The Centers for Disease Control and Prevention (CDC) and American Water Works Association (AWWA) recently released a guide entitled Emergency Water Supply Planning Guide for Hos-pitals and Health Care Facilities¹. Guidance is provided to assist health care facilities in developing an Emergency Water Supply Plan (EWSP) that prepares for, responds to, and recovers from a partial or total interruption of the normal water supply. Obviously a water supply loss would have a significant adverse effect on the daily operations of any health care facility, potentially affecting both patient safety and the quality of patient care. While there is little that can be done to prevent losing an offsite supply, develop-ing and exercising an EWSP can help lessen the impact should such an incident occur. The CDC EWSP Guide provides a four-step process for devel-oping an emergency water supply plan:

1. Assemble the appropriate EWSP team and the necessary background documents for your facility;

2. Understand your water usage by performing a water use audit;

3. Analyze your emergency water supply alternatives; and, 4. Develop and exercise your EWSP.

The Joint Commission accreditation standards require an Emer-gency Operations Plan that calls for organizations to have alterna-tive means of providing for essential utilities during different types of emergencies, including the disruption or loss of its water supply. 2011 Emergency Management Standard EM.02.02.09, “As part of its Emergency Operations Plan, the hospital prepares for how it will manage utilities during an emergency.” Element of Performance (EP) 3 - Water needed for consumption and essential care activi-ties. Element of Performance (EP) 4 - Water needed for equip-ment and sanitary purposes. Det Norske Veritas (DNV) Healthcare’s National Integrated Ac-creditation for Healthcare Organizations (NIAHOSM) Interpretive Guidelines, PE.6 Emergency Management System Standard SR.5

also has similar requirements for the loss of essential utility sys-tems including water. “SR.5 The Emergency Management System processes shall address alternative means to support essential building functions such as …, water,… and other identified utilities.” The Centers for Medicare & Medicaid Services (CMS) Conditions of Participation 42 CFR 482.41 CoP: Physical Environment also require that health care facilities develop plans for loss of essential utilities during emergency situations including water. When and if possible, hospitals should identify more than one wa-ter supplier outside of the local community in case the community’s infrastructure is severely compromised and not able to support the hospital due to an incident or disaster.

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By Dean Samet , CHSP dsamet@ssr- Inc .com

P R E P A R I N G A N E M E R G E N C Y W A T E R S U P P LY P L A N

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The CDC EWSP Guide provides several examples of water usage to consider when developing an emergency water sup-ply plan:

• Hand washing and hygiene• Drinking at faucets and fountains• Food preparation• Flushing toilets and bathing patients • Laundry and other services provided by central ser-

vices (e.g., cleaning and sterilization of surgical in-struments)

• Reprocessing of medical equipment, including that typically performed by special services (e.g., bron-choscopy, gastroenterology)

• Patient care (e.g., hemodialysis, hemofiltration, extra-corporeal membrane oxygenation, hydrotherapy)

• Radiology• Fire suppression sprinkler systems• Water-cooled medical gas and suction compressors • Heating, ventilation, and air conditioning (HVAC)• Decontamination/hazmat response

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S E P T E M B E R / O C T O B E R 2011

Every health care facility, large or small, should have an emer-gency water supply plan (EWSP) to ensure patient safety and quality of patient care while responding to and recovering from a water emer-gency, whether it’s for a short or long duration. For more information go to: 1) www.awwa.org

2) www.cdc.gov/healthywater/pdf/emergency/emergency- water-supply-planning-guide.pdf

¹) Emergency Water Supply Planning Guide for Hospitals and Health Care Facilities. Atlanta: U.S. Department of Health and Human Services; 2011

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PLENUM REQUIREMENTS FOR EGRESS CORRIDORSIN HE A LTH CARE FACILIT IES

By Rober t Trot ter, CBO, CFM r t ro t ter @ssr- Inc .com

In the built environment a plenum is a separate space for air circu-lation for HVAC systems, typically provided in the space between the structural floor/ceiling and suspended-grid acoustical tile ceil-ing. Incorporating a plenum can have its design advantages but corridors serving adjoining ar-eas of health care occupancies are prohibited from being used for a portion of an air supply, air return, or exhaust air plenum.

Using building cavities as return air plenums can draw them below atmospheric pressure if not properly designed, causing outdoor air to be drawn into the building fabric. In humid climates, this can result in condensation of moisture from outdoor air within architectural cavities, conse-quently resulting in mold and mildew growth. Also, under certain circumstances, plenum configurations can have an adverse ef-fect on life/fire safety. Clearly, plenum returns should not be used where codes prohibit them, such as health care occupancies, where individual space pressures must be controlled. These pro-visions are prescribed in the NFPA 101®, Life Safety Code® and NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems.

Health care organizations that receive Medicare and Medic-aid funding from The Centers for Medicare & Medicaid Services (CMS) must comply with the 2000 edition of NFPA 101®, Life Safety Code®. Chapter 18 New Health Care Occupancies, sec-tion 18.5.2.1 and Chapter 19 Existing Health Care Occupancies,

section 19.5.2.1 under Building Services both state, “Heating, ven-tilating, and air conditioning shall comply with the provisions of Section 9.2 and shall be installed in accordance with the manufac-

turer’s specifications.” Life Safety Code sec-tion 9.2 states “Air conditioning, heating, ven-tilating ductwork, and related equipment shall be in accordance with NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems, or NFPA 90B, Standard for the Installation of Warm Air Heating and Air-Conditioning Systems, as applicable, un-less existing installations, which shall be per-mitted to be continued in service, subject to approval by the authority having jurisdiction.”

Any hospital accredited by The Joint Commission must comply with the 2011 Hospital Accreditation Standards. Specifically, Life Safety Standard LS.02.01.30 Element of Performance 13, “Cor-ridors serving adjoining areas are not used for a portion of an air supply, air return, or exhaust air plenum.”

Note: The Joint Commission interprets the NFPA code to allow incidental air movement between rooms and corridors (such as isolation rooms) because of the need for pressure differentials in health care facilities. In such cases, the direction of airflow is not the focus for this element of performance. For the purpose of fire protection, air transfer should be limited to the amount necessary to maintain positive or negative pressure differentials. (For full text and any exceptions, refer to NFPA 90A-1999: 2-3.11.1.)

PREPA RING A N EM ERGENCY WATER SUPPLY PL A N (C o n t i nu e d f r o m pa g e 1 )

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Section 2-3.11.1 states: Egress corridors in health care, de-tention and correctional, and residential occupancies shall not be used as a portion of a supply, return, or exhaust air system serving adjoining areas. An air transfer opening(s) shall not be permitted in walls or in doors separating egress corridors from adjoining areas.

• Exception No. 1: Toilet rooms, bathrooms, shower rooms, sink closets, and similar auxiliary spaces opening directly onto the egress corridor.

• Exception No. 3: Use of egress corridors as part of an en-gineered smoke-control system.

Fire in egress corridor scenario: With a plenum arrangement with a diffuser or return air grille located in the egress corridor, as well as adjoining areas such as patient rooms, the above-men-tioned provisions would be prohibited in health care occupancies. Smoke and products of combustion accumulating in the plenum would be able to enter the patient rooms through the return air grille, resulting in a critical life safety consideration. Fire in egress corridor scenario: With a plenum arrangement with a diffuser or return air grille located in the egress corridor and ducted HVAC for the adjoining areas such as patient rooms, the above-mentioned provisions would be acceptable in health care occupancies because the plenum would not be serving adjoining areas. Smoke and products of combustion accumulating in the plenum would not be able to enter the patient rooms. Fire in patient room scenario: With a plenum arrangement with a diffuser or return air grille located in the egress corridor and ducted HVAC for the adjoining areas such as patient rooms, the

above-mentioned provisions would be acceptable in health care occupancies because the plenum would not be serving adjoining areas. Smoke and products of combustion accumulating in the room would not be able to enter the plenum, nor could they enter patient spaces through the return air grille in the corridor. When the plenum is found to serve adjoining areas in existing health care occupancies, corrections must be made to bring the building into compliance. An evaluation of the design and as-built conditions are important in taking corrective measures. Where corridor walls extend to the floor or roof deck above, smoke damp-ers may be an option to separate the egress corridor from ad-joining areas. Under this arrangement, the plenum would be fully functional during normal operating conditions, but upon activation of a fire alarm system the dampers should automatically close. Depending on the number of openings to protect in corridor walls above the ceiling, another option is to install ceiling dampers at the return air locations. The ceiling dampers installed in corridors at the return air locations may be the most cost-effective way to separate the egress corridor from adjoining areas and achieve compliance.

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PLENUM REQUIREM ENTS FOR EG RESS CORRIDORS IN HE A LTH CA RE FACILIT IES (C o n t i nu e d f r o m pa g e 2 )

Note: This article is based upon the comprehensive cover story article by Bob Trotter entitled “Plenum Requirements for Egress Corridors in Health Care Environments” in the July 2011 edition of Engineered Systems (Volume 28 No. 7) www.esmagazine.com. For further information, please contact Bob at: rtrotter@ssr-inc.com

PUBLICATIONS AND SEMINARS

SeminarsSeptember 27 27th Annual AHCA Seminar, Orlando, FL, “NFPA 110/111 Updates”September 28 Florida Healthcare Engineering Association Annual Meeting, Orlando, FL, “Life Safety Accreditation and EC Hot Spots”October 21 AlaSHE Fall Conference, Montgomery, AL, “Continuous Compliance - Maintaining Constant Survey Readiness”October 24 Decision Health EC Summit, Las Vegas, NV, “Overcoming Environment of Care and Life Safety Accreditation Challenges”November 1-3 Tennessee Hospital Association Technical and Educational Exposition, Nashville, TN, “Avoiding Life Safety Accreditation Vulnerabilities,” “Impact of new Energy Codes,” and “Post Occupancy Building Commissioning Successes”

S EP T EM B ER /O CTO B ER 2011

The 2000 edition of NFPA 101®, Life Safety Code® re-quires all occupied rooms in a health care facility to have direct access to a cor-ridor leading to an exit, or must be arranged to com-ply with one of the exemp-tions. The term “habitable

room” does not include bathrooms, closets, and similar spaces as well as briefly occupied work spaces. Section 19.2.5.1 states “Every habitable room shall have an exit access door leading di-rectly to an exit access corridor.” There are four exceptions to the prescriptive requirement:

Exception No. 1: If there is an exit door opening directly to the outside from the room at ground level.Exception No. 2: Exit access from a patient sleeping room with not more than eight patient beds shall be permitted to pass through one intervening room to reach the exit access corridor.Exception No. 3: Exit access from a special nursing suite shall be permitted to pass through one intervening room to reach the exit access corridor where the arrangement allows for direct and constant visual supervision by nursing personnel.Exception No. 4: Exit access from a suite of rooms, other than patient sleeping rooms, shall be permitted to pass through not more than two adjacent rooms to reach the exit access corridor where the travel distance within the suite is in accordance with 19.2.5.8. [One intervening room if the travel distance within the suite to the exit access door does not exceed 100 feet (ex-ample pictured above) and two intervening rooms where the travel distance within the suite to the exit access door does not exceed 50 feet.]

Consult the Life Safety Code® for additional requirements re-lated to suites of sleeping rooms, and suites of rooms, other than patient sleeping rooms.

Arrangement of Means of Egress – Corridors Leading to Two ExitsFor health care occupan-cies Section 19.2.5.9 of the 2000 edition of NFPA 101®, Life Safety Code® states “Every corridor shall pro-

vide access to not less than two approved exits in accordance with Sections 7.4 [number of means of egress] and 7.5 [arrangement of means of egress] without passing through any intervening rooms or spaces other than corridors or lobbies.” This would include pro-hibited travel through a suite, hazardous areas, and rehabilitation rooms such as the example pictured. It is important to note that ev-ery exit or exit access should be arranged, if practical and feasible, so that no corridor, passageway, or aisle has a pocket or dead end exceeding 30 feet. When updating life safety drawings, look for opportunities to create suites.

Arrangement of Means of Egress – Two Means of EgressAccording to the 2000 edition of NFPA 101®, Life Safety Code® the provision of 18/19.2.5.2 requires a second exit access door from any patient sleeping room or suite of sleeping rooms that exceeds 1000 square feet. Likewise, the provision of 18/19.2.5.3 requires a second exit access door from any non-sleeping room or suite of rooms other than sleeping that ex-ceeds 2,500 square feet. The two exit access doors must be remote-ly located from each other. In order to comply with the remoteness re-

quirement for exit access doors, consider the following:1. The two exit access doors must be separated by

a distance, d, that is one-third the room diagonal measurement, D, for sprinklered buildings.

2. The two exit access doors must be separated by a distance, d, that is one-half the room diagonal m e a s u r e -ment, D, for non-sprinklered buildings.

This remote rule addresses the concern that a large area with only one exit access door might allow a fire near the door to grow to the extent that the path of travel would no longer provide a ten-able egress path.

ARR ANGEMENT OF ME ANS OF EGRESS

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Compl iance News is a news le t ter ded icated to acc red i ta t ion, regu la tor y compl iance and fac i l i t y management issues fo r hea l thcare execut ives and fac i l i t y managers .

For more in fo rmat ion, p lease contac t Dean Samet , CHSP, 800 - 5 45 - 6732; dsamet@ssr- inc .com

By Rober t Trot ter, CBO, CFM r t ro t ter @ssr- Inc .com