2009 PE Update
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Transcript 2009 PE Update
2009
The Physical Environment
George Mills, Sr. Engineer
Standard Interpretation Group
The Joint Commission
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Overview
Environment of Care
Emergency Management
Life Safety Chapter
Overview
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Standards Improvement Initiative (SII)
Standards Improvement Initiative
The Standards Improvement Initiative
(SII) did not create any new
requirements
Replaced bulleted lists with expanded
Elements of Performance
Enhance clarity and objectivity of
standards and EPs
3 chapters of the Physical Environment:
Management of the Environment of Care
Emergency Management Chapter
Life Safety Chapter
Management of these chapters is up to
the organization
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Standards Improvement Initiative
Improved language
No more ‘hard to measure’ words like
“appropriate”
Improved structure of the manual
Hard copy (6 x 9)
Electronic (CD)
Decisions more accurately reflect
organizational performance
New numbering conventions
EC.02.04.03 EP 2 The organization inspects,
tests & maintains all life support equipment.
These activities are documented. (See also
EC.02.04.01 EPs 3 &4; PC.02.01,11 EP 2)
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Naming of Chapter
EC. [Environment of Care]
This is the chapter title designator
LS. [Life Safety Chapter]
This is the chapter title designator
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EM. [Emergency Management]
This is the chapter title designator
EC.01 [Plan]
The organization plans activities to
minimize risk in the Environment of Care.
EC.02 [Implement]
The organization manages safety and
security risks.
EC.03 [Educate/Train]
Staff and LIP are familiar with their roles
and responsibilities relative to the EC.
EC.04 [Information, Collection
Evaluation System (ICES)]
The
organization collects information to
monitor conditions in the EC.
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Numbering of the Standards
EC.02.01
Safety & Security
EC.02.02
Hazardous Materials & Waste
EC.02.03
Fire Safety
EC.02.04
Medical Equipment
EC.02.05
Utilities Management
EC.02.06
Safe, Functional Environment
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Numbering of the Subject
Numbering of the Issues
EC.02.03.05
Implementation | Fire Safety | Maintains Fire Safety
Equipment & Fire Safety Building Features
LS.02.01.34
Healthcare | One Building Type | [3] Protection [4] Fire
Alarm Systems
EM.02.01.01
Develop Emergency Operations Plan | Overview
Administrative Features in the Emergency Operations Plan
| Response Procedures and Capabilities
EM.02.02.09
Emergency Operations Plan | Addresses One of the six (6)
Critical Functions | Utilities
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Elements of Performance
EC.02.01.01
Implementation | Safety & Security | Safety &
Security Issues
EP 3 The organization takes action to minimize or
eliminate identified safety and security risks in the
physical environment
EC.02.01.01
Implementation | Safety & Security | Safety &
Security Issues
EP 4 The organization maintains all grounds and
equipment
EC.02.01.03
Implementation | Safety & Security | Smoking
Prohibited
EP 1 The organization develops a written policy
prohibiting smoking in all buildings. Exceptions for
patients in specific circumstances are defined.
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Scoring
Scoring Scale
0 = Insufficient Compliance
1 = Partial Compliance
2 = Full Compliance
Requirement for Improvement (RFI)
All findings of less than full compliance will
be cited as a RFI
All RFIs require resolution through an
Evidence of Standards Compliance (ESC)
This includes findings scored partial
“Supplemental Findings” (2008 term) are
eliminated
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Scoring & Decision Process
A: Structural requirements
EP’s scored yes (2) or no (0)
May address issues requiring full
compliance
C: Based on number of times an EP is not met
Score 2: 0-1 instances of non-compliance
Score 1: 2 instances of non-compliance
Score 0: > 3 instances of non-compliance
Above is based on a sample of 10
NOTE: The ‘B’ Category has been eliminated
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EP Scoring Categories
Criticality
safety or quality of care as a result of noncompliance
with a Joint Commission requirement.”
4 Levels of Criticality
1. Immediate Threat to Life (ITL)
PDA until resolved
2. Situational Decision Rules
Based on specific situations at time of survey
3. Direct Impact Requirements [45 Day Resolution]
Noncompliance may create an immediate risk to
patient safety or quality of care
4. Indirect Impact Requirements [60 Day Resolution]
Based on planning and evaluation or care processes
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Criticality defined as “the immediacy of risk to patient
2009 Scoring Decision Model
Immediacy of risk to patient care
and the organization’s
certification status
Higher
Timeline for resolution of
non-compliant findings
ITL
PDA until
resolved
Shorter
Direct Impact Requirements
“Implementation” Based Requirements
(Short Resolution Timeframe)
Lower
Indirect Impact Requirements
“Planning” and “Evaluation” Based Requirements
(Longer Resolution Timeframe)
Longer
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“Situational”
Decision Rules
CON & PDA
2009 Scoring Decision Model
Immediate Threat to Life
ITL
“Situational”
Decision Rules
Direct Impact Requirements
Indirect Impact Requirements
survey, which have or may
potentially have a serious adverse
effect on patient health and safety.
The Joint Commission President
can issue an expedited Preliminary
Denial of Accreditation (PDA)
decision.
PDA remains until corrective
action is demonstrated, via an onsite validation review.
PDA changes to Conditional
Accreditation which includes a
follow-up review to assess
sustained implementation of
corrective action.
Examples:
Inoperable fire alarm system
Lack of Master Alarms for
Medical Gas System
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Situations, identified during
2009 Scoring Decision Model
Situational Decision Rules
ITL
“Situational”
Decision Rules
Direct Impact Requirements
Indirect Impact Requirements
of PDA or CON is recommended
to the Accreditation Committee
Demonstration of resolution
through submission of Evidence
of Standards Compliance (ESC).
Onsite review to validate
implementation of corrective
action.
Examples:
Failure to implement
corrective action in
response to accepted PFI
unlicensed facility
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Situations in which a decision
2009 Scoring Decision Model
Direct Impact Requirements
ITL
“Situational”
Decision Rules
Direct Impact Requirements
Indirect Impact Requirements
impact on quality of care and patient
safety
“Implementation” based
requirements
Non-compliant requirements must be
addressed via ESC submission process
Short time-frame (45 days)
Decision is pending submission of
ESC within established timeframe
Failure to resolve results in
progressively more adverse decision
(e.g., Provisional, Conditional, PDC)
Example:
Inspects, tests & maintains Life
Support Systems
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Non-compliance results in direct
2009 Scoring Decision Model
Indirect Impact Requirements
Initially less immediacy of risk; failure
“Situational”
Decision Rules
Direct Impact Requirements
Piping used for AASS is not used to
support any other item
Hospital provides storage space to
meet patient needs
Indirect Impact Requirements
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ITL
to resolve non-compliance increases risk
“Planning” and “Evaluation” based
requirements
Non-compliant requirements must be
addressed via ESC submission process
Longer time-frame (60 days)
Decision is pending submission of ESC
within established timeframe
Failure to resolve = progressively
more adverse certification decision (e.g.,
Provisional, Conditional, PDC)
Examples:
Direct Impact Count
Environment of Care
Direct Impact
Life Safety Chapter
7 Administrative (LS.01)
20 Healthcare (LS.02)
56 Total (62 ‘z’ items in 2008)
Emergency Management
3 Direct Impact
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38
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Survey Process
Periodic Performance Review
compliance with all standards
When: 12 months from last
Survey activity
Where: via extranet
(secure/password accessible site)
Why: Continuous Survey
Readiness
Like
Statement of Conditions
assess & improve
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What: self assessment for
PPR Process
Plan of Action for non-compliance
to JC for review
Telephone interaction with JC staff
No change in accreditation status
No scores under corrective action
plan
Measures of success (MOS)
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Submit
“A numerical or other quantitative measure
usually related to an audit that validates
that an action was effective and
sustained.”
Indicated for some EP’s (M)
Required for PPR: included as part of
Plan for Action for non-compliant stds
Required for ESC: following an on-site
survey for select EPs if the std is scored
Out of Compliance
Not to be used as performance monitor
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Measure of Success (MOS)
Survey Process
months of previous survey activity
Survey process
Opening conference
Leadership interview
Validation of self assessment
Tracing patients through system
“Tracer methodology”
Discussion and education
Closing conference
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Survey is scheduled between 18 and 39
TRACER METHODOLOGY
SAMPLE
PATIENT
VENTILATION
EMERGENCY
DEPARTMENT
MEDICAL
EQUIPMENT
SECURITY
ICU
INFECTION
CONTROL
MED/SURG
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SURGERY
Contingency Planning
environment of care
Failure of utilities could directly impact patient
care delivery
Activities associated with managing utilities are
designed to ensure the reliability of the
systems day to day
Contingency plans are developed to ensure
reliability of utilities systems
Contingency plans address at least two issues:
Equipment failure or disruption
Emergency related failures or disruption
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Utilities exist to provide a safe and comfortable
Contingency Planning: Survey
plans are current and accurate
Discuss the organization Memorandum
of Understanding and its impact in the
community
Evaluate against Standards & Elements
of Performance
Suggest the organization include
exercising these contingency plans with
their Emergency Exercise
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Organizations ensure their contingency
EP 7 The hospital maps the distribution of utility
systems
EP 8 The hospital labels controls for a partial or
complete emergency shutdown
EP 9 The hospitals has procedures for responding to
utility system disruptions
EP 10 The hospitals' procedures address shutting off
the malfunctioning system and notifying staff in
affected areas
EP 11 The hospitals procedures address performing
emergency clinical interventions during utility
systems disruptions
EP 12 The hospitals procedures addresses the
following: How to obtain emergency repair services
EP 13 The hospital responds to utility system
disruptions as described in its procedures
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EC.02.05.01 Utilities Mgmt.
Emergency Operations Plan identifies alternative
means of providing:
EP 2 electricity
EP 3 water needed for consumption and essential
care activities
EP 4 water needed for equipment and sanitary
purposes
EP 5 fuel required for building operations or
essential transport activities
EP 6 medical gas/vacuum systems
EP 7 Utility systems defined as essential, such as
Vertical & horizontal transport
Heating & cooling systems
Steam for sterilization
EP 8 Utility needs identified in the HVA
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EM.02.02.09
Survey Expectations
Documentation
Current
EC/Safety Committee Minutes
EC Management Plans
Annual Evaluations of EC Plans
• EC.04.01.01 EP 15
Statement of Conditions
• LS.01.01.01 EP 2
Inspect, Test & Maintain
• EC.02.05.05
• EC.02.05.07
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Life Safety Code Specialist
LSCS Background
Facilities or Environment of Care based
Prefer CHFM certification
LSCS Agenda
On-Site one day (typically on day 1 or day 2)
Interfaces with survey team member(s)
LSCS Focus
EC.02.03.05 Fire Protection Systems
EC.02.05.07 Emergency Power
EC.02.05.09 Medical Gas and Vacuum
LS.01.01.01 Life Safety Code
LS.01.02.01 Interim Life Safety Measures (ILSM)
Other EC “Observations”
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Life Safety Code Specialist Update
May also survey
LD.04.01.05 EP 4
LD.03.03.01 EP 4
LD.04.04.01 EP 2
survey day for the LSCS
Critical Access Hospitals ONLY:
LSCS
will survey all of the EC
In 2009 will survey EC, LS and EM
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Greater than 750,000 sq ft second
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Environment of Care
Environment of Care: Structure
Plan (EC.01.01.01)
Implement
and Security (EC.02.01.01, 02.01.03)
Hazardous Materials and Wastes (EC.02.02.01)
Fire Safety (EC.02.03.01, 02.03.03, 02.03.05)
Medical Equipment (EC.02.04.01, 02.04.03)
Utilities (EC.02.05.01, 02.05.03, 02.05.05,
02.05.07, 02.05.09)
Other Physical Environment Requirements
(EC.02.06.01, 02.06.05)
Staff Demonstrate Competence (EC.03.01.01)
Monitor and Improve (EC.04.01.01, 04.01.03,
04.01.05)
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Safety
Environment of Care: Issues
EC.01.01.01: The hospital plans activities to
minimize risks in the environment of care.
One or more persons can be assigned to
manage risks associated with the
management plans described in this standard.
EP 3 The hospital has a written plan for
managing: environmental safety of
everyone who enters the hospitals
facilities
EP 4 The hospital has a written plan for
managing: security of everyone who
enters the hospitals facilities
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Note:
1 The hospital identifies safety & security
risks associated with the environment of
care. Risks are identified from internal
sources such as ongoing monitoring of
the environment, results of root cause
analysis, results of annual proactive risk
assessments of high risk processes, and
from credible external sources such as
Sentinel Event Alerts.
3 The hospital takes actions to minimize or
eliminate identified safety and security
risks in the physical environment.
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EC.02.01.01 EPs 1 & 3
Does Every mean Every ?
Commission has defined time in the
Introduction of all 3 chapters:
Daily, weekly, monthly and quarterly are
calendar references
Semi-annual is 6 months from last
occurrence +/- 20 days
Annual is 12 months from last
occurrence +/- 30 days
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For the Physical Environment the Joint
EC.02.03.05
EP 2 Every 6 months the hospital tests valve
tamper switches and water-flow devices. The
completion date of the test is documented.
Every 6 months +/- 20 days
EP 12 Every 12 months the hospital tests
visual and audible alarms, including speakers.
The completion date of the test is
documented.
Every 12 months +/- 30 days
At least monthly the hospital inspects portable
fire extinguishers. The completion dates of
the inspections are documented.
Tested within the calendar month
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Does Every mean Every ?
EC.04.01.01 The hospital manages medical
equipment risks.
EP 1 The hospital solicits input from individuals
who operate and service equipment when it
selects and acquires equipment.
EP 2 The hospital maintains either a written
inventory of all medical equipment or a written
inventory of selected equipment categorized
by physical risk associated with use (including
all life support equipment) and equipment
incident history. The hospital evaluates new
types of equipment before initial use to
determine whether they should be included in
the inventory. (see also EC.01.01.01 EP 7)
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Medical Equipment
EC.02.05.01 EP 3
The hospital identifies in writing inspection
and maintenance activities for all operating
components of utility systems on the
inventory. (See also EC.02.05.05 EPs 3 – 5
and EC.02.05.09 EP 1)
NOTE: Hospitals may use different
approaches to maintenance. For example,
activities such as predictive maintenance,
reliability-centered maintenance, interval
based inspections, corrective maintenance,
or metered maintenance may be selected
to ensure dependable performance.
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Utilities Management
EC.02.05.07 EP 4
Twelve times a year, at intervals of not
less than 20 days and not more than
40 days, the hospital tests each
generator for at least 30 continuous
minutes. The completion date of the
tests is documented.
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Utilities Management
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Life Safety Chapter
Life Safety Chapter
Based on the Life Safety Code®
101-2000
Format to be consistent with NFPA
CMS K-Tags reconciled
Three occupancies
Healthcare
Ambulatory
Residential
EPs are sequentially listed as found in LSC
Exception language accepted
Annual Life Safety Assessment will occur as
part of Periodic Performance Review
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NFPA
Life Safety Chapter
Removed optional Building Maintenance
Program (BMP)
Standards & Elements of Performance
LS.01.01.01 Administrative
LS.01.02.01 Interim Life Safety
Measures (includes construction and
LS.02 - .04
LS.02 Healthcare
LS.03 Ambulatory
LS.04 Residential
LS.04.01 < 16 Rooming & Lodging
LS.04.02 > 17 Hotel & Dormitory
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non-construction)
Overview: When an [organization] finds that
it is out of compliance with Standards
LS.02.01.10 through LS.04.02.05, the
hospital either resolves the deficiencies
immediately or manages it through one of
the following options:
a maintenance management process
that documents the deficiency and
corrective resolution within 45 days; or
a Plan For Improvement derived from
the Statement of Conditions™; or
a Life Safety Code Equivalency
approved by The Joint Commission.
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Life Safety Process
Traditional Equivalencies
Alternative means of complying with the LSC
In the SOC select PFI
Select PFI Change Request
routes the user to a Web Request page
Identify deficiency using specific Life Safety
Code references
Identify alternative solution
Provide timeline of actions
Have one of the following certify proposed
actions:
• Fire Protection Engineer
• Registered Architect
• Local AHJ (over enforcement of fire
safety)
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This
FSES Equivalencies
Include the following:
Completed FSES evaluation
Identify all deficiencies that are being
addressed
Use specific Life Safety Code references
Identify why the equivalency is being
made
Confirmation that all open PFIs will
receive high priority resolution
Provide summary of FSES findings
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Submit in writing
LS.01.01.01 (Administrative)
EP 3
When the hospital plans to resolve a
deficiency through a Plan for
Improvement (PFI), the hospital
meets the time frame identified in
the PFI accepted by The Joint
Commission.
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Life Safety Chapter
Life Safety Chapter
The hospital has a written Interim Life
Safety Measures (ILSM) policy that covers
periods of construction or situations when
the Life Safety Code deficiencies cannot
be immediately corrected or when The
Joint Commission has not granted an
equivalency. The policy includes criteria
for evaluating when and to what extent
the hospital follows special measures to
compensate for increased risk.
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LS.01.02.01 (ILSM) EP 3
Life Safety Chapter
The organization maintains the integrity of
the means of egress
EP 13 Exits, exit accesses, and exit
discharges are clear of obstructions or
impediments to the public way, such as
clutter (for example, equipment, carts,
furniture), construction material, and
snow and ice. (For full text and any
exceptions, refer to: NFPA 101-2000,
18/19.2.3.3.)
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LS.02.01.20
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Electronic Statement of
Conditions (eSOC)
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Security Administrator
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Sites & Buildings: Revised
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Government Suspension
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BBI Enhancements
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After Gov’t Suspension
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Sites & Building Page
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Emergency Management
Overview
Is now an accreditation manual chapter
Performance from 2008 are
incorporated into the 2009 Emergency
Management Chapter
No new Standards or Elements of
Performance in 2009
This new chapter contains some
standards that were in HR, EC and MS
Survey Process is similar to 2008
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All Standards and Elements of
Hospital/Community Debriefings:
Tropical Storm Allison-June 2001
Terrorist Attacks-September 2001
Power Outage- Summer 2003
S. California Wild Fires-Summer
2003
SARS (Asia/Toronto)-Spring 2003
Florida Hurricanes (Frances,
Charley, Jeanne) - Aug/Sept 2004
Hurricane Katrina, Rita, WilmaAug, Sept & Oct 2005
G
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History of Disasters
Assessment Conclusions
Major Issues Began to Surface:
approach emergency management
Problems with Communication
Inadequate emergency generator backup
Faulty Incident Command Systems
Lack of Involvement with Emergency
Operations Center (EOC)
The extend of an organization’s planning is
dictated by the impact of their worst recent
disaster
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Scalable
Chapter Outline
Foundation for the Emergency Plan
[EM.01.01.01]
Plan for Emergency Operations Plan
Requirements [EM.02.01.01]
Specific Requirements
Evaluation
Evaluating the planning [EM.03.01.01]
Evaluating the plan through exercises
[EM.03.03.03]
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General
Conduct a Hazard Vulnerability Analysis
Documented
Annual Review
Site specific: one or many
Organization and community partners
prioritize HVA
Includes disclosing to community needs and
vulnerabilities
EP 8 Documented inventory of resources & assets
Fuel
Personal Protective Equipment (PPE)
Water
Medical/surgical supplies
Other
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HVA to plan mitigation
HVA to plan preparedness
Emergency Operations Plan
Emergency Operations Plan (EOP)
describes response procedures
plan
Capabilities to self-sustain for up to 96
hours
EOP describes
Recovery strategies
Initiation and termination of response
and recovery phases
Defines authorities
Alternative care sites
Actual implementation is documented
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Written
Six Critical Components
2.
3.
4.
5.
6.
[EC.02.02.01]
Resources & Assets
[EC.02.02.03]
Safety & Security
[EC.02.02.05]
Staff responsibilities
[EC.02.02.07]
Utilities Management
[EC.02.02.09]
Patient, clinical & support activities
[EC.02.02.11]
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1. Communication
Relief: until 12/31/2008
The following 15 EPs will not impact your
accreditation status
These EPs will be cited but not aggregated
EC.4.12
EC.4.13
EC.4.14
EC.4.15
EC.4.16
EC.4.17
EC.4.18
EP 9 & 10
EP 6
EP 7
EP 8 & 10
EP 2, 3 & 5
EP 2 & 3
EP 4
EP 4, 5, & 6
NOTE: EC.4.20 has until
the end of 2008 to show
compliance, so they are
not included here
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EC.4.11,
Corridor Clutter & Other
Life Safety Code
Interpretations
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Issue Resolution
&
Clarification
Damper Inspection: Actual EP Language:
EC.02.05.05 EP 18
1For
additional guidance, see NFPA 80-2007
(19.4.1.1) and NFPA 105-2007 (6.5.2).
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The hospital operates fire and smoke dampers
one year after installation and then at least
every six years to verify that they fully close.
The completion date is documented.1
Note: The initial test that must occur one year
after installation applies only to dampers
installed on and after January 1, 2008.
LD.04.01.05 EP 4: What to do when
the documentation isn’t there…
will be available later in the survey this may
result in a finding at LD.04.01.05 EP 4
The requested information should be utilized
by the organization, so not having the
information may indicate a lack of
responsibility by the organization
If the documentation arrives late, noncompliance has already been established
Scored at LD.04.01.05 EP4
Leaders hold staff accountable for their
responsibilities
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During survey documentation is reviewed
If the information is not readily available, but
If the corridor looks cluttered, it probably is
Carts with wheels that are not parked and
forgotten (not longer than 30 minutes),
but are actively used are allowed provided
they are "in use"
Crash Carts are always considered "in
use" and allowed with staff understanding
that in an emergency situation the cart is
moved out of the corridor
Isolation carts, located outside a occupied
patient room & required would be “in use”
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Corridor Clutter
Computers on Wheels
wheeled carts may be stored in a
corridor for not more than 30
minutes
Computers on Wheels may be
charging in the corridor while being
used
Computers on Wheels may be
stored in alcoves
The
corridor width must not be
compromised
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Computers on Wheels and other
Computers on Wheels
What about the Batteries?
Battery and charging systems must
meet the following design requirements
to ensure safe operation:
Lead-Acid Batteries:
Absorbed Glass Mat design and
Sealed Case (Sealed Lead-Acid)
All Battery Systems (SLA, NiMH, Li+ Ion, Li+
Ion Polymer):
Smart Charging system with overcharge
protection and
Shorted cell protection that shuts down
upon detecting a shorted cell
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Sealed
General Life Safety Interpretations
the door and jambs
Doors installed prior to 1967 may
have jambs without rating labels
Missing labels may be equivalized if
evidence of compliance is provided to
central office
Alternative is to have third party
testing agency re-label doors
Are ILSM in place where noncompliant door assemblies are found?
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Rated doors must have legible labels on
General Life Safety Interpretations
Fire stop: existing application is acceptable if:
was installed in a manner consistent with
original design specifications
It is in acceptable condition currently
If the firestop is cracking, etc, then it is
to be removed and repaired using current
technologies
JC does not accept the expanding foam used
for insulation in any fire or smoke barrier
This product does have a UL label, for
insulation properties
Easily ignited
Toxic gases when burned
Testing has confirmed foam alcohol based
hand rub (ABHR) is equivalent to gel
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It
Fully sprinklered buildings
Not required in elevator mechanical
rooms if state codes do not allow
(i.e. Ohio, Massachusetts)
Ensure sprinkler piping is not used to
support wiring or other material
Score as life safety code deficiency
(LS.02.01.35 EP 4)
Piping supports are not damaged
or loose (LS.02.01.35 EP 3)
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General Life Safety Issues
Non Flammable Medical Gas
Storage: General Issues
<300 ft³: 12 ‘e’ cylinders per smoke compartment, in
rack or appropriate holders
• Each ‘e’ cylinder is 24.96 ft³
• Smoke Compartment is limited to 22,500 ft²
Between 300 and 3000 ft³ must be stored in a room
that is limited construction with doors that can be
locked
“In use” verses “in storage”
On gurney is considered “in use”
In rack is “in storage”
• limited to 12 unprotected, racked per smoke
compartment (i.e. open to egress corridor)
“Empty” are NOT considered part of the 12 “in
storage”
Process to remove empties in a timely manner
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Non-Flammable Gas Storage:
NFPA 99-2005
NFPA 99-2005 edition has additional language
regarding O2 storage requirements, specifically:
Other:
5.1.3.3.2
5.1.3.3.3
5.1.3.3.3.2
5.1.3.3.3.3
design and construction
ventilation of locations for manifolds
ventilation for motor driven equipment
ventilation for outdoors
NOTE: CMS also uses NFPA 99-2005, 9.4.3
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Storage of nonflammable gases:
9.4.1
> 3000 cubic feet
9.4.2
300 – 3000 cubic feet
9.4.3
0 - 300 cubic feet
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Questions?
SIG Support: 630 792 5900
George Mills, MBA, FASHE, CEM, CHFM
Senior Engineer
SIG
Jerry Gervais, CHSP, CHFM
Engineer
SIG
John Maurer CHFM, CHSP
Engineer
SIG
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Charles “Skip” Wilson, MBA
Engineer
SIG