1 ASHE CODE ADVOCACY YEAR IN REVIEW Prepared by: Lennon Peake, P.E. Koffel Associates, Inc.

OVERVIEW ASHE Code Advocacy Highway Code Changes ASHE Compliance Tools TJC/CMS Compliance Updates

ASHE Advocacy Highway ASHE's response to confusing and contradictory health care regulations A two-way communications network between ASHE staff and ASHE members, ASHE Advocacy liaisons, and other health professionals with regulatory issues Quarterly conference calls

CODE UNITY 5 year process to date Building Codes and Life Safety Code ICC Ad Hoc Committee on Healthcare IBC adoption by CMS?

IBC Group I-1 Subclassification Modification: Use now includes care recipients who may need limited verbal or physical assistance during an emergency Condition 1: This occupancy condition shall include buildings in which all persons receiving custodial care who, without any assistance, are capable of responding to an emergency situation to complete building evacuation. Condition 2: This occupancy condition shall include buildings in which there are any persons receiving custodial care who require limited verbal or physical assistance while responding to an emergency situation to complete building evacuation.

IBC Group I-2 Sub-classification Modification: Distinction is now made between short- term and long-term care facilities Condition 1: This occupancy condition shall include facilities that provide nursing and medical care but do not provide emergency care, surgery, obstetrics or inpatient stabilization units for psychiatric or detoxification, including but not limited to nursing homes and foster care facilities. Condition 2: This occupancy condition shall include facilities that provide nursing and medical care and could provide emergency care, surgery, obstetrics or inpatient stabilization units for psychiatric or detoxification, including but not limited to hospitals.

IBC Atrium Smoke Control Modification to exception: Smoke control required in atriums of I-2 and I-1 Condition 2 facilities regardless of # of stories

IBC Group I-2 Shared Living Spaces Addition § Nursing Home Condition 1 allow open space to corridor: Walls and ceilings constructed as corridors Not used for sleeping, treatment or hazardous area Protected by smoke detection system Corridor smoke detection system or quick-response sprinkler protection Does not obstruct the means of egress

IBC Group I-2 Cooking Facilities Addition § Nursing Home Condition 1 allow cooking facilities open to corridor: Smoke compartment < 30 clients (housed and served) 1 facility per smoke compartment Domestic cooking equipment only Corridor is clearly delineated from cooking area Does not obstruct the means of egress

IBC Group I-2 Cooking Facilities Addition § Nursing Home Condition 1 allow cooking facilities open to corridor: Domestic cooking hood with UL 300A listed extinguishing system including manual activation device Interlock device to shunt power or fuel upon activation of extinguishing system Manual shut-off accessible only to staff Automatic deactivation of cooking equipment < 120 minutes Portable Class K fire extinguisher

IBC Group I-2 Care Suites Modification § Access to corridor No limitation on intervening rooms Limited to passage through 3 doors and travel < 100 ft Travel < 125 ft if smoke detection is provided in suite § Doors in suites may be: Manually operated horizontal sliding door per exc. 9 Power operated door per exc. 7 Means of egress door per 1010

IBC Group I-2 Care Suites Modification § Sleeping Suites Arrangement allows for direct and constant supervision into sleeping rooms by providers Smoke detection in sleeping rooms Suite size increases from 5,000 gsf to 7,500 gsf Suite size can be increased to 10,000 gsf if smoke detection is provided throughout suite

IBC Group I-2 Care Suites Modification § Non- Sleeping Suites Suite size increases from 10,000 gsf to 12,500 gsf Suite size can be increased to 15,000 gsf if smoke detection is provided throughout suite

IBC Group I-2 Smoke Barriers Modification §407.5 Smoke Barriers Condition 1 smoke compartments < 22,500 gsf Condition 2 smoke compartments < 40,000 gsf Elevator lobbies must comply with §3006.2

IBC Dampers § Exc. 2 Addition Smoke dampers are no longer required in smoke barriers in I-2 Condition 2 facilities that are protected throughout with QR sprinklers

LSC STAIRWAY IDENTIFICATION § New enclosed stairs serving three or more stories and existing enclosed stairs, other than those addressed in (P), serving five or more stories shall comply with (A) through (O)… f)Signage shall be located inside the stair enclosure g)Bottom of the signage shall be located a min of 48 in. above the floor landing h)Top of signage shall be located a max of 84 in. above the floor landing i)Floor level number shall be located below the stairway identifier j)Previously approved, existing signage shall not be required to comply with (L) through (O) f)L – O details lettering stroke and width

LSC FIRE-DOOR ASSEMBLIES § Labels on fire door assemblies shall be maintained in a legible condition. § In existing installations, steel door frames without a label shall be permitted where approved by the authority having jurisdiction.

LSC HIGH-RISE BUILDINGS § (2012 Edition) High-rise buildings containing health care occupancies must be sprinkler protected within 12 years of adoption of the code 9 years if the 2009 edition was adopted locally

HEALTH CARE INTERPRETATION TASK FORCE 7 voting AHJ members CMS, DoD, IFMA, IHS, TJC, SHA, VA 5 non-voting members AHCA, ASHE, NFPA, NFPA 99/101/5000 TCC Chair Agenda and meeting minutes can be located on NFPA / ASHE webstites

HITF INTERPRETATIONS Sprinkler clearance Question : Is it required that perimeter wall shelving that extends to the ceiling be fastened to the wall? Answer : NO a. Shelving isn’t even required for the storage. b. There is no correlation between the shelving, the clearance and the need to secure any shelving.

HITF INTERPRETATIONS SUITE MINIMUM “CORRIDOR” WIDTH Question: Within a space meeting the requirements for a suite, do the requirements for minimum corridor width apply? Answer: NO 28 – 36 inches of clear width required to be maintained

HITF INTERPRETATIONS Exit Discharge over non-paved surface Question 1: In a healthcare occupancy, are sidewalks required between the exit door and the public way in order to qualify as an exit discharge as stated in Section 7.7.1? Answer 1: NO.

LIFE SAFETY CODE ADOPTION Congress has three years to accept the Proposed Rule August 2017 Deadline

PHYSICAL ENVIRONMENT REFERENCES

CMS Fire and life safety survey reports CoP State Operations Manual Links to S&C Letters Formal Interpretations and errata FGI Guidelines, ASHRAE, NFPA 101 HITF Interpretations

Just Ask ASHE More than 30 Subject Matter Experts provide responses to your questions submitted through the ASHE website

FSES TOOL Fire Safety Evaluation System tool Developed by ASHE for NFPA 101A 2001 Search ASHE website for “FSES TOOL” Must be a member of ASHE to use tool

NFPA 99 RISK ASSESSMENT TOOL Spreadsheet tool contains worksheets for systems, equipment, and emergency management

NFPA 99 Wet Procedure Location Risk Assessment Three page document on how to conduct assessment

ASHE MECHANICAL SYSTEMS HANDBOOK

FOCUS ON COMPLIANCE ASHE / TJC collaboration on top 8 citations for physical environment standards Every two months ASHE and the Joint Commission will focus on a new standard Receive alerts when posted at ashe.org/compliance/

FOCUS ON COMPLIANCE July 2015: Introduction and announcement of collaboration at the ASHE Annual Conference August/September 2015: Utility systems (EC ) October/November 2015: Means of egress (LS ) December/January 2016: Built environment (EC ) February/March 2016: Fire protection (EC ) April/May 2016: General requirements (LS ) June/July 2016: Life safety protection (LS ) August/September 2016: Automated suppression systems (LS ) October/November 2016: Hazardous materials and waste management (EC )

UTILITY INVENTORY Utility System Heating, cooling, water distribution Operating components require inventory Boiler, pumps, condensate return, electrical panels Supporting parts do not require inventory Belts, filters, steam traps Ensure internal policies do not contradict classification of parts

WIRELESS TELEMETRY Letter writing campaign to urge FCC to limit Channel 37 for wireless patient monitoring devices Interference may affect patient care 8/6/2015 – FCC approved rules to allow unlicensed devices to operate on Channel 37 9/8/15 12:00 pm CST Free Webinar – "Critical WMTS Update: What You Need to Know,"

BARRIER MANAGEMENT SYMPOSIUMS Each region by early 2016 Region 2 was in spring 2014 Chapter Symposium ?

NFPA 2017 Conference and Expo June 4 – 7 Boston Need NFPA health care members to attend Floor votes in 2014 failed by a handful of votes Reimbursement

AMBULATORY SURGERY CENTERS The Joint Commission Survey team will include a Life Safety Code Surveyor

2015 TJC TOP CITIATION Required pressure differentials ORs, Sterile Processing, Soiled Utilities, etc. ACH per design at original construction FGI Guidelines otherwise

ENERGY TO CARE Free energy benchmarking program Robust dashboard to track consumption Value to facility through energy savings Resources diverted to patient care 10% energy reduction goal 67 million in savings since 2009

EQUIVALENCY PROCESS Submit equivalencies to TJC If approved by TJC, will be sent to CMS Regional Office for review CMS requires that any deviation from the adopted codes include an assessment of hardship and assurance that patient safety is not diminished.

EQUIVALENCY PROCESS Required to be submitted by Professional Engineer OR Certified Fire Protection Specialist

LIFE SAFETY PLANS Legend Sprinkler protected areas Hazardous areas Rated barriers and smoke barriers Suite boundaries and size Chutes and shafts Equivalencies or waivers Smoke zone sizes ?

FIRE ALARM DEVICE INVENTORY Unique identifier for each device required Blanket statements such as “All 52 relay devices passed annual test no permitted”

CMS CATEGORICAL WAIVERS S&C Letter LSC Various NFPA 99 / 101, 2012 Provisions Master medical gas alarms Normally unoccupied rooms Locking arrangements Generator testing Suite provisions Fire pump and flow switch testing frequencies > 32 gal trash / soiled linen containers

CMS CATEGORICAL WAIVERS S&C Letter LSC – NFPA Provisions – Nursing Homes Wheeled equipment and fixed furniture in corridors permitted Kitchens are no longer required to be separated from corridors Fireplaces in some instances are no longer to be required to be separated from corridors Combustible decorations limitations

CMS CATEGORICAL WAIVERS S&C Letter LSC & ASC Anesthetizing locations relative humidity minimum was decreased from 35% RH to 20% RH. ASHREA 170, 2008 Edition FGI Guidelines, 2010 Edition

CMS CATEGORICAL WAIVERS S&C Letter LSC NFPA RELOCATABLE POWER TAPS (RPTs) RPTs are permitted in the patient care vicinity provided all of the following are met: Receptacles are permanently attached to equipment 75% amperage maximum and meet NFPA 70 Cord integrity is monitored and documented Does not pertain to LTC facilities

CMS CATEGORICAL WAIVER PROCESS Document decision to use waiver must be documented Inform survey team at entrance conference TJC LS standards must also be indicated in the eBBI comment box

CMS WAIVER TEMPLATE ASHE has a document that lists all CMS categorical waivers in one location A template for all CMS categorical waivers has been generated by ASHE Search ASHE website for “WAIVER TEMPLATE” ASHE membership is required to access document

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