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CMS - Frequently Asked Questions |
Starting January 1, 2008 KFSMO Inspectors will no longer be conducting 50% inspections on a project remoldel or addition, see link for more information. Q: Recently a question has been asked if candles are allowed to be used at supervised acivities. For example, at a sit-down dinner in the dining room of a facility with several staff members, residents, and members of the public present, could a candle be burning in the middle of each table? A: This would be allowed only for special occasions, and this activity must be monitored by staff 24/7. Q: Can up to 300 cu ft of nonflammable medical gas (12 E sized cylinders) associated with patient care be located outside of an enclosure at locations open to the corridor in a healthcare facility? A: Yes, up to 300 cu ft of nonflammable medical gas can be located outside of an enclosure (per smoke compartment) at locations open to the corridor such as at a nurse's station or in a corridor of a healthcare facility. This amount of nonflammable medical gas per smoke compartment is not considered a hazard if the containers are properly secured, such as in a rack to prevent them from tipping over or being damaged. In this case the medical gas is considered an "operational supply" and not storage. If the cylinders are placed in a corridor they should be placed so as not to obstruct the use of the corridor. This amount of medical gas is in addition to those cylinders contained in "crash carts" and in use on wheelchairs or gurneys. Q: When medical gases are used by patients on a “PRN” basis does the container have to be stored in an approved gas storage room when not being used? A: The term “PRN” means “as needed.” An individual cylinder placed in a patient room for immediate use by a patient is not required to be stored in an enclosure and is considered in use. It should be secured to prevent tipping or damage to the cylinder. If the resident does not need the use of oxygen for an extended period of time, such as several days, then the medical gas container should be removed from the room and properly secured in an approved storage room. Q: Could the interpretive guidelines explain that handrails are not necessary at the very ends of the hallways on the very small sides of the door? This would allow for filling these unused areas with live plants, for instance, without obstructing egress and handrails would still be available up to the end of each hallway. A: The purpose of the handrail requirement is to assist residents with ambulation and/or wheelchair navigation. They are a safety device as well as a mobility enhancer for those residents who need assistance. They survey team onsite would need to observe the responses of residents to the placement of object that block the portion of the handrails that is at the end of a hallway. They would also interview residents to gain their opinion as to whether the objects in questions are interfering with their independence in navigating to the places they wish to go. Q: Does the 8 feet requirement (at LSC Tag 39) continue to be necessary since evacuations are no longer done via wheeling a person out of the building in a bed? Could 6 feet the requirement? If 6 feet sufficed, this would again refer back to our question regarding the requirement for handrails when something else such as a bench might take up the other 2 feet. A: The 8 foot corridor width is a requirement of the LSC. Corridors remain a route to use in internal movement of residents in an emergency situation to areas of safety in different parts of the facility. This movement may be by beds, gurney or other methods which may require the full width of the corridor. We do not believe it would be in the best interest of the residents to reduce the level of safety in a facility. Q: In regard to LSC Tag 72 (no furnishings, decorations, or other objects are placed to obstruct exits or visibility of exits), can secured unit doors be disguised or masked with murals, etc? Staff typically will be the ones to use these doors in the case of emergency and will know where they are. By disguising exit doors, resident anxiety of wanting to go out them may decrease. A: The life safety code allows some coverings on doors, but not concealment. The code also specifically forbids the use of mirrors on a door. It is a judgment call by the survey team as to what would be considered concealment of the door, but in general the door must still be recognizable by a non-impaired person (such as a visitor). The code does not allow the removal or concealment of exit signs, door handles, or door opening hardware. Q: Can candles be used in nursing homes under supervision, in sprinklered facilities? A: Regarding the request to use candles in sprinklered facilities under staff supervision, National Fire Protection Association data shows candles to be the number one cause of fire in dwellings. Candles cannot be used in resident rooms, but may be used in other locations where they are placed in a substantial candle holder and supervised at all times while they are lighted. Lighted candles are not to be handled by residents due to the risk of fire and burns. Q: In a fully sprinklered building, must a hazardous room or area have one-hour separation? A: If you have a fully sprinklered building, and the hazardous room does not meet the one hour requirement, this is acceptable as long as the door resist the passage of smoke, is self closing or automatic closing. The code requires: 19.3.2.1: So if you have a room that meets the sprinkler requirement you do not need to cite this if there door resist the passage of smoke. Now if it doesn't then you must cite it. Q. A question has been asked concerning smoke barrier walls? See link for answer. Q: A facility has converted a number of our incandescent bulbs to GE's energy smart bulbs which they believe are a type of florescent bulbs. They understand that we are not use incandescent of more than 60 watt; these 13 watt energy smart bulbs put out the same as a 60 watt incandescent bulb. Does that allow a facility to use higher rated energy smart bulbs for a brighter light? A: All light fixtures have a rating and the bulb used should not exceed that rating. From what I have researched, it is not safe to use a higher compact florescent light bulb than what is recommended on the package or at the following web sites. http://www.alliantenergy.com/docs/groups/public/documents/pub/p012396.hcsp Wattage Screw-in CFL's come in wattages from 5 to 40 watts. Hard-wired CFL's can go up to 55 Watts. The list below shows the CFL wattage required for roughly the same light output as standard incandescent bulbs:
A safe rule of thumb of 3:1 for incandescent to CFL wattage can be applied
when determining appropriate replacement CFL's for incandescent bulbs. Q. What do we need to do to be in compliance with K-tag K14 on interior finish? A. If your facility has applied any product for interior finish to meet the Code requirement make sure you are putting the documentation in your Fire Book. Also, when choosing your product make sure you read and understand the re-application process (how often, how much etc.) Also, document who applied the product, the date the product was applied and the areas the product was applied to. Document all this information each time the product is reapplied. For proof of documentation, pictures are worth a thousand words. NFPA standard for carpeted walls: Interior wall and ceiling finish materials complying with 10.2.3 shall be permitted as follows: Existing materials - Class A or Class B. Exception: In rooms protected by an approved, supervised automatic sprinkler system, existing Class C interior finish shall be permitted to be continued to be used on walls and ceilings within rooms separated from the exit access corridors in accordance with 19.3.6. 2000 NFPA 101, 19.3.3.2 NFPA standard: Requires the use of textile materials on walls or ceilings shall be limited as specified in 2000 NFPA 101, 10.2.4.1.1 through 10.2.4.1.5. NFPA standard for paneling: Interior wall and ceiling finish materials complying with 10.2.3 shall be permitted as follows: Existing materials - Class A or Class B. Exception: In rooms protected by an approved, supervised automatic sprinkler system, existing Class C interior finish shall be permitted to be continued to be used on walls and ceilings within rooms separated from the exit access corridors in accordance with 19.3.6. 2000 NFPA 101, 19.3.3.2 Q. What are the requirements for a remote annunciator panel for an emergency generator? A. The requirements can depend on the type of facility and type of generator. Please review this document for clarification on what standards are applicable and what the requirements are. Q. In my last survey, I was cited for having 30-second magnetic locks on my doors. I thought this was permissible. Why was it cited? A. When KSFMO inspects a facility that has a 30 second delay with a magnetic lock on any exit doors, this will be cited as a deficiency. The Life Safety Code NFPA 101, 2000 edition only allows up to a 15 second delay, but has an exception to allow the Authority Having Jurisdiction to allow up 30 seconds. But in order for us to be able to allow this we must see how many you have and their locations. Your local inspector cannot approve the 30 second delay; this must be approved by the Topeka Office. What will you need to do once you have been cited for this? You will be advised by your local inspector that you are required to submit an annual waiver request along with your Plan of Correction explaining the reason why the 30 second magnetic locks are necessary, how many doors are affected, and where the doors are located throughout your facility. Through our enforcement process KSFMO will then determine if this will be acceptable. Q. When is it acceptable to have rooms open to the corridor? A. There are some very specific circumstances in which is acceptable under currently adopted codes. For more information, view this explanation.
CMS has requested information be forwarded. If a facility has a waiver in place for K69 citation that we have been told not to continue citing, please direct them to write a letter concerning which citation along with a copy of the waiver and we will take care of that specific citation. If the K69 citation has already been corrected there is nothing we can do concerning that situation. If you have questions call Brenda McNorton at 785-296-3401. When a facility prepares their plan of correction response, all deficiencies cited need to indicate a completion date within 30 days from the date the KSFM inspection was completed. However, if a facility submits waiver requests, the completion date on the 2567 form and the 2786R (waiver request form) need to match. For example; KSFM inspection was completed on 7/1/2007, and a waiver request is submitted for K12, K29 and K69 with a completion date of 11/1/2007 for each deficiency, the completion date on the 2567 form should also be written as 11/1/2007 for each of these deficiencies.
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