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2017
John Maurer, SASHE, CHFM, CHSP
Engineering Department
The Joint Commission
Engineering Department 2017- 1
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The Healthcare Environment
Update
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Survey Process
Survey Process
 Agenda for Life Safety surveyor
 Evaluation starts upon arrival
 Specified OR Survey time
both customers and surveyors
 Time allotted for primary surveyor
responsibilities
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 A single document list and tracking tool for
Primary LSCS Survey Responsibilities
 LS.01.01.01 (SOC)
 LS.01.02.01 (ILSM)
 EC.02.03.01 (Fire Response Plan)
 EC.02.03.03 (Fire Drills)
 EC.02.03.05 (Fire Equipment Maintenance)
 EC.02.05.07 (Emergency Power Testing)
 EC.02.05.09 (Piped Medical Gas Testing and
cylinders management)
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 EC.02.05.01 (EP 15 – Pressure Relationships)
Survey Resource
Activity Guide has been updated to include “Life
Safety and Environment of Care—Document List
and Review Tool”
 This new resource is located on The Joint
Commission website at
http://www.jointcommission.org/life_safety_
code_information__resources/
 This resource is also at the Joint Commission
Connect™ extranet site
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 To prepare for document review, the Survey
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Pre-Survey Checklist: EC & LS
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Pre-Survey Checklist: EC & LS
LS/EC Document List & Review Tool
 Same tool for surveyor
and organization
 Serves as organization
prep tool and tracking
tool during survey
 Identifies frequency
 Relates to standard/EP
 Request reflects scope
of survey
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requirements
EC Documents
 If Primary Survey
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Responsibility
completed and LSCS
will be conducting the
EC Session, review
these documents
Building Tour Guidance
should include
 Lists related
standards/EPs
 Only guidance
 Does not reflect
touring order
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 Reflects what a tour
Survey Analysis For Evaluating Risk
(SAFER) Matrix
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See also January 2017 Perspectives
What is SAFER™?
 The Survey Analysis for Evaluating Risk™ (SAFER™) is a transformative
approach for identifying and communicating risk levels associated with
deficiencies cited during surveys. The additional information related to risk
provided by the SAFER Matrix helps organizations prioritize and focus
corrective actions.
 The SAFER Matrix™ provides one, comprehensive visual representation of
 The SAFER Matrix replaces the current scoring methodology, which is based
on pre-determined categorizations of elements of performance (such as direct
and indirect impact) – instead allowing surveyors to perform real-time, on-site
evaluations of deficiencies. Placement of RFIs within the matrix will determine
the level of detail required within each RFI’s Evidence of Standards
Compliance follow-up.
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survey findings in which all Requirements for Improvement (RFIs) are plotted
on the SAFER matrix™ according to the likelihood of the issue to cause harm to
patients, staff or visitors, in addition to how widespread the problem is, based
on the surveyor’s observations.
The Joint Commission’s Survey Analysis
for Evaluating Risk (SAFER) Matrix™
HIGH
MODERATE
LOW
LIMITED
PATTERN
Scope
WIDESPREAD
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Likelihood to Harm a Patient/Staff/Visitor
Immediate Threat to Life
Customer Impacts
 No more Direct and Indirect EP designations
 All ESC now 60-day time frame
 Consolidated Evidence of Standards Compliance (ESC)
into one time frame
 No more Measures of Success (MOS)
 See it / Cite it
 No more A or C categories
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 No more Opportunities for Improvement (OFIs)
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Post-Survey Actions
“After a survey event, organizations have
the opportunity to submit clarifying ESC if
they believe that their organization was in
compliance with a particular standard
at the time of survey.”
ACC-59
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What is Clarification?
Clarification
 Eligible
 Observations made in error
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 Ineligible
 Required documentation; i.e. “D” icons
 SAFER placement
Evidence of Standards Compliance (ESC)
 ESC due within 60 days

45 day ESC still applicable for organizations with a PDA
decision
 All observations will require an ESC

OFI section of the report no longer applicable
fields
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 Findings of higher risk will require 2 additional ESC
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Prioritized Follow-up Action
Challenging Standards
John Maurer, SASHE, CHFM, CHSP
Engineering Department
The Joint Commission
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Most Cited Observations
EC.02.06.01
2015 %
Noncompliance
62%
2016 %
Noncompliance
68%
2016
Rank
1
IC.02.02.01
EC.02.05.01
LS.02.01.35
LS.02.01.30
59%
58%
46%
50%
60%
57%
49%
51%
2
3
4
5
LS.02.01.20
LS.02.01.10
EC.02.02.01
51%
45%
39%
46%
50%
48%
6
7
8
PC.02.01.03
RC.01.01.01
40%
47%
47%
42%
9
10
Standard
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Most Cited Standards
EC.02.06.01 EP 1
 Interior spaces meet the needs of the patient
population and are safe and suitable to the care,
treatment and services provided.




2017 Scoring at EC.02.05.09 EP 6 NEW!
Storage – Secured, labeled, etc.
Segregation – Full vs. Empty
NFPA 99 – 2012
• Chapter 11 – Gas Equipment
• Chapter 5 – Gas and Vacuum
Systems
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 Cylinder management
EC.02.06.01 EP 1
 Interior spaces meet the needs of the patient
population and are safe and suitable to the care,
treatment and services provided.






2017 Scoring at EC.02.05.09 EP 7 NEW!
Previously scored at EC.02.01.01 EP 5
Secured
Protected for the elements (sun, snow, water, etc.)
Protective shipping mesh or wraps
NFPA 99 – 2012
• Chapter 5 – Gas and Vacuum Systems
• Chapter 11 – Gas Equipment
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 Outside Cylinder Management
EC.02.06.01 EP 1
 Interior spaces meet the needs of the patient
population and are safe and suitable to the care,
treatment and services provided.
 Relocatable Power Taps (Power Strips)
 2017 Scoring at EC.02.04.03 EP 14 if in patient care area NEW!
 EC.02.06.01 EP 1 if non-patient care
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 NFPA 99 – 2012
Relocatable Power Taps
 RPTs may be used for non-patient care equipment such

ensuring they are never “daisy-chained”

preventing cords from becoming tripping hazards

installing internal ground fault and over-current protection
devices

using power strips that are adequate for the number and types
of devices used
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as computers/monitors/printers, and in areas such as
waiting rooms, offices, nurse stations, support areas,
corridors, etc.
 Precautions needed if RPTs are used include:
Definitions From NFPA 99-2012
patient sleeping bed, or the bed or procedure table of a critical care area
 Patient-care-related electrical equipment is defined in section 3.3.137 as
electrical equipment that is intended to be used for diagnostic,
therapeutic, or monitoring purposes in the patient care vicinity
 Patient care room is defined in section 3.3.138 as any room of a health
care facility wherein patients are intended to be examined or treated.
Note that this term replaces the term “patient care area” used in the
1999 NFPA 99, but the definition has not changed
 Patient care vicinity is defined in section 3.3.139 as a space, within a
location intended for the examination and treatment of patients (i.e.,
patient care room) extending 6 ft. beyond the normal location of the bed,
chair, table, treadmill, or other device that supports the patient during
examination and treatment and extends vertically 7 ft. 6 in. above the
floor
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 Patient bed location is defined in section 3.3.136 as the location of a
RPT Requirements
 Power strips may be used in a patient care vicinity to power

The receptacles are permanently attached to the equipment
assembly

The sum of the ampacity of all appliances connected to the
receptacles shall not exceed 75 percent of the ampacity of the
flexible cord supplying the receptacles

The ampacity of the flexible cord is suitable in accordance with the
current edition of NFPA 70, National Electric Code.

The electrical and mechanical integrity of the assembly is regularly
verified and documented through an ongoing maintenance program

Means are employed to ensure that additional devices or nonmedical
equipment cannot be connected to the multiple outlet extension
cord after leakage currents have been verifiedEngineering
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rack-, table-, pedestal-or cart-mounted patient care-related
electrical equipment assemblies, provided all of the following
conditions are met, as required by section 10.2.3.6:
RPT Requirements
 Patient bed locations in new health care facilities, or
in existing facilities that undergo renovation or a
change in occupancy, shall be provided with the
minimum number of receptacles as required by
section 6.3.2.2.6.2
pedestal-, or cart-mounted patient care-related
electrical equipment assemblies are not required to
be an integral component of manufacturer tested
equipment. Power strips may be permanently
attached to mounted equipment assemblies by
personnel who are qualified to ensure compliance
with section 10.2.3.6
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 Power strips providing power to rack-, table-,
RPT Requirements
power non-patient care-related electrical equipment (e.g.,
personal electronics)
 Power strips may be used outside of the patient care
vicinity for both patient care-related electrical equipment &
non-patient-care-related electrical equipment
 Power strips providing power to patient care-related
electrical equipment must be Special-Purpose Relocatable
Power Taps (SPRPT) listed as UL 1363A or UL 60601-1
 Power strips providing power to non- patient-care-related
electrical equipment must be Relocatable Power Taps (RPT)
listed as UL 1363
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 Power strips may not be used in a patient care vicinity to
EC.02.06.01 EP 1
 Interior spaces meet the needs of the patient
population and are safe and suitable to the care,
treatment and services provided.
 Ligature/self harm risks (i.e. BHC)

Current Risk Assessment
Best Practice Guidelines
• Design Guide for the Built Environment of Behavioral
Health Facilities
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
Ligature Risks – Psychiatric Settings
See also Joint Commission Online, March 1, 2017
www.jointcommission.org/issues
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 Process: self-harm risks identified
 Determination if previously identified
 Evaluate existing plans for removing the risks
 Evaluate the environmental risk assessment
process
Ligature Risks – Psychiatric Settings
See also Joint Commission Online, March 1, 2017
www.jointcommission.org/issues
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 Further evaluation
 Plans and policies on mitigation of harm
posed by risks while removal occurs
 Adequacy of staffing patterns to the
mitigation plans
 The patient suicide risk assessment process
Ligature Risks – Psychiatric Settings
 The history of patient safety events and the
process for root cause analysis of these events
 The organization’s process for monitoring its
compliance with its policies
 Actions taken when noncompliance was identified
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 Further evaluation
 Policies and practices related to actions
needed for patients identified at risk
 Policies and processes of ensuring staff
awareness of a patient’s level of risk
 The organization’s internal processes for
improvement, including:
IMPACT OF CMS ADOPTION OF THE
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2012 LIFE SAFETY CODE (NFPA 101-2012)
2012 HEALTH CARE FACILITIES (NFPA 99-2012)
Standards – NFPA 101-2012
 The NFPA created a series of codes to provide guidance
in building and maintaining buildings

CMS adopted this body of codes, incorporating them into their
COP as K-Tags

The Joint Commission has also recognized the NFPA body of
codes
 The Life Safety Chapter is based on NFPA 101-2012
 In the Environment of Care several other NFPA
• NFPA 10-2010, Standard for Portable Fire Extinguishers
• NFPA 25-2011, Standard for Water-based Systems ITM
Activity
• NFPA 72-2010, Fire Alarm Code
• NFPA 99-2012, Health Care Facilities Code
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codes are referenced, including:
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New vs. Existing Occupancies
 Existing Health Care
 Buildings, additions, renovations or changes in
occupancy whose final plans were approved by the local
Authority Having Jurisdiction (AHJ) prior to July 5th, 2016
 Use Chapter 19 of the NFPA 101-2012 Life Safety Code®
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 New Health Care
 Buildings, additions, renovations or changes in
occupancy whose final plans were approved by the local
AHJ after July 5th, 2016
 Use Chapter 18 of the NFPA 101-2012 Life Safety Code®
CMS Information
 Tuesday May, 3, 2016 CMS issued the final rule
adopting the 2012 Life Safety Code®. The rule is
effective July 5, 2016

This rule also adopts most of NFPA 99, 2012 edition.
Chapters 7, 8, 12, 13 are excluded from the adoption
Survey for compliance November 1, 2016
 Emergency Management
 Published September 8, 2016
 Implementation by November 15, 2017
 Standards under review
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
NFPA 99-2012: Risk-based
 Chapter 4: Building systems shall be designed to
meet Category 1-4



Category 1: Failure likely to cause major injury of
death
Category 2: Failure likely to cause minor injury
Category 3: Failure to cause discomfort
Category 4: Failure with no impact to care
 Risk assessment
 Categories determined by organization’s risk
assessment procedure
 Chapters identify new vs. existing application
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
NFPA 99-2012 Adoption Exclusions
 Chapter 7: IT and Communication Systems
 Chapter 8: Plumbing
 Chapter 12: Emergency Management
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 Chapter 13: Security Management
CMS statement:
“As stated in the proposed rule, we will not be
adopting Chapters 7, 8 and 13 because we have no
authority to regulate these specific topics in health
care facilities. Additionally, the content of Chapter
12, Emergency management, is already being
addressed in a separate rule for emergency
preparedness. Although, we have not adopted
these chapters, providers may use these chapters
for their individual facility needs.”
Source: Federal Register, Vol. 81, No. 86
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NFPA 99-2012 Adoption Exclusions
CMS Adoption Issues
 Roller latches continue to be prohibited


Corridor doors
Doors protecting hazardous areas
 ASC that renders one or more incapable continue to be
AHC

Outpatient surgical departments
provisions of the Life Safety Code for unreasonable
hardship
 Hospitals may install ABHR provided the installation
adequately protects against inappropriate access
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 There is a provision to allow CMS to waive specific
While CMS does not directly enforce the Americans with
Disabilities Act (ADA) it does expect compliance with the
requirements as additional Federal requirements that
facilities are required to follow.
An example of this is corridor projections where the Life
Safety Code (LSC) allows a noncontinuous projection to
be no more than 6 inches from the corridor wall.
Section 307 of the ADA Accessibility Guidelines for
Buildings and Facilities” requires that projections be not
more than 4 inches from the corridor wall. Facilities are
required to meet this more stringent requirement as set
forth by the ADA.
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CMS Quote:
CMS Adoption Issues
 If the sprinkler system is shut down for 10 or more hours, a
fire watch or evacuation of the building or affected portion of
the building must occur
 Every sleeping room has outside door or window

Windows in atrium walls are considered outside windows

Exception: newborn nurseries and rooms intended for less than 24hour stays (see NFPA 101-2006 18/19.3.8)
higher than 36 inches above the floor (with exceptions, see
NFPA 101-2006 18/19.3.8.2)
 Required sprinkler protection of all high rises (>75 ft)
 Includes Chapter 43, Building Rehabilitation
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 In new buildings the fixed window sill height is to be no
Impact to Standards [Estimated for 2017]
 Environment of Care
149 – 1 = 148 + 13 = 161
31 modifications
203 – 5 = 198 +21 = 219
32 modifications
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 Life Safety Chapter
2017
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Environment of Care
Chapter
EC.02.02.01 EP 9
 The hospital minimizes risks associated with
Note: Hazardous gases and vapors include, but are not
limited to, ethylene oxide and nitrous oxide gases; vapors
generated by glutaraldehyde; cauterizing equipment, such as
lasers; waste anesthetic gas disposal (WAGD); and
laboratory rooftop exhaust. (For full text, refer to NFPA 992012: 9.3.8; 9.3.9)
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selecting, handling, storing, transporting, using,
and disposing of hazardous gases and vapors.
EC.02.03.05 EP 25
 The hospital has written documentation of annual
inspection and testing of door assemblies by
individuals who can demonstrate knowledge and
understanding of the operating components of the
door being tested. Testing begins with a pre-test
visual inspection; testing includes both sides of the
opening.
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Note: For additional guidance on testing of door assemblies, see
NFPA 101-2012: 7.2.1.5.10.1; 7.2.1.5.11; NFPA 80-2010: 4.8.4;
5.2.1; 5.2.3; 5.2.4; 5.2.6; 5.2.7; 6.3.1.7; NFPA 105-2010: 5.2.1.
EC.02.03.05 EP 25
 When the door rating of a higher rating than
required in an opening

May be modified provided they continue to meet the
requirements of the barrier
Barrier and door information is documented on the Life
Safety Drawings
 Label may remain if the door was not modified (i.e. hardware
intact).
 If the organization chose to remove the hardware, the label
should also be removed as the door no longer meets original
design.
 If the door was intact but in a lesser barrier (i.e. 90 minute door
in a 30 minute barrier), the label could remain as part of the
original assembly.
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
EC.02.05.01 EP 8
 The hospital labels utility system controls
Note 1: Examples of utility system controls that
should be labeled are utility source valves, utility
system main switches and valves, and individual
circuits in an electrical distribution panel.
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to facilitate partial or complete emergency
shutdowns.
Note 2: For example, the fire alarm system’s
circuit is clearly labeled as Fire Alarm Circuit;
the disconnect method (that is, the circuit
breaker) is marked in red; and access is
restricted to authorized personnel. Information
regarding the dedicated branch circuit for the
fire alarm panel is located in the control unit.
For additional guidance, see NFPA 101-2012:
18/19.3.4.1; 9.6.1.3; NFPA 72-2010: 10.5.5.2.
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EC.02.05.01 EP 8 (cont.)
EC.02.05.01 EP 18
 Medical gas storage rooms and transfer
and manifold rooms comply with NFPA 992012: 9.3.7.
Ventilation
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
EC.02.05.01 EP 19
equipment and environment are
maintained per manufacturers’
recommendations, including ambient
temperature of at least 40°F; ventilation
supply and exhaust; and water jacket
temperature (when required). (For full
text, refer to NFPA 99-2012: 9.3.10)
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 The emergency power supply system’s
EC.02.05.03 EP 10
seconds for the following: Emergency lighting at
emergency generator locations. The hospital’s
emergency power system (EPS) has a remote
manual stop station (with identifying label) to
prevent inadvertent or unintentional operation.
A remote annunciator (powered by storage
battery) is located outside the EPS location.
Note: For guidance in establishing a reliable emergency
power system (that is, an essential electrical distribution
system), refer to NFPA 99-2012: 6.4.1.1.6; 6.4.1.1.17;
6.4.2.2.3.3; NFPA 110-2010: 5.6.5.6; 7.3.1.
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 The hospital provides emergency power within 10
EC.02.06.05 EP 2
 When planning for demolition, construction,
Note: See LS.01.02.01 for information on fire safety
procedures to implement during construction or
renovation.
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renovation, or general maintenance, the
hospital conducts a preconstruction risk
assessment for air quality requirements,
infection control, utility requirements, noise,
vibration, and other hazards that affect care,
treatment, and services.
EC.02.05.05 EP 1
 When performing repairs or maintenance
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activities, the hospital has a process to manage
risks associated with air-quality requirements;
infection control; utility requirements; noise,
odor, dust, vibration; and other hazards that
affect care, treatment, or services for patients,
staff, and visitors.
Medical Equipment & Utilities Systems
 All scheduled maintenance activities for
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non-high-risk medical equipment and utility
systems components in an alternative
equipment maintenance (AEM) program
inventory are to be completed at 100%.
AEM frequency is determined by the
organization AEM program.
Medical Equipment Note 3 Update
 …Scheduled maintenance activities for non-high-risk
medical equipment in an alternative equipment
maintenance (AEM) program may be deferred … provided
the completion rate is not less than 90%
for AEM for non-high-risk medical equipment. CMS
indicated that 100% of the maintenance has to be
completed and that AEM is performed at a frequency
defined by the organization’s AEM program
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 CMS response: Note allows for completion rate of 90%
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Life Safety
Chapter
2017
LS.01.01.01 EP 2
 In time frames defined by the hospital, the
hospital performs a building assessment to
determine compliance with the Life Safety
chapter.
Requires documentation of the policy
 Policy requires time frame
 Policy on how an assessment is completed
 Does not include review of results of
assessment
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
The hospital maintains current and accurate drawings denoting
features of fire safety and related square footage.
Fire safety features include the following:
 Areas of the building that are fully sprinklered (if the building is
partially sprinklered)
 Locations of all hazardous storage areas
 Locations of all fire-rated barriers
 Locations of all smoke-rated barriers
 Sleeping and non-sleeping suite boundaries, including the size of
the identified suites
 Locations of designated smoke compartments
 Locations of chutes and shafts
 Any approved equivalencies or waivers
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LS.01.01.01 EP 3
When the hospital plans to resolve a deficiency through a Survey-Related
Plan for Improvement (SPFI), the hospital meets the 60-day time
frame.
Note 1: If the corrective action will exceed the 60-day time frame, the
hospital must request a time-limited waiver within 30 days from the
end of survey.
Note 2: If there are alternative systems, methods, or devices considered
equivalent, the hospital may submit an equivalency request using its
Statement of Conditions (SOC).
Note 3: For hospitals that use Joint Commission accreditation for deemed
status purposes: if there are existing alternative systems, methods, or
devices, the hospital may submit a waiver request using their
Statement of Conditions (SOC).
Note 4: For additional guidance on equivalencies, see NFPA 2012:
101:1.4.3
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LS.01.01.01 EP 4
EP 5 For hospitals that use Joint Commission
accreditation for deemed status purposes: The
hospital maintains documentation of any
inspections and approvals made by state or local
fire control agencies.
EP 6 The hospital does not remove or minimize an
existing life safety feature when such feature is a
requirement for new construction. Existing life
safety features, if not required by the Life Safety
Code, can be either maintained or removed. (For
full text, refer to NFPA 101-2012: 4.6.12.2;
4.6.12.3)
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LS.01.01.01 EP 5 & 6
LS.02.01.34 EP 3
 EP 3 The ceiling membrane is installed and
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maintained in a manner that permits
activation of the smoke detection system.
(For full text, refer to NFPA 101-2012:
18/19.3.4.1)
LS.02.01.35 EP 5
also free from corrosion, foreign materials,
and paint and have necessary escutcheon
plates installed. (For full text, refer to
NFPA 101-2012: 18.3.5.1; 19.3.5.3; 9.7.5;
NFPA 25-2011: 5.2.1.1.1; 5.2.1.1.2; NFPA
13-2010: 6.2.6.2.2; 6.2.7.1)
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 Sprinkler heads are not damaged. They are
LS.02.01.35 EP 10
portable fire extinguisher is 75 feet or less. Portable
fire extinguishers have appropriate signage, are
installed either in a cabinet or secured on a hanger
made for the extinguisher, and are at least four
inches off the floor. Those fire extinguishers that are
40 pounds or less are installed so the top is not
more than 5 feet above the floor. (For full text, refer
to NFPA 101-2012: 18/19.3.5.12; 9.7.4.1; NFPA 102010: 6.2.1.1; 6.1.3.3.1; 6.1.3.4; 6.1.3.8)
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 The travel distance from any point to the nearest
LS.02.01.70 EP 1
compartment where flammable liquids, combustible
gases, or oxygen is used or stored; these areas have
signs that read “NO SMOKING” or display the
international symbol for no smoking. In facilities
where smoking is prohibited and signs are
prominently placed at all major entrances, secondary
signs that prohibit smoking in hazardous areas are
not required. (For full text, refer to NFPA 101-2012:
18/19.7.4)
Note: The secondary sign exception is not applicable to medical
gas storage areas.
Engineering Department 2017- 67
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 Smoking is prohibited in any room, ward, or
LS.02.01.70 EP 2
ashtrays are safely designed and made of
noncombustible material. Metal containers
with self-closing cover devices in which
ashtrays can be emptied are readily
available to all areas where smoking is
permitted. (For full text, refer to NFPA 1012012: 18/19.7.4)
Engineering Department 2017- 68
© Copyright, The Joint Commission
 In areas where smoking is permitted,
Department of Engineering
630-792-5900
George Mills, MBA, FASHE, CEM, CHFM, CHSP, Green Belt
Director
Andrea Browne, PhD., DABR
John Maurer, CHFM, CHSP, SASHE
Medical Physicist
Engineer
Engineer
James Woodson, P.E., CHFM
Engineer
Kathy Tolomeo,
CHEM, CHSP
Engineer
Kate Dolezal,
MA, CRC, LPC
Technical Coordinator
Engineering Department 2017- 69
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Herman McKenzie, MBA, CHSP
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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
Engineering Department 2017- 70
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 These slides are current as of 3/24/2016.