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Transcript of © Copyright, The Joint Commission 2011 Joint Commission Findings, Impact & Update Joint Commission...
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2011
Joint Commission Findings , Impact & Update
Joint Commission & CMS: Issue Resolution
George Mills, Sr. Engineer
Standard Interpretation Group
The Joint Commission
SIG Engineering 2011 - 2
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Top 5 Most Cited Standards in 2010
Hospitals
1. 62% RC.01.01.012. 50% LS.02.01.20 3. 44% LS.02.01.104. 38% EC.02.03.055. 37% LS.02.01.30
Critical Access Hospitals
1. 47% EC.02.03.052. 44% LS.02.01.103. 40% EC.02.05.074. 33% LS.02.01.205. 27% EC.02.06.01
SIG Engineering 2011 - 3
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#2: LS.02.01.20 (50%)
The hospital maintains the integrity of the means of egress.EP 13 Corridor ClutterEP 12 ProjectionsEPs 16 – 22 Suites issues
Equivalize > 5000 sq ftEP 1 Doors locked in means of
egress
SIG Engineering 2011 - 4
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Corridor Storage “If the corridor looks cluttered…it probably is” Corridor clutter is not a PFI issue Carts Allowed:
Crash Carts Isolation Carts Chemo Carts
Based on a HITF Interpretation (TJC, CMS & other AHJs) the following carts are not allowed: Linen Hampers Latex Carts
Anything in the egress corridor more than 30 minutes is storage
SIG Engineering 2011 - 5
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Corridor Storage
Dead end corridors may be used for storage Less than or equal to 50sqft space
Converting patient room: Long term include door closure
Surge issue: based on policy patients may be treated in the egress corridor during surge conditions
SIG Engineering 2011 - 6
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#3: LS.02.01.10 (44%) Building and fire protection features
are designed and maintained to minimize the effects of fire, smoke, and heat.EP 9 PenetrationsEPs 5 – 7 Door issuesEPs 1 & 2 Building Type issuesEP 8 Duct issues
SIG Engineering 2011 - 7
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#4: EC.02.03.05 (38%) The hospital maintains fire safety
equipment and fire safety building features.Features of fire protection
NOTE: #1 for Critical Access Hospitals
SIG Engineering 2011 - 8
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#5: LS.02.01.30 (37%) The hospital provides and maintains
building features to protect individuals from the hazards of fire and smoke.EPs 16 – 23 Smoke Barriers & DoorsEP 2 Hazardous Areas
SIG Engineering 2011 - 9
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Life Safety Code Specialist
LSCS Background Facilities or Environment of Care based Prefer CHFM certification
LSCS Agenda On-Site Two Days Interfaces with survey team member(s)
LSCS Survey Focus Life Safety Chapter EC.02.05.03 EC.02.05.07 EC.02.05.09
Other “Observations”
SIG Engineering 2011 - 10
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Life Safety Code Specialist May also survey
LD.04.01.05 EP 4 Accountability LD.04.04.01 EP 2 Hi-Priority LD.01.03.01 EP 5 Resources
All HAP and CAH will be surveyed for a minimum of 2 days by a LSCS Greater than 1.5 million sq ft will be surveyed
for a third day by the LSCS An additional day is added for every three
buildings that are classified as healthcareExample: for a HAP organization with 2 million
square feet of healthcare occupancy and 5 buildings classified as healthcare occupancy:
the number of LSCS days would be 4
SIG Engineering 2011 - 11
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LD.04.01.05 EP 4: What to do when the documentation isn’t
there… During survey specific documentation is reviewed If the documentation is not available write the observation
as non-compliant Also score LD.04.01.05 EP 4
If the documentation becomes available later in the survey to the survey team, the team can: Consider removing the previous finding if documentation
confirms the activity was completed as per the EP LD.04.01.05 EP 4 may also be removed during survey
If the survey team would prefer not to evaluate the documentation the organization can submit clarification
If the organization clarifies after survey: SIG Engineers will review and evaluate compliance LD.04.01.05 EP 4 remains
SIG Engineering 2011 - 12
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What Triggers ITL(Immediate Threat to Life)
Significantly compromised fire alarm system
Significantly compromised sprinkler system Significantly compromised emergency
power supply system Significantly compromised medical gas
master panel Significantly compromised exits Other situations that place patients, staff or
visitors at extreme danger
SIG Engineering 2011 - 13
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What Triggers AFS 13
AFS 13 is only related to previously accepted PFIsFailure to make sufficient progress
(LS.01.01.01 EP 2)Failure to implement appropriate ILSMs
(LS.01.02.01 EP 3) Failure to manage previously accepted
PFIs affects the Joint CommissionBoth organizations are aware of
deficiencies that have been managed using the PFI process
SIG Engineering 2011 - 14
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Deficiency Resolution Resolution to a deficiency:
Resolve it immediately Correct it within 45 days:
Management process that documents the deficiency and actions to resolve
ILSM must be considered Plan For Improvement located in the
Statement of Conditions™ Corrected within 6 months of the
Projected Completion Date ILSM must be considered
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45 Day Corrective Action Documented
Origination date Completion date Kept available for rolling 3 years Life Safety deficiencies Must not exceed 45 days If greater than 45 days create a Plan For
Improvement (PFI) If originally a work order, close out as complete
and generate the PFI Must be made available to the Joint Commission
During survey to confirm management of the deficiency
During CMS/Joint Commission validation process upon request
SIG Engineering 2011 - 16
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How Many Open PFIs Are Too Many?
The PFI process was created to allow organizations to self assess and create a Plan for Improvement
The self disclosure has never defined how many is too many
The ILSM process was created to allow both the organization and The Joint Commission to be aware of Life Safety Code deficiencies
Failure to make progress on previously accepted PFIs, including failure to implement ILSMs results in Conditional Accreditation
SIG Engineering 2011 - 17
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How Many Open PFIs Are Too Many?
Survey Process:Evaluate both closed and currently open
PFIs in the View All screenSpot check during building tour both some
closed and open PFIs to evaluate how well the organization is managing the PFI process
Evaluate the scope of PFI entries Are there life safety deficiencies Are they greater than maintenance items
(i.e. screws missing from a door hinge)
SIG Engineering 2011 - 18
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Statement of Conditions: PFI PFIs should be related to the LS Chapter
Corridor clutter is not a legitimate PFI PFIs should provide specific information
No blanket statements “…penetrations on 3rd floor”
Specific references to Life Safety Drawings is acceptable 32 penetrations as identified on LS
Drawing 3rd Floor, Center Tower dated 3/3/2010
Projected Completion Date is for all listed items (i.e. “32 penetrations”)
SIG Engineering 2011 - 19
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Equivalencies
The Joint Commission accepts two forms of equivalencies Traditional Equivalency
A process of field verification identifying alternative methods of fire safety that off-set the identified deficiency
Fire Safety Evaluation System (FSES) A process of calculating the features of life
safety and deducting any deficiencies, with the outcome determining if the building is equivalized based on the FSES
SIG Engineering 2011 - 20
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History Audit Trail
The History Audit Trail is used by SIG Engineers when considering extensions or other activities related to an organization
Prior to surveying, the surveyor must preview the History Audit Trail to discover if equivalencies or other actions have occurred by SIG Engineers
When surveying, brief but accurate information entered in the File Room is important
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Building Maintenance Program
(BMP)The BMP is no longer available to offset
findings during survey, but is considered “best practice”
All EPs related to the original ten BMP items are ‘C’ categories
SIG Engineering 2011 - 22
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Contingency Planning
Utilities exist to provide a safe and comfortable 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: Utility/Equipment failure or disruption Emergency related failures or disruption
SIG Engineering 2011 - 23
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Contingency Planning: Survey Organizations ensure their
contingency 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
SIG Engineering 2011 - 24
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EC.02.05.01 Utilities Mgmt.
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
SIG Engineering 2011 - 25
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EM.02.02.09: Utility DisruptionEmergency Operations Plan identifies alternative
means of providing: EP 2 electricityEP 3 water needed for consumption and
essential care activitiesEP 4 water needed for equipment and sanitary
purposesEP 5 fuel required for building operations or
essential transport activitiesEP 6 medical gas/vacuum systemsEP 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
SIG Engineering 2011 - 26
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Time DefinedThe Joint Commission EC chapter defines time as:
Daily, weekly, monthly and quarterly are calendar references
Semi-annual is 6 months from the last scheduled event +/- 20 days
Annual is 12 months from the last scheduled event +/- 30 days
3 years is 36 months from the last scheduled event +/- 45 days
NOTE 1: The above does not apply to required frequencies such as emergency generator testing (see EC.02.05.07 EP 4 & 8)
NOTE 2: An alternative of developing either a unique, written policy or adopting NFPA definitions when available is acceptable
SIG Engineering 2011 - 27
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Semiannual: +/- 20 daysAnnual: +/- 30 days
Due Date
Due Date
Scheduled Month
Scheduled Month
20 202020
30 303030
July Sept OctAug NovJune Dec
Jan F M A J J O N
Semiannual
Annual
+ +
JanM A S D
Frequencies required by Code may not be modified (i.e. EC.02.05.07 EP 4 & 8)
SIG Engineering 2011 - 28
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Does Every mean Every ? EC.02.03.05
EP 13 Every 6 months the hospital inspects any automatic fire extinguishing systems in a kitchen. 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
SIG Engineering 2011 - 29
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PRA EC.02.06.05 EPs 2 & 3
Preconstruction Risk Assessment (PRA)Construction or renovation in occupied
healthcare facilities can result in environmental problems such as:NoiseVibration Creation or spread of contaminantsDisruption of essential servicesEmergency ProceduresAir quality
SIG Engineering 2011 - 30
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Interim Life Safety Measures Order of Standards (LS.01.02.01)
EP 1 & 2 regardless of ILSM policyEP 3 must clearly define the ILSM
policy including AFS 13 Process When to implement What to do to protect occupants Both construction related and non-
compliance with the LSCEPs 4 – 14 align with policy and
implementation strategies
SIG Engineering 2011 - 31
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Fire WatchAn organization experiencing a compromising
situation (4 out of 24 hours) must implement a fire watch until the fire alarm system or sprinkler system has been returned to service or is stable. In many situations, this distinction comes
down to whether an event or activity is scheduled or unscheduled.
A scheduled activity would be an event known to and under the knowledge of and control of organization staff a construction project servicing or upgrading the fire alarm system
or sprinkler system.
SIG Engineering 2011 - 32
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Service SituationFire WatchRequired?
ILSM EvaluationRequired?
Putting a shield over one smoke detector to prevent dust/false alarms for more than 4 hours
No Recommended
Rationale: Other features of fire protection are not compromised during the event, such as additional smoke detectors or sprinkler heads in the affected area.
Covering all smoke detectors during a controlled event, such as only during the time contractors are working in an affected area, although after hours, the entire area is fully operational
No Yes
Rationale: During a controlled event the organization is managing the deficien cy. The area would be continually monitored, and ILSM should be implemented as per policy.
Shutting off a zone valve to the sprinkler system or disabling a fire alarm zone for more than 4 hours
● Scheduled event (that is, working on, servicing, or upgrading fire alarm system or sprinkler system)
Not in allcases
Yes (emphasison occupantnotification)
Rationale: During a controlled event, the organization is managing the defi ciency. The area would be continually monitored, and ILSM would be implemented as per policy.
●
Unscheduled event (that is, shutting off a zone valve to the sprinkler system or disabling a smoke zone for more than 4 hours in response to a system failure)
Yes Yes
SIG Engineering 2011 - 33
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EC.02.06.05 EP 1 Effective 1/1/2011 the Joint Commission will
recognize the Facilities Guidelines Institute (FGI) Guidelines for Design & Construction of Health Care Facilities
ASHRAE 170 has been attached to the Guidelines Ventilation Table 20 – 60 % RH requirement of relative humidity in
seven affected areas of the Surgical Environment, and one in Diagnostic & Treatment. NOTE CMS has not adopted this, but remains
at 35 – 60%RH The established 60% upper range however
should be maintained for issues such as mold growth.
SIG Engineering 2011 - 34
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RH% Treatment Areas
Class A Operating/Procedure room Class B and C operating rooms Operating/surgical cystoscopic rooms Delivery room (Caesarean) Treatment rooms Trauma room (crisis or shock) Laser eye room Diagnostic & Treatment: Gastrointestinal
Endoscopy Procedure Room
SIG Engineering 2011 - 35
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General Life Safety Interpretations
ASHRAE 188 Prevention of Legionellosis Associated with Building Water Systems
This 29 page DRAFT document provides guidance related to Legionella mitigationSite survey to identify risk points
i.e. water towers Mitigation strategies
Water treatments • what to do if contamination occurs,
such as secondary treatment
SIG Engineering 2011 - 36
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Central Sterile Layout Physically separated soiled and clean work rooms
Soiled Work Room: Work surface, sink, washer/sterilizer decontaminators Soiled room is not to have direct contact with the OR
Clean assembly /work room Hand washing station Sufficient workspace and equipment
Self-closing door or pass through is acceptable between soiled and clean work rooms
Storage provisions for humidity, temperature, and ventilation Location of storage may be within the clean assembly/
workroom in a permanently designated space
Guidelines for Design & Construction of Health Care Facilities FGI 2010 edition 3.7-5.1.2 - 3.7-5.1.2.3
SIG Engineering 2011 - 37
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Ventilation (Table 7-1)
FunctionPressure
Relationship
Min Outdoor
ACH
Minimum Total ACH
All Room Air
Exhausted Directly Outdoors
Relative Humidity
Design Temp.
°F
Equip. Room
Negative N/R 10 Yes N/R N/R
Soiled or Deconta
mNegative 2 6 Yes N/R 72 – 78
Clean Work Room
Positive 2 4 N/R Max 60 72 – 78
Sterile Storage
Positive 2 4 N/R Max 60 72 – 78
ANSI/ASHRAE/ASHE Standard 170-2008 Table 7-1
SIG Engineering 2011 - 38
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Changes to EC.02.03.05 EP 2
Existing: Every six months the hospital tests
valve tamper switches and water-flow devices. The completion date of the tests is documented.
NOTE: for additional guidance on performing tests see NFPA 72-1999 (Table 7-3.2)
SIG Engineering 2011 - 39
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Changes to EC.02.03.05 EP 2
Revised: EP2 For hospitals that use Joint Commission
accreditation for deemed status purposes: At least quarterly the hospital tests water-flow devices. Every 6 months the hospital tests valve tamper switches. The completion date is documented.
NOTE: For additional guidance on performing tests see NFPA 25-1998 (Section 2-1.3 & 2.3.3) and NPFA 72-1999 (Table 7-3.2 and Section 7-5.2).
SIG Engineering 2011 - 40
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Changes to EC.02.03.05 EP 2
EP 2 (continued) For hospitals that do not use accreditation for deemed status purposes: Every 6 months, the hospital tests valve tamper switches and water-flow devices. The completion date of the tests is documented. Note: For additional guidance on performing tests, see NFPA 72, 1999 edition (Table 7-3.2).
SIG Engineering 2011 - 41
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NEW: EC.02.03.05 EP 25
For hospitals that use Joint Commission accreditation for deemed status purposes:Documentation of maintenance, testing,
and inspection activities for fire alarm and water-based fire protection systems includes the following:
Next Slide for ContentsNote: For additional guidance on documenting
activities: NFPA 25, 1998 edition (Section 2-1.3) NFPA 72, 1999 edition (Section 7-5.2)
SIG Engineering 2011 - 42
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NEW: EC.02.03.05 EP 25Continued Text: Name of the activity Date of the activity Required frequency of the activity Name and contact information,
including affiliation, of the person who performed the activity
NFPA standard(s) referenced for the activity
Results of the activity
SIG Engineering 2011 - 43
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NEW: EC.02.03.05 EP 25
For hospitals that use Joint Commission accreditation for deemed status purposes: Documentation of maintenance,
testing, and inspection activities for fire alarm and water-based fire protection systems includes the following:
Note: For additional guidance on documenting activities: NFPA 25, 1998 edition (Section 2-1.3) NFPA 72, 1999 edition (Section 7-5.2)
SIG Engineering 2011 - 44
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Fire & Smoke Damper Inspections
Ensure inaccessible dampers truly are by random sampling
Confirm ILSM policy is implemented for any horizontal exits or egress enclosures that are compromised by inaccessible dampers
Evaluate adequacy of damper accessibility plan
SIG Engineering 2011 - 45
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LS.02.01.34 EP 2 Master Alarm Panel
The master fire alarm control panel is located in a protected environment (an area enclosed with 1-hour fire-rated walls and ¾ hour fire rated doors) that is continuously occupied OR in an area with a smoke detector. NFPA 72-1999 1-5.6 & 3-8.4.1.3.3.2
SIG Engineering 2011 - 46
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Fire Extinguisher: Dating
Month, day year and initials of inspector as per NFPA 10-1998 EC.02.03.05 EP 15
4-3.4 Inspection Recordkeeping.4-3.4.1 Personnel making inspections shall keep records of all
fire extinguishers inspected, including those found to require corrective action.
4-3.4.2 At least monthly, the date the inspection was performed and the initials of the person performing the inspection shall be recorded.
4-3.4.3 Records shall be kept on a tag or label attached to the fire extinguisher, on an inspection checklist maintained on file, or in an electronic system (e.g., bar coding) that provides a permanent record.
DO NOT COUNT DAYS, BUT ENSURE MONTHLY INSPECTION
SIG Engineering 2011 - 47
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General Life Safety Interpretations
Perimeter shelving and sprinkler provision:Are perimeter wall shelving that
extends to the ceiling required to be fastened to the wall?
NO Shelving is not required for storage There is no correlation between
• Shelving• Clearance • The need to secure any shelving
SIG Engineering 2011 - 48
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18” rule
18”18”
OK OK OKWrong
Wall Wall
Ceiling
Perimeter Shelving Perimeter
Shelving
SIG Engineering 2011 - 49
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General Life Safety Interpretations
Rated doors must have legible labels on the door and jambsJambs prior to 1966 may not have a rating label
Are ILSM in place where non-compliant door assemblies are found?
SIG Engineering 2011 - 50
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General Life Safety Interpretations
Firestop: Existing application is acceptable
whenIt 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
SIG Engineering 2011 - 51
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General Life Safety Interpretations
Expanding foam used for insulation purposes is NOT an acceptable firestop in any fire or smoke barrier This product does have a UL label: for insulation properties
Easily ignited Toxic gases may occur when burned
NOTE: There are several acceptable fire stop products that expand when installed
SIG Engineering 2011 - 52
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Non Flammable Medical Gas Volume & Storage: Scoring
Score EC.02.03.01 EP 1 …fire risk12 ‘E’ cylinders (<300ft³) per smoke compartment
(22,500ft²) may be open to the egress corridor in a rack or appropriate holders
Between 300 and 3000ft³ must be stored in a room that is limited construction with doors that can be locked
“In use” verses “in storage” Properly secured to a gurney is considered “in use” Properly racked is “in storage” Empty are NOT considered part of the 12 in storage Empty and full must be stored (racked) separately
SIG Engineering 2011 - 53
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Non-Flammable Gas Storage: NFPA 99-2005
NFPA 99-2005 edition has additional language regarding O2 storage requirements, specifically:
Storage of nonflammable gases:9.4.1 > 3000 cubic feet9.4.2 300 – 3000 cubic feet 9.4.3 0 - 300 cubic feetOther:5.1.3.3.2 design and construction5.1.3.3.3 ventilation of locations for manifolds5.1.3.3.3.2 ventilation for motor driven equipment5.1.3.3.3.3 ventilation for outdoors
NOTE: CMS also recognizes 9.4.3 reference
SIG Engineering 2011 - 54
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Non-Flammable Medical Gas Unsafe Conditions: Scoring
Score EC.02.06.01 …unsafe condition Unsecured cylinders
Laying on top a gurney mattress; leaning against the wall Free standing
Transfilling liquid oxygen Transfer of any gases from one cylinder to another in patient
care areas of health care facilities is prohibited. Transfilling of liquid oxygen shall be performed in an area that
is• mechanically ventilated• sprinklered• ceramic or concrete flooring• separated with at least 1 hour construction from any patient
care areas
SIG Engineering 2011 - 55
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Tank Farm EC.02.05.09 EP 1 states the hospital tests, inspects and
maintains critical components of the piped medical gas systems. Tank Farm is included in this EP The bulk storage tank(s) and associated systems are
critical components of the piped medical gas system Tanks above ground, not on roofs No electrical service above tanks 10’ Clear from vehicles & sidewalks 50’ from wood frame buildings
• At least 1’-0” from other buildings• At least 10’ form any opening in wall of adjacent
structures• Concrete pads at all spill points (3’ min)
Permanent signage: OXYGEN – NO SMOKING – NO OPEN FLAMES
Access controlled (i.e. locked)
SIG Engineering 2011 - 56
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General Life Safety Interpretations
Q. Is a UPS used to condition power or supply power when normal power is interrupted until emergency power is established a SEPSS?
A. The UPS in this application is a bridging device, and is not a SEPSS
SIG Engineering 2011 - 57
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NFPA 110: Emergency & Standby Power Systems
Automatic Transfer Switches (ATS) are self-acting devices that have normal electrical power entering and leaving the ATS The power continues on to distribution panels
When a ATS senses a disruption in power it sends a signal to the alternative power source seeking power This start circuit initiates the emergency generator
starter The ATS is also equipped with a test switch to
simulate the power disruption Recommended practice is to rotate which ATS
initiates the start circuit to the emergency generator
SIG Engineering 2011 - 58
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General Life Safety Interpretations
Generator Loading The 30% requirement assures the diesel engine achieves correct
operating temperature The output of the EPSS is not as critical as the operating
temperature during the generator tests Two common ratings on the nameplate: KW & Amps The diesel engine drives the alternator, creating electrical charge Power factor and the nameplate ratings
With a static load the power factor is 1.0 With a dynamic load the power factor is .8
The nameplate rating measures the capacity of the system with a diesel engine driving the alternator The 30% is taken from the nameplate without calculating the
power factor EPs 5 & 8: …uses a dynamic or static load that is at least
30% of the nameplate rating…
SIG Engineering 2011 - 59
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General Life Safety Interpretations
ElectricalUnlocked distribution panels in patient
care areas Based on policy Consider risk assessment Score EC.02.01.06 EP 1
Open junction boxes Score at EC.02.03.01 EP 1
• Risk: arcing resulting in fire or loss of service
SIG Engineering 2011 - 60
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General Life Safety Interpretations
Supervisory Signals: EC.02.03.05 EP 1At least quarterly, the hospital tests
supervisory signal devices (except valve tamper switches). The completion date of the tests is documented. Note: For additional guidance on performing tests, see NFPA 72, 1999 edition (Table 7-3.2). Table 7-3.2 actually only states that
Supervisory Signal Devices must be tested quarterly• The Table does not actually define the
specific devices
SIG Engineering 2011 - 61
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General Life Safety Interpretations
EC.02.03.05 EP 1: NFPA 72-1999, 2-9 lists Supervisory Signal Initiating
Devices: 2-9.1 Control Valve Supervisory Signal Initiating
Devices 2-9.2 Pressure Supervisory Signal Initiating Devices 2-9.3 Water Level Supervisory Signal Initiating
Devices 2-9.4 Room Temperature Supervisory Signal
Initiating DevicesThis is further reinforced by the listing in NFPA 72-1999,
Table 7-2.1, 13.h as devices addressed in NFPA 72-1999
SIG Engineering 2011 - 62
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General Life Safety Interpretations Staff Safety
EC.02.02.01 EP 3: Precautions & PPE EP 4: Spill procedures EPs 5 – 10: minimizes risk
EC.04.01.01 EP 1: Monitoring & Reporting EPs 2 – 11: Specifics
Manifests: EP 11DOT training for those signing
SIG Engineering 2011 - 63
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General Life Safety Interpretations
Unsafe Conditions & Suicide Risk EC.02.06.01 EP 1:
Interior Spaces meet the need of the patient population and are safe and suitable to the care, treatment and services provided.
Any unsafe condition can be scored here, provided it is in the patient care interior spaces
Suicide risk may be addressed by clinical interventions or policies Work with other survey team members
SIG Engineering 2011 - 64
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Outdoor Safety
EC.02.01.01 EP 5The hospital maintains all grounds and
equipment Grounds includes
SidewalksParking lotsPark waysPicnic and patio areasPlay structures
SIG Engineering 2011 - 65
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Outdoor Safety
EC.02.01.01 EP 5 The hospital maintains all grounds and
equipment Equipment includes
Lawn maintenance equipment Snow removal equipment Maintenance equipment
Paving Road repair
Lighting
SIG Engineering 2011 - 66
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CE: Lessons Learned from 2010
Scope issues Contamination issues
Alarm HazardsDisabled or otherwise
compromised Telemetry Infusion pumps
Surgical Site FiresSentinel Event Alert
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Defibrillators: FAQ
Q. Are defibrillators considered life support equipment?
A.YES. Maintenance activities then must be identified
for equipment on the inventory A maintenance strategy for defibrillators could
include a range of activities from a visual inspection of the single-use AED (automatic external defibrillator) to the scheduled PM maintenance of a defibrillator
Note: the daily and weekly observations are assessed as per policy (see PC.02.01.11 EP2)
SIG Engineering 2011 - 68
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Emergency Management:Key Concepts
All hazards approachCollaboration with community
partnersSituational awarenessActive mitigation and
preparation, not just a written plan
Monitor and evaluate
SIG Engineering 2011 - 69
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Pre-Session documents
Emergency Operations PlanAll hazards approachAddresses the six critical areasInventory of resources and assets
Hazard Vulnerability Analysis (HVA)Mitigation and preparedness activities
for the top 2 or 3 events Disaster drill and real event evaluations
Monitors and evaluates the six critical areas
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Conducted by EM Committee/Team Use Multi-disciplinary Approach
Experts within your facility Community
Share information with: Community-prioritizes events Hospital Leadership
For each emergency, the organization defines Mitigation, Preparation, Response,
Recovery Directs the survey process related to EM
Hazard Vulnerability Analysis
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Six Critical Areas
1. Communication2. Resources & Assets3. Safety & Security 4. Staff Responsibilities 5. Utilities Management6. Patient Clinical & Support
Activities
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Overview of the 2011 EM Changes
Stand alone EM session Up to 90 minutes
Focus on mitigation and preparedness No disaster scenarios; use hospital
disaster critiques Data collection tool and EM Tips
document Focused discussion on six critical areas Look at resources and assets inventory;
appropriate storage, expirations, training
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Questions?
SIG Engineering 2011 - 74
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SIG Engineers: 630 792 5900
George Mills, MBA, FASHE, CEM, CHFM, CHSP
Senior Engineer SIG
Michael Chisholm, CPE, CHFM
Engineer SIG
Anne Guglielmo, CFPS, LEED, A.P., CHSP
Engineer SIG
SIG Engineering 2011 - 75
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The Joint Commission Disclaimer
These slides are current as of 4/22/2011. The Joint Commission reserves the right to change the content of the information, as appropriate.
These slides are only meant to be cue points, which were expounded upon verbally by the original presenter and are not meant to be comprehensive statements of standards interpretation or represent all the content of the presentation. Thus, care should be exercised in interpreting Joint Commission requirements based solely on the content of these slides.
These slides are copyrighted and may not be further used, shared or distributed without permission of the original presenter or The Joint Commission.
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Surveying
Maintenance Strategies
Medical EquipmentUtilities Systems
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Changes to EC.02.03.05 EP 2
Existing: Every six months the hospital tests
valve tamper switches and water-flow devices. The completion date of the tests is documented.
NOTE: for additional guidance on performing tests see NFPA 72-1999 (Table 7-3.2)
SIG Engineering 2011 - 78
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Changes to EC.02.03.05 EP 2
Revised: EP2 For hospitals that use Joint Commission
accreditation for deemed status purposes: At least quarterly the hospital tests water-flow devices. Every 6 months the hospital tests valve tamper switches. The completion date is documented.
NOTE: For additional guidance on performing tests see NFPA 25-1998 (Section 2-1.3 & 2.3.3) and NPFA 72-1999 (Table 7-3.2 and Section 7-5.2).
SIG Engineering 2011 - 79
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Changes to EC.02.03.05 EP 2
EP 2 (continued) For hospitals that do not use accreditation for deemed status purposes: Every 6 months, the hospital tests valve tamper switches and water-flow devices. The completion date of the tests is documented. Note: For additional guidance on performing tests, see NFPA 72, 1999 edition (Table 7-3.2).
SIG Engineering 2011 - 80
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NEW: EC.02.03.05 EP 25
For hospitals that use Joint Commission accreditation for deemed status purposes:Documentation of maintenance, testing,
and inspection activities for fire alarm and water-based fire protection systems includes the following:
Next Slide for ContentsNote: For additional guidance on documenting
activities: NFPA 25, 1998 edition (Section 2-1.3) NFPA 72, 1999 edition (Section 7-5.2)
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NEW: EC.02.03.05 EP 25Continued Text: Name of the activity Date of the activity Required frequency of the activity Name and contact information,
including affiliation, of the person who performed the activity
NFPA standard(s) referenced for the activity
Results of the activity
SIG Engineering 2011 - 82
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NEW: EC.02.03.05 EP 25
For hospitals that use Joint Commission accreditation for deemed status purposes: Documentation of maintenance,
testing, and inspection activities for fire alarm and water-based fire protection systems includes the following:
Note: For additional guidance on documenting activities: NFPA 25, 1998 edition (Section 2-1.3) NFPA 72, 1999 edition (Section 7-5.2)
SIG Engineering 2011 - 83
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Fire & Smoke Damper Inspections
Ensure inaccessible dampers truly are by random sampling
Confirm ILSM policy is implemented for any horizontal exits or egress enclosures that are compromised by inaccessible dampers
Evaluate adequacy of damper accessibility plan
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LS.02.01.34 EP 2 Master Alarm Panel
The master fire alarm control panel is located in a protected environment (an area enclosed with 1-hour fire-rated walls and ¾ hour fire rated doors) that is continuously occupied OR in an area with a smoke detector. NFPA 72-1999 1-5.6 & 3-8.4.1.3.3.2
SIG Engineering 2011 - 85
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Fire Extinguisher: Dating
Month, day year and initials of inspector as per NFPA 10-1998 EC.02.03.05 EP 15
4-3.4 Inspection Recordkeeping.4-3.4.1 Personnel making inspections shall keep records of all
fire extinguishers inspected, including those found to require corrective action.
4-3.4.2 At least monthly, the date the inspection was performed and the initials of the person performing the inspection shall be recorded.
4-3.4.3 Records shall be kept on a tag or label attached to the fire extinguisher, on an inspection checklist maintained on file, or in an electronic system (e.g., bar coding) that provides a permanent record.
DO NOT COUNT DAYS, BUT ENSURE MONTHLY INSPECTION
SIG Engineering 2011 - 86
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CMS Conditions of Participation
42 CFR 482.41 Hospital must maintain adequate facilities for its
services
42 CFR 482.41(c)(2) Facilities, supplies and equipment must be
maintained to ensure an acceptable level of safety and quality.
The CMS Interpretive Guideline states “the hospital must monitor, test, calibrate and maintain equipment periodically in accordance with the manufacturer’s recommendation and Fed and State law.”
SIG Engineering 2011 - 87
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CMS Conditions of Participation
The Interpretive Guideline states the hospital must monitor, test, calibrate and maintain equipment periodically in accordance with the manufacturer’s recommendation and Federal and State law.
Medical Equipment includes Biomedical equipment Radiological equipment Patient beds, stretchers IV infusion equipment Ventilators Laboratory equipment Etc.
SIG Engineering 2011 - 88
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CMS Conditions of Participation
The Interpretive Guideline states the hospital must monitor, test, calibrate and maintain equipment periodically in accordance with the manufacturer’s recommendation and Federal and State law.
Utility Systems and Equipment includes Elevators Generators Air handlers Medical gas systems Air compressors Vacuum systems Etc.
SIG Engineering 2011 - 89
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Manufacturer’s Recommendations
In January 2010 a formal complaint was made to CMS regarding this issue
The Joint Commission advocated to CMS the importance of allowing the organizations to continue using the Joint Commission process
Based on these discussions, CMS noted that they “understand the principles behind applying risk assessment and hospital experience to the frequency of hospital preventive maintenance”
SIG Engineering 2011 - 90
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CMS Response
CMS technical review team has completed its review if the Joint Commission’s submission of surveyor instructions and survey protocol for evaluating an organizations preventive maintenance schedule. The purpose of this review was to ensure that Joint Commission’s surveyors were properly trained to evaluate the adequacey of an organization’s recommended frequency of preventive maintenance.
SIG Engineering 2011 - 91
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CMS Response
I am happy to inform you that the Joint Commission’s approach of utilizing a preventive maintenance schedule has been approved. Thank you for your cooperation and collaboration.
CMS Deputy Director July 26, 2010
SIG Engineering 2011 - 92
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EC.02.04.01 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.02.04.03, EPs 1 and 3)
SIG Engineering 2011 - 93
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EC.02.05.01 EP 2
The hospital maintains a written inventory of all operating components of utility systems or maintains a written inventory of selected operating components of utility systems based on risks for infection, occupant needs, and systems critical to patient care (including all life-support systems).
The hospital evaluates new types of utility components before initial use to determine whether they should be included in the inventory.
(See also EC.02.05.05, EPs 1, 3-5)
SIG Engineering 2011 - 94
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Maintaining Medical Equipment
Inventory is populated based on one of two strategies: All equipment inclusion Physical risk based process
For example, evaluating:• Function• Risk Levels• Maintenance Requirement
Utilize resources, i.e. the FDA MAUDE report All life support equipment is included All new types of equipment evaluated for inclusion
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Maintaining Utilities Equipment Inventory is populated based on one of two
strategies: All equipment inclusion Based on physical risks for
Infection Occupant needs Systems critical to patient care
All life support equipment is included All new types of equipment is evaluated for
inclusion
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Joint Commission Medical Equipment
Medical equipment includes equipment used in Life support, such as
anesthesia machines ventilators defibrillators heart-lung machines
Monitoring, such asBedside monitors Telemetry monitors
SIG Engineering 2011 - 97
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Joint Commission Medical Equipment Treatment, such as
Electrosurgery Lasers Diathermy
Diagnostic, such as Laboratory analyzers Radiology equipment Endoscopes
Patient support, such as Patient beds Specialty beds Lifts
Taken from the Environment of Care Handbook
Chapter 5 (page 73) 3rd edition
SIG Engineering 2011 - 98
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Joint Commission Utilities Equipment
Utility System as defined in the Accreditation Manuals Glossary and EC.02.05.03 include:
Electrical distribution Emergency Power Supply System (EPSS) Vertical & Horizontal Transport Heating, Ventilation & Air Conditioning Plumbing Boiler and Steam Piped Gases Vacuum Systems Communication Systems & Data Exchange
SIG Engineering 2011 - 99
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Joint Commission Utilities Equipment
Specific Utility Systems include Features of Fire Safety (EC.02.03.01) Alarm and Notification (LS.02.01.34) Suppression Systems (LS.02.01.35) Design criteria (EC.02.05.01) Power Distribution System (EC.02.05.03) Emergency Power Supply Systems (EC.02.05.07) Medical Gases (EC.02.05.09)
Specific populations of equipment Life support systems (EC.02.05.05) Infection Control utility systems (EC.02.05.05)
SIG Engineering 2011 - 100
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EC.02.04.01 EP 3
The hospital identifies the activities, in writing, for maintaining, inspecting, and testing for all medical equipment on the inventory.
(See also EC.02.04.03, EPs 2 and 3)
Note: Hospitals may use different strategies for different items as appropriate. For example, strategies such as predictive maintenance, reliability-centered maintenance, interval-based inspections, corrective maintenance, or metered maintenance may be selected to ensure reliable performance.
SIG Engineering 2011 - 101
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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; 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 maintenance, corrective maintenance, or metered maintenance may be selected to ensure dependable performance.
SIG Engineering 2011 - 102
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Maintaining Equipment: Strategies Written strategies identify the activities for
Maintaining Inspection Testing
Strategies may include Predictive maintenance Reliability-centered maintenance Interval based maintenance Corrective maintenance Metered maintenance Other recognized strategy
Manufacture’s recommendations
SIG Engineering 2011 - 103
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Maintenance Strategies Preventive Maintenance
The scheduled activities designed to extend equipment reliability based on performing activities prior to equipment failure based on risk levels and organization experience
Interval Based Maintenance The scheduled activities are based on a preset
schedule that is established regardless of need Determine Interval Time:
Manufacturer’s guidelines Accepted industry practices Regulatory code requirements Organization’s past experiences
Most preventive maintenance software programs are “Interval-Based”
SIG Engineering 2011 - 104
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Maintenance Strategies
Reliability-Centered MaintenanceBased on historical analysis of the
reliability of equipment Anticipated maintenance activities to
extend the reliability based on intersecting historical failure
Metered MaintenanceBased on established amount of time
the equipment has operated rather than a calendar schedule
SIG Engineering 2011 - 105
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Maintenance Strategies Corrective Maintenance
Equipment is not serviced based on preventive models, but allowed to run until repairs are needed
Also includes response to any corrective measures related to the physical environment
Other, such as manufacturer’s recommendations Always during warranty period Evaluate against other strategies
SIG Engineering 2011 - 106
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EC.02.04.01 EP 4
The hospital identifies, in writing, frequencies for inspecting, testing, and maintaining medical equipment on the inventory based on criteria such as manufacturer’s recommendations risk levelscurrent hospital experience
(See also EC.02.04.03, EPs 2 and 3)
SIG Engineering 2011 - 107
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EC.02.05.01 EP 4
The hospital identifies, in writing, the intervals for inspecting, testing, and maintaining all operating components of the utility systems on the inventory, based on criteria such asManufacturer‘s recommendationsRisk levelshospital experience
(See also EC.02.05.05, EPs 3-5)
SIG Engineering 2011 - 108
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Maintenance Frequencies
Manufacturer’s RecommendationsNew equipment that has no operating
history should follow manufacturer’s recommendations until enough history and level of risk has been established
Industry experience has established that often manufacturer’s recommendations are based on worse-case situations and may exceed the normal operating condition level maintenance activity
SIG Engineering 2011 - 109
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Maintenance Frequencies
Risk levels Evaluating the potential risk of equipment
failure is a significant part of evaluating maintaining, inspecting and testing requirements
Based on physical risks impact for Infection Occupant needs Systems critical to patient care
SIG Engineering 2011 - 110
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Maintenance Frequencies
Hospital experienceEvaluating the benefits of maintaining,
inspecting and testing activities based on history may contribute to increasing or extending those activity periods
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Case Study #1 A manufacturer’s recommendation for telemetry
monitors required the Clinical Engineer open the monitor case and inspect for dust
Hospital experience identified that those monitors that were opened tended to fail before those monitors that were not opened • the factory assembly was essentially air and
dust free, once opened the seal was compromised
Should the organization continue to open the monitor cases?
Would it be acceptable to conduct a visual inspection of the case and service on an “as needed” basis?
SIG Engineering 2011 - 112
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Case Study #2 A manufacturer’s recommendation for an air
handler required the Building Engineer to change the filters on a quarterly frequency based on the manufacturer’s industrial application
Hospital experience identified that those filters were not soiled to the point where they needed to be changed at the end of the quarter• Slightly soiled filters actually increase the
efficiencies The organization determined that by measuring
the pressure differential across the filter bank the filters could be replaced semi-annually
Should the organization continue to change the filters quarterly?
SIG Engineering 2011 - 113
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Case Study #3
A manufacture of a device that may be used in either an ambulance or in an ICU created its manufacturer’s recommendations
• The manufacturer’s recommendations were based on the unit being used in the field, which would be the more extreme environment
Would the manufacturer’s recommendations be appropriate for the device in the ambulance?
Would the manufacturer’s recommendations be appropriate for the device on the ICU?
SIG Engineering 2011 - 114
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Case Study #4
Manufacturer’s recommendations for greasing a 165# washer is 2 strokes of the grease gun per week to the main bearing • This was based on industrial laundry
applications running two shifts per day, 6 days per week
The Facility Director determined that the frequency was excessive as the hospital laundry is operated one shift per day for 5 days per week
Should the organization change to every other week grease application although the manufacturer’s recommendations is weekly?
SIG Engineering 2011 - 115
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EC.02.04.03 The hospital inspects, tests, and maintains medical equipment
EP 2. The hospital inspects, tests, and maintains all life support equipment. These activities are documented. (See also EC.02.04.01, EPs 3 and 4; PC.02.01.11, EP 2)
EP 3. The hospital inspects, tests, and maintains non-life support equipment identified on the medical equipment inventory. These activities are documented. (See also EC.02.04.01, EPs 2-4 and PC.02.01.11, EP 2)
SIG Engineering 2011 - 116
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EC.02.05.05: The hospital inspects, tests, and maintains utility systems
EP 2. The hospital inspects, tests, and maintains the following: Life support utility system components on the inventory. These activities are documented. (See also EC.02.05.01, EPs 2-4)
EP 3. The hospital inspects, tests, and maintains non-life support equipment identified on the medical equipment inventory. These activities are documented. (See also EC.02.04.01, EPs 2-4 and PC.02.01.11, EP 2)
EP 4. The hospital inspects, tests, and maintains the following: Infection control utility system components on the inventory. These activities are documented. (See also EC.02.05.01, EPs 2-4)
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Survey Process
Document Review Evaluate the Management Plan
Determine the Maintenance Strategies applied to the inspection, testing and maintenance of the equipment
Evaluate the work completion rates (% complete) To compute the percent complete divide the
number of devices completed by the number of scheduled work orders
Example:795 devices completed out of 825 scheduled = 96.4%
795 ÷ 825 = 96.36
SIG Engineering 2011 - 118
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Survey Process: Medical Equipment
Evaluate the program documentation Logs are completed and reflect both Life Support
devices and non-life support devices Accuracy of Inventory
All Life Support equipment must be represented on the inventory
Preventive maintenance frequencies must be clearly defined in writing
Confirm work done as per scheduled activities Ensure appropriate work is scheduled based on
maintenance strategies Evaluate device failure against scheduled actions
SIG Engineering 2011 - 119
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Survey Process: Utility Systems
Evaluate the program documentation Logs are completed and reflect both Life Support
Systems, Infection Control equipment, and Non-life support equipment on the inventory
Accuracy of Inventory All Life Support equipment must be represented
on the inventory Preventive maintenance frequencies must be
clearly defined in writing Confirm work done as per scheduled activities
Ensure appropriate work is scheduled based on maintenance strategies
Evaluate equipment failure and scheduled actions
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Survey Process: Staff Interviews
Department Leader Establish how the inventory was created Establish the Maintenance Strategies used Evaluate the Monitoring processes Evaluate the effectiveness of the program
Equipment Maintainers Evaluate their understanding of the maintenance
process/strategies Evaluate competencies based on repeat work
orders Evaluate work scheduled against completed
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Survey Process: Staff Interview
Users of the Equipment Evaluate equipment reliability Evaluate response time when equipment fails
Evaluate emergency response process Evaluate “Culture of Safety”
Appropriate training of staff related to equipment use
Customer satisfaction with department Contract Services
Evaluate reliability of equipment serviced Evaluate integration of the process
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Survey Process
Evaluate the effectiveness of the program to maintain the equipment Repeat work orders Equipment turn-around time Completion rates
Evaluate confidence of the users while using equipment
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Questions?
SIG Engineering 2011 - 124
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SIG Engineers: 630 792 5900
George Mills, MBA, FASHE, CEM, CHFM, CHSP
Senior Engineer SIG
Michael Chisholm, CPE, CHFM
Engineer SIG
Anne Guglielmo, CFPS, LEED, A.P., CHSP
Engineer SIG
SIG Engineering 2011 - 125
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The Joint Commission Disclaimer
These slides are current as of 4/22/2011. The Joint Commission reserves the right to change the content of the information, as appropriate.
These slides are only meant to be cue points, which were expounded upon verbally by the original presenter and are not meant to be comprehensive statements of standards interpretation or represent all the content of the presentation. Thus, care should be exercised in interpreting Joint Commission requirements based solely on the content of these slides.
These slides are copyrighted and may not be further used, shared or distributed without permission of the original presenter or The Joint Commission.