* EC: CMS Adopts 2012 Life Safety Code® and 2012 Health Care Facilities Code: Long-awaited decision allows hospitals to take advantage of patient-centric elements (PDF) REF: CMS, EC] EC News, July 2016, Vol 19, #7, Pg 1 JCe1607_B6

The CMS final rule on Fire Safety Requirements for Certain Health Care Facilities (CMS–3277–F) was published on 5/4/16 and went into effect earlier this month (July 5). With this ruling, CMS adopts National Fire Protection Association’s (NFPA) 2012 Life Safety Code®* (NFPA101-2012) and the 2012 Health Care Facilities Code (NFPA 99-2012). TJC plans to follow suit and will update its standards “in the near future”. Here are some additional points to keep in mind:
• CMS is retaining some 2000 Life Safety Code (LSC) requirements as exceptions in its adoption of the 2012 codes (e.g., disallowing roller latches on doors in hazardous areas and corridors). A sidebar on page 3 lists some of the new requirements and exceptions.
• The 8 categorical waivers (identified in a sidebar on page 4) established in the Survey and Cert Letter 13-58 of 2013 are no longer necessary as those issues are now addressed in the 2012 codes.
• Some of the main 2012 requirements according to a CMS press release on 5/6/16 include the following:

– Health care facilities located in buildings that are taller than 75 feet are required to install automatic sprinkler systems within 12 years after the rule’s effective date.
– Health care facilities are required to have a fire watch or building evacuation if their sprinkler systems is out of service for more than ten hours.
– The provisions offer LTC facilities greater flexibility in what they can place in corridors. Currently, they cannot include benches or other seating areas because of fire code requirements limiting potential barriers to firefighters. Moving forward, LTC facilities will be able to include more home-like items such as fixed seating in the corridor for resting and certain decorations in patient rooms (such as pictures and other items of home décor).
– Fireplaces will be permitted in smoke compartments without a one hour fire wall rating, which makes a facility more home-like for residents.
– Cooking facilities now may have an opening to the hallway corridor. This will permit residents of inpatient facilities such as nursing homes to make food for themselves or others if they choose to, and, if the patient does decide to make food, facility staff is able to provide supervision of the patient.
– For ASCs, all doors to hazardous areas must be self-closing or must close automatically. Additionally, alcohol based hand rub dispensers now may be placed in corridors to allow for easier access.

According to the article, if your organization is in compliance with the 2000 LSC, than you should also be compliant with the 2012 edition, especially if you were using any of the categorical waivers. However, there was a suggestion that some of an organization’s plans may need to be adjusted and a recommendation for key staff (e.g., chief engineer, facility directors, safety officers) to obtain and review a comparison crosswalk for the two codes. There was specific reference to ASHE’s Life Safety Code® Comparison that identifies the changes between the 2000, 2009 and 2012 code editions.
Tip: Try to obtain a copy of the ASHE crosswalk to identify new requirements may require updating of your plans and/or practices. At the very least, make sure you are compliant with the 9 requirements referenced in the page 3 sidebar (See Comments for more details)