet wide 2010 ADA

  • Paragraph 307.2
  • Handrails 4-1/2 inches

Wheeled Equipment in Corridors

LSC 19.2.3.4(4)

  • Clear width at

wheeled items is at least 60 inches

  • Fire Safety Plan

and Training Program for Emergency relocation

  • Limited to:
  • Equipment and carts in use
  • Medical emergency equipment not in use (new)
  • Patient lift and transport equipment (new)
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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 9

Permissible Wheeled Equipment

Food Service Carts (In Use) Housekeeping Carts (In Use) Medication Carts (In Use) Isolation Carts Crash Carts Wheeled Emergency Medical Equipment (not stored) Portable Lift Equipment Transport Equipment

Fixed Furniture in Corridors

LSC 19.2.3.4(5) Summary of requirements:

  • Securely attached to floor or wall
  • On one side of the corridor
  • Each grouping limited to 50 square feet
  • Groupings at least 10 feet apart
  • No obstruction of access to building and fire equip.
  • Corridors have

smoke detection,

  • r furniture in view

from nurse station

  • Sprinkler system

in compartment

Hazardous Areas

LSC 19.3.2.1.5

  • Soiled linen rooms with a volume

exceeding 64 gallons

  • “Trash collection rooms” changed to

“Rooms with collected trash.” Hazardous if volume exceeds 64 gallons.

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 10

Residential Cooking Equipment

LSC 19.3.2.5.2

  • Food warming or limited cooking
  • No fire extinguishing system required

(new expanded wording)

  • Room not required to be protected as a

hazardous area (modified wording)

“Culture Change” Kitchen

LSC 19.3.2.5.3 to prepare meals for up to 30 residents (per Appendix)

  • “Cooking facility” open to corridor
  • No separation required from other spaces

within the smoke compartment

  • 13 Conditions listed
  • Requires plan review through Technical

Services

“Culture Change” Kitchen

LSC 19.3.2.5.4 to prepare meals for up to 30 residents

  • “Cooking facility” not open to corridor
  • Separation required from corridor
  • Not a sleeping room
  • 11 Conditions apply
  • Requires plan review through T

echnical Services

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 11

“Traditional” Kitchens

LSC 19.3.2.5.5

  • Cooking equipment protected by kitchen

fire extinguishing system

  • Not considered hazardous area
  • Not open to the corridor

Alcohol-Based Hand Rub Dispensers

LSC 19.3.2.6 “ABHR” K-211

  • Comply with this paragraph in lieu of NFPA 30
  • Quantity within a smoke compartment clarified,

generally up to 10 gallons totaled is acceptable

– One dispenser within a bedroom not included in this limitation

  • More than 5 gallons stored in a compartment to

comply with NFPA 30

  • Aerosol dispensers added

Alcohol-Based Hand Rub Dispensers Locations

LSC 19.3.2.6(8)

  • In corridors at least 6 feet

wide.

  • At least 48 inches apart
  • Mounted over carpet only

in sprinklered smoke compartments

  • Mounting near an ignition

source, including:

– Light switch – Electrical receptacle

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 12

Alcohol-Based Hand Rub Dispensers

“Inappropriate Access” statements by CMS in code adoption announcement, Page 63.

  • Certain patients or residents may misuse ABHR

solutions, which are toxic and flammable.

  • Secure dispensers from inappropriate access

– Not in corridors in or near dementia or psychiatric units – Only where units can be easily and frequently monitored

Powered Corridor Doors

LSC 19.3.6.3.7 New provision to allow powered doors in corridor wall. Doors may swing or slide.

  • Must have latching device to keep the door in a

closed position

  • Must comply with 7.2.1.9, “Powered Door Leaf

Operation”

Protective Door Plates

LSC 19.3.6.3.12 2012 wording removed the height restriction

  • n protective plates on corridor doors.

Plates may be factory-applied or field-applied. Fire rating of the plate is not required.

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 13

Corridor Wall Openings

LSC A19.3.6.5.1 New Annex note

  • Unprotected mail slots and pass-through
  • penings in walls, vision panels and doors
  • Not intended to be at hazardous areas

Bedroom Outside Window

LSC 19.3.8

  • NFPA deleted code requirement for outside

window or door at each sleeping room. However –

  • CMS added the requirement to the revised

federal regulations for hospitals and long term care facilities. Required sill heights.

  • ADPH licensure requirement

Indoor Gas Fireplaces

LSC 19.5.2.3 Expanded requirements

  • Direct-vent type, per NFPA 54
  • May be within smoke compartment with sleeping

rooms if sprinklered with quick-response or residential sprinklers

  • Not within a sleeping room
  • Locked or restricted gas controls
  • Wire mesh screen and sealed glass front
  • Electrically supervised carbon monoxide

detection in the room

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 14

Indoor Solid Fuel Fireplaces

LSC 19.5.2.3

  • Minimum 1-hour fire separation from patient

sleeping space

  • Fireplace enclosure such as tempered glass
  • Electrically supervised carbon monoxide

detection in the room

  • AHJ may require lock on enclosure, and other

safety precautions.

  • Raised hearth required in Chapter 18 New

.

Smoking Areas

LSC 19.7.4 No changes.

Portable Space Heaters

LSC 19.7.8 No changes.

19.7.5.1 Drapes vs. Cubicle Curtains

  • Cubicle curtains still have to be flame

resistant.

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 15

19.7.5.1 Drapes vs. Cubicle Curtains

  • Draperies and curtains are not required to be

flame resistant in patient rooms within a sprinklered smoke compartment.

  • Draperies and curtains in other rooms or

areas if the panels are not more than 48 sq ft, not exceeding 20% of wall area, and in sprinklered locations.

19.7.5.4 Mattresses and Upholstered Furniture

  • No change for Alabama Nursing Homes.
  • Since all existing nursing homes in

Alabama have complete automatic sprinkler systems, the requirement for smoke detectors in the patient room does not apply.

19.7.5.6 Decorations

  • Flame-retardant or treated with approved

coating

  • Meet the NFPA 701, Standard Methods of Fire

T ests for Flame Propagation of T extiles and Films, using the 20 kW ignition source

  • Heat release not exceeding 100kW, NFPA 289,

Standard Methods of Fire T ests for Individual Fuel Packages

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 16

19.7.5.6(4) Decorations Attached to Walls, Ceilings & Doors

Inside any room or space of a smoke compartment:

  • Without a sprinklered system in the smoke

compartment, decorations shall not exceed 20%

  • f the wall, ceiling, and door in the area.
  • With a sprinklered system in the smoke

compartment, decorations shall not exceed 30%

  • f the wall, ceiling, and door area.
  • For patient sleeping rooms in a smoke

compartment with sprinkler coverage, 50% is the max of the wall, ceiling, and door area.

19.7.5.7 Trash & Linen Containers

No new requirements. Soiled linen or trash collection receptacles shall not exceed 32 gallons in capacity. Exception: No limit in hazardous areas.

19.7.5.7 Trash & Linen Containers

  • Average density of container

capacity in a room or space shall not exceed 0.5 gallon per square foot. Exception: No limit in hazardous areas.

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 17

19.7.5.7 Linen Containers

  • General guideline: Bedrooms

may have one 30 gallon linen container per resident.

19.7.5.7 Trash & Linen Containers

“Mobile soiled linen or trash collection receptacles with capacities greater than 32 gallons shall be located in a room protected as a hazardous area when not attended.”

19.7.5.7 (Handbook) Trash & Linen Containers

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 18

Recycling Containers

LSC 19.5.7.2 – New provision for clean paper

  • Up to 96 gallon size
  • If more than 96 gallons, shall be located in a

room with self-closing door. Walls and ceiling resist the passage of smoke.

  • The container used shall be labeled and listed

as meeting FM approved Standard 6921, or equivalent.

Essential 2012 NFPA Codes

catalog.nfpa.org

$98 $73

catalog.nfpa.org

Essential 2012 NFPA Codes

NFPA 99

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 19

$60

catalog.nfpa.org

Essential 2012 NFPA Codes

NFPA 25

  • Types of Suites

Sleeping Suite Patient Care Non-Sleeping Suite Non-Patient Care Suite

  • 19.2.5.7.2.1 Sleeping Suite Arrangement

Staff Supervision Sleeping Rooms within the Suite

2012 NFPA 101 Suites

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 20

  • 19.2.5.7.2.2 Sleeping Suite Means of Egress

Exit Access Doors Exit into Other Suites

  • 19.2.5.7.2.3 Sleeping Suite Maximum Size

Not to Exceed 5,000 square feet

Suites, continued Sprinkler Requirements

  • 19.3.5.2 High-rise Buildings

Sprinkler System Throughout

Egress Lighting

  • 7.8.1.3 New Stairs

Illumination Levels

  • 7.9.2.2 New Power Systems for

Emergency Lighting

Type 10, Class 1.5, Level 1

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 21

  • 4.1 Building Systems Categories

The Code lists four categories: Category 1 Category 2 Category 3 Category 4 Risk Assessment Application

NFPA 99 Fundamentals

  • 9.1 Applicability

New construction Renovated or Altered Requirement for smoke venting in anesthetizing locations has been deleted from NFPA 99.

Heating, Ventilation, and Air Conditioning

  • 10.2.3.6 Multiple Outlet Connection

Two or more power receptacles connected to a flexible cord to supply power to components of a movable equipment assembly that is rack, table, pedestal or cart mounted is permitted if you meet the four steps listed. TIA 12-5.

NFPA 99 Electrical Equipment

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 22

  • 15.1 Applicability

New & Existing

NFPA 99 Features of Fire Protection

  • CMS is working on a separate rule for

“Emergency Preparedness” and is excluding this chapter from their regulations.

NFPA 99 Emergency Management

Remember! If It’s Not Documented, It Didn’t Happen!

– 7.9.3 T esting of emergency lighting monthly and annually – 7.10.9 Visual inspection of Exit signs/30 days – 9.4.6 Elevator T esting

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 23

Fire Alarm

It’s official! The fire alarm system doesn’t have to wake the dead in health care facilities, see 9.6.3.6.3. You may use the private operating mode.

Sprinkler Systems

  • All nursing homes shall have a complete

automatic sprinkler system. 19.3.5.1

  • Maintenance and testing per NFPA 25
  • Documentation on the sprinkler system

that you must maintain includes design and inspections for the life of the fire protection system.

Sprinkler Systems Impairment

  • Reference NFPA 25

Ø Must have an “Impairment Coordinator” Ø Sprinkler system must be tagged to show that the sprinkler system is impaired; a tag shall be posted at each fire department connection, system connection valves, and

  • ther locations as required by the AHJ to

indicate all or which part is impaired.

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 24

Sprinkler Systems Impairment

  • Planned Impairment Program
  • Emergency Impairments

Sprinkler Systems Impairment

If the sprinkler system is out of service for more than 10 hours in a 24 hour period: ØEvacuate the building or the portion of the building, or ØImplement an approved fire watch, or ØEstablish a temporary water supply, or ØSet up an approved program to eliminate potential ignition source and limit the amount

  • f fuel for a fire.

Sprinkler Systems

  • Identify the location of the shutoff valves with

a permanent sign

  • Test sprinkler heads if in service for more than

50 years, repeat at 10 years

  • If sprinkler system installed prior to 1929

replace

  • Sprinkler system with fast-response elements

after 20 years replaced or tested

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 25

Statement of Deficiencies (SOD)

Due out of the state office within 10 working days

Plan of Correction (POC)

Must be returned to state office within 10 calendar days

§ Each deficiency must have a POC (Plan of Correction) with a completion date not later than the date shown in the ADPH letter § 35 days after the health team has left your facility § Waivers for additional time may be granted

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 26

4 ELEMENTS TO A POC

  • 1. Specific corrective action.
  • 2. Identify any other occurrences.
  • 3. Policies/procedures you have set in place to

insure the deficiency will not occur again.

  • 4. How will you monitor the policies and

procedures you have set in place? Who will collect the information? How often will it be collected? What will trigger additional action?

An Example of a Citation

K-25

Smoke barriers shall be constructed to provide at least a one half hour fire resistance rating and constructed in accordance with 8.3. Smoke barriers shall be permitted to terminate at an atrium wall. Windows shall be protected by fire-rated glazing or by wired glass panels and steel frames.

Example of a citation (cont.)

Based on observation of all smoke barriers on 5/11/2016, the facility failed to maintain smoke barriers with a system or material capable of restricting the transfer of

  • smoke. Findings include:

Smoke barrier at Room 201 had holes in several locations where drywall mud had fallen out. In some locations, the holes had been sealed with an orange foam product. The facility personnel could not provide documentation for the orange foam to verify if the product could be used in a commercial building for rated walls.

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 27

Rejected Plan of Correction Provided

1) The unsealed penetration in the smoke barrier at Room 201 will be repaired by the Maintenance Director. 2) The unapproved orange foam substance used to seal penetrations in the smoke barrier will be removed and will be sealed per life safety code standards by the maintenance personnel.

Rejected Plan of Correction Provided

3) The administrator provided training to the

maintenance personnel on how to seal the smoke barrier and educated them on the importance of maintaining the wall to resist the transfer of smoke. 4) The maintenance personnel will monitor the smoke barriers weekly to ensure barriers are sealed appropriately and per life safety code

  • standards. Any concerns noted will be

addressed and monitoring will continue. A copy

  • f these checks will be kept in the

administrator’s office.

Reasons POC Rejected

  • This was the exact wording for the POC from

the previous years.

  • The name of the product used to seal the

penetrations was not provided.

  • What training did the administrator have in
  • rder to train the maintenance staff on how to

maintain the wall to limit the transfer of smoke?

  • This facility was cited for this same tag

three years in a row.

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 28

Why are we looking so closely?

  • CMS has asked that the State Agency work to

reduce repeat deficiencies in facilities.

  • How can this be accomplished?

ØFacilities must provide a better Plan of Correction. ØFacility staff must be properly trained and must be more diligent in follow-through

Sprinkler Systems

  • New provision – dry-type sprinkler heads that

have been installed for 10 years shall be replaced, or a sampling sent for testing. Retest after next 10 years.

  • Sample needed for testing not less than four

sprinklers or 1%, whichever is greater

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 29

Evacuation and Relocation Plan 19.7

  • No change

– Written copies of your plan available for supervisors and at the security desk, phone

  • perators location, or nurses station.

– Instruct all employees periodically. – During fire drills, alarm shall be transmitted off site. – Drill quarterly on each shift (not less than

  • nce in any 3-month period).

– Written record of drills, including participants (LSC 4.7.6)

Fire Safety Plan 19.7.2.2

  • Remove all occupants.
  • Transmission of fire alarm signal.
  • Isolate the fire by closing the door to the

effected room.

  • Relocate patients as described per facility fire

safety plan.

Written Safety Plan

1.Use of alarms 2.Transmission of alarm to fire department 3.Emergency phone call to fire department (2003) 4.Response to alarms 5.Isolation of fire 6.Evacuation of immediate area 7.Evacuation of smoke compartment 8.Preparation of floors and building for evacuation 9.Extinguishment of fire

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2012 Life Safety Code Update June 20, 2016 Alabama Department of Public Health 30

HCFA Transmittal Notice 99-94

  • Issued by federal agency, still in effect

– Deals with items in the corridor must be in use, staff is actually using the equipment not just moving the equipment around because of the LSC survey. The equipment must have a permanent storage location, off of the corridor. Not referring to “emergency medical equipment” in new wheeled equipment section.

Top 10 Deficiencies

  • 1. K147 Electrical
  • 2. K25 Smoke Barriers
  • 3. K18 Corridor Doors
  • 4. K29 Hazardous Areas
  • 5. K69 Cooking Equipment
  • 6. K66 Smoking
  • 7. K130 Miscellaneous
  • 8. K50 Fire Drills
  • 9. K38 Maintain Exits
  • 10. K62 Sprinkler