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CMS released proposed rule to adopt NFPA 101®, Life Safety Code®, 2012 with certain modifications and also to adopt the majority of NFPA 99 Health Care Facilities Code, 2012 Edition. While the adoption of NFPA 99 and NFPA 101, 2012 editions is supported by ASHE, a few of the proposed modifications listed below which will have a great impact health care organizations:
- The requirements of the LSC and NFPA 99 must be met regardless of the number of patients served.
- Hospital departments which provide treatment to one inpatient must be classified as a health care occupancy
- Satellite facilities which provide general anesthesia to one patient must be classified as an ambulatory health care occupancy
i. Based on billing of hospital-based provider services in outpatient buildings
- Fire watch / building evacuation is required after 4 hours of a sprinkler system being out of service in lieu of 10 hours.
- Windowless anesthetizing locations must be provided with smoke control.
- Patient sleeping rooms require an outside window/door and sill height must not be greater than 36 inches above floor
- Current wording applies to existing construction
- Does not apply to newborn nurseries
- Existing roller latches not permitted on corridor doors
- Alcohol based hand rub must be adequately protected against inappropriate access
Comments are due by June 16, 2014. Tip on draft comments are as follows:
- Be concise and support your claims
- Provide sound reasoning, scientific evidence, and how the adoption will affect your facility
- Assess trade-offs and opposing views
- Provide as much information as necessary to support your claims
- If you are commenting on a particular word, phrase, or sentence, provide page number, column, and paragraph citation from the Federal Register document
- Contact CASHE code advocacy liaison (Lennon Peake, lpeake @koffel.com) for this information if having difficulty
Click on the link below to make a comment.
Lets make a difference and let CMS know what you think.
Lennon Peake, P.E.
Licensed In MD, PA, CA
Fire Protection Engineers: Expertly Engineering Safety From Fire