CMS Corridor Obstructions Stance Revised - NEHES

1 Volume 8 / Issue 4 July / August 2010 CMS Corridor Obstructions Stance Revised IN THIS ISSUE: Corridor ObstructionsArc flash SafetyPolyurethane Expanding FoamHumidity Levels in ORsElevatorsFire Sprinkler SystemsPublications / SeminarsBy Dean Samet, CHSP - a May 14, 2010 Centers for Medicare & Medicaid Services memorandum, Ref: S&C-10-18-LSC, CMS announced changes to previous policies regarding the use of Corridor wall-mounted computer touch screens in healthcare facilities. CMS is now allowing certain wall-mounted technologies and other items to be wall-mounted in corridors as long as they don t project out more than six inches from the Corridor wall or conflict with other sections of the National Fire Protection Association s Life Safety Code.

2 The projections shall:1) Not project out more than 6 inches 2) Not exceed a length of 36 inches 3) Be separated by at least 48 inches from other projections4) Be installed at least 40 inches or greater above the floor 5) Be installed in corridors that are at least 6 feet in width Note: The above dimensions are consistent with the 2009 edition of the NFPA 101 Life Safety Code , sections 18 Other items of similar dimensions may be mounted to Corridor walls such as [non-combustible] artwork and wreaths, sharps disposal units, infection control supply cabinets, and lighting devices.

3 Policies and procedures should be developed and enforced before allowing placement of any such items. CMS goes on to explain that the placement of items associated with the use of these wall-mounted pieces of equipment in corridors such as chairs, tables, carts, cabinets, etc., which would reduce the Corridor width below the allowable limits, would not be permitted when not in use. This includes keyboard trays and equipment doors that project more than six inches into the Corridor when in use. Such items shall be closed or retracted when the equipment is not in use or is unattended for any period of time.

4 An item is considered not in use if it is left unattended or is not moved for more than 30 minutes. Items such as linen carts, medication carts, and janitorial equipment would not be included in these exclusions. However, infection control supply carts/cabinets outside of a specific room are allowed in the Corridor while precautions are in effect or in force for that specific room. Crash carts are also allowed in the corridors for quick access in an emergency. The above information is current CMS policy as of May 14, 2010.. items shall be closed or retracted when the equipment is not in use.

5 Dean is the Director of Regulatory Compliance Services for Smith Seckman Reid, Inc. where he is responsible for heading up and coordinating efforts of SSR s Compliance & Facility Management consulting team. He brings 35 plus years of combined construction management, safety, and The Joint Commission (TJC) experience. Dean served with TJC for 17 years and was an Associate Director, the Senior Engineer and a Certified Joint Commission Surveyor. Dean was a TJC/JCR faculty member, speaker and surveyor trainer. He was also The Joint Commission s chief liaison to the NFPA, ASHE, AIA, DOD, VA, IHS, and CMS for EC issues.

6 He has co-authored the Environment of Care Essentials, Engineering Handbook, and EC News. The AuthorPhoto 2009 arc flash Safety - Part 2: How close is too close?By David Stymiest, PE, FASHE, CHFM, GBE - 1 explained why this issue is 70E defines a series of boundaries related to electrical safety near energized equipment. These boundaries can be based on the voltage; the available short-circuit current and the predicted fault duration. The definitions are not repeated here, but the following considerations are useful to gain an overview of the issues involved.

7 flash Protection Boundary an imaginary boundary within which there is the potential for a second-degree burn injury. Fire resistive protection (also called PPE) is required. This is the first item that must be determined by an arc flash hazard analysis. Limited Approach Boundary previously described as working near but terminology was changed to reflect that non-work activities can be equally dangerous when carried out within this boundary. Some incidents have shown that arcs occurred even with equipment doors closed, an arc flash can cause equipment doors to bulge or become missiles, and hot gases can escape through equipment ventilation louvers.

8 Restricted Approach Boundary this is a shock protection boundary unrelated to arc flash or incident energy, rather it invokes where special considerations and constant supervision by qualified workers are required for unqualified workers. (A qualified worker must possess the necessary skills and knowledge, must have received relevant safety training, and according to OSHA must have also demonstrated these skills and knowledge.) Prohibited Approach Boundary this is also a shock protection boundary unrelated to arc flash or incident energy.

9 It must not be crossed without full-voltage PPE and possession of an authorized (signed) energized work permit. The worker must also comply with all other restrictions and controls of the electrical safety article is based upon a portion of the author s Health Facilities Management magazine article entitled Shock Resistant Preventing arc- flash hazards in the hospital setting. Segments reprinted from Health Facilities Management, by permission, October 2009, Copyright 2009, by Health Forum, Inc. Contact David Stymiest at for more information.

10 Polyurethane Expanding FoamBy Robert Trotter, CBO, CFM - use of polyurethane expanding foam is expressly not permitted by The Joint Commission for sealing penetrations in fire-rated walls and floors. According to the 2010 Hospital Accreditation Standards Element of Performance 9, The space around pipes, conduits, bus ducts, cables, wires, air ducts, or pneumatic tubes that penetrate fire-rated walls and floors are protected with an approved fire-rated material. The Joint Commission included this specific note, Polyurethane expanding foam is not an acceptable fire-rated material for this purpose.