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Survey Hot Topics
amp
Preparing for the 2012 Life Safety Codereg
November 2015
RPA Effectiveness
Agenda
Most Common NYSDOH K-tags
Status of the 2012 Life Safety Code
Key 2012 Provisions
Categorical Waivers
Power Strips
QampA
K56 amp K62 Sprinkler Systems
K29 Hazardous Areas
K50 Emergency Plans
K38 Exit Access
K25 Smoke Barriers
K20 Stairwells amp Shaft Enclosures
K18 Corridor Doors
K147 Electrical Issues
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
RPA Effectiveness
Agenda
Most Common NYSDOH K-tags
Status of the 2012 Life Safety Code
Key 2012 Provisions
Categorical Waivers
Power Strips
QampA
K56 amp K62 Sprinkler Systems
K29 Hazardous Areas
K50 Emergency Plans
K38 Exit Access
K25 Smoke Barriers
K20 Stairwells amp Shaft Enclosures
K18 Corridor Doors
K147 Electrical Issues
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Agenda
Most Common NYSDOH K-tags
Status of the 2012 Life Safety Code
Key 2012 Provisions
Categorical Waivers
Power Strips
QampA
K56 amp K62 Sprinkler Systems
K29 Hazardous Areas
K50 Emergency Plans
K38 Exit Access
K25 Smoke Barriers
K20 Stairwells amp Shaft Enclosures
K18 Corridor Doors
K147 Electrical Issues
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
K56 amp K62 Sprinkler Systems
K29 Hazardous Areas
K50 Emergency Plans
K38 Exit Access
K25 Smoke Barriers
K20 Stairwells amp Shaft Enclosures
K18 Corridor Doors
K147 Electrical Issues
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
K29 Hazardous Areas
K50 Emergency Plans
K38 Exit Access
K25 Smoke Barriers
K20 Stairwells amp Shaft Enclosures
K18 Corridor Doors
K147 Electrical Issues
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
K50 Emergency Plans
K38 Exit Access
K25 Smoke Barriers
K20 Stairwells amp Shaft Enclosures
K18 Corridor Doors
K147 Electrical Issues
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
K38 Exit Access
K25 Smoke Barriers
K20 Stairwells amp Shaft Enclosures
K18 Corridor Doors
K147 Electrical Issues
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
K25 Smoke Barriers
K20 Stairwells amp Shaft Enclosures
K18 Corridor Doors
K147 Electrical Issues
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
K20 Stairwells amp Shaft Enclosures
K18 Corridor Doors
K147 Electrical Issues
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
K18 Corridor Doors
K147 Electrical Issues
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
K147 Electrical Issues
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
K144 Generator Testing amp Inspection
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
K69 Commercial Cooking Equipment
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
K12 Construction Type
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Fire Safety Evaluation System (FSES)
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
The 2012 Life Safety Codereg
Change Can Be Good
Improved
readability
Incorporates 12
years (4 editions)
worth of changes
Primarily beneficial
changes to Health
Care Occupancies
Reflects benefits of
automatic sprinkler
protection
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
2012 LSC Code Adoption
April 2014 proposed rule in the Federal Register
Adopt 2012 editions of 101 and 99
Proposing various alterations exceptions
Comment period until June 16 2014
Much reviewhellipNFPA ASHE AHCA
Expect adoption sometime in 2015
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Waivers
392012 CMS released Survey amp Certification
(SampC) letter 12-21-LSC allowing health care facilities
to use the ldquocultural changerdquo provisions contained
within the 2012 LSC
Wheeled equipment in corridors
Fixed furniture in corridors
Combustible decorations
Fireplaces
Cooking facilities
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Challenges to the Waiver Approach
Health care facilities must first be cited for
noncompliant conditions and then request a
waiver to use 2012 LSC provisions
Waiver approval process can take time
Negative connotation associated with citations
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
On 83013 CMS permits facilities to apply various
provisions of the 2012 LSC
Provisions are generally less restrictive than the
provisions of the 2000 Edition
Includes the ldquocultural changerdquo provisions
Facilities do not have to be cited to apply these
waivers
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
Facilities must COMPLY
Assess compliance with applicable 2012 LSC
sections ndash not as easy as you may think
Waiver compliance is not ldquoautomaticrdquo ndash MUST
MEET ALL 2012 LSC REQUIREMENTS
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
Facilities must DOCUMENT
As directed by CMS NYSDOH or other AHJs
RPA has developed a Categorical Waiver Declaration Form ndash
this approach meets CMS requirements and is accepted by
the other agencies with deemed status
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waiver Declaration Form
httpwwwphillipsllccomresourcesresource-library
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
Facilities must PRESENT
As directed by CMS NYSDOH or other AHJs
It is critical that facilities inform AHJs of the use of
Categorical Waivers at the onset of their
inspection
It is not acceptable to be cited and then elect to use a
categorical waiver
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
1 Openings in Exit Enclosures
2 Door Locking for Patient Special Needs
3 Doors with Delayed Egress
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
4 Suite-to-Suite Exiting
5 Suite Exiting Utilizing Stairs Passageway or Exterior
6 Suite Size
7 Clean Waste and Patient Record Recycling
Containers
Containers are labeled
amp listed as meeting FM
Approval Standard 6921
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
8 Corridor Projections for Wheeled Equipment
bull Equip does not reduce corridor width to less than
60 inbull Fire Safety Plan addresses relocation of wheeled
equip
bull Wheeled equip is limited to
i Equip amp carts in use
ii Medical emergency equip not in use
iii Patient lift amp transport equip
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
9 Corridor Projections for Fixed Furniture
bull 8 foot corridor
bull Furniture is securely attached to the floor or wallbull Furniture does not reduce corridor width below 6rsquo
bull Furniture located on one side of corridor
bull Furniture groupings do not exceed 50 ft2
bull Furniture groupings separated by at least 10rsquo
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
10 Alternative Type Kitchen Cooking Arrangements
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
11 Direct-Vent Gas Fireplaces
12 Solid Fuel-Burning Fireplaces
13 Combustible Decorations
(a) Decorations do not exceed 20 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is not fully sprinklered
(b) Decorations do not exceed 30 of wall ceiling amp door areas inside any
room or space of a smoke compartment that is fully sprinklered
(c) Decorations do not exceed 50 of wall ceiling amp door areas inside
patient sleeping rooms having a capacity not exceeding 4 persons in a
smoke compartment that is fully sprinklered
Individual walls and ceilingshellipnot aggregate The door is part of the wall
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
14 Medical Gas Master Alarms
15 Emergency Generators and Standby Power Systems
16 Testing of Vane-Type and Pressure Switch-Type
Water Flow Alarms
17 Testing of Electric Fire Pumps
18 Relative Humidity Levels in Anesthetizing Locations
19 Fire Smoke Damper Testingnote this waiver option is applicable to hospitals only
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
20 Power strips
Power Strip Use in Patient Care Areas The facility is electing to apply the
categorical wavier permitting the application of the power strip provisions
in the 2012 edition of NFPA 99 This also exempts resident rooms in long-
term care facilities from the NFPA 99 power strip provisions when the
facility does not utilize line-operated electrical appliances in resident
rooms for diagnostic therapeutic or monitoring purposes
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Power Strips
Underwriters Laboratories (UL) Listing
StandardPhrase Term
UL 1363 Relocatable Power Tap (RPT)
UL 1363ASpecial Purpose Relocatable Power Taps
(SPRPT)
UL 60601-1 Medical Electrical Equipment
UL 1449Surge Protective Device (SPD)
Transient Voltage Surge Suppressor (TVSS)
UL 1778 Uninterruptible Power Supply (UPS)
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
Categorical Waivers
Facilities must COMPLY
Make sure you meet the 2012 LSC requirements
Facilities must DOCUMENT
Use the Categorical Waiver Declaration
Facilities must PRESENT
Inform the AHJ during survey opening meeting
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
David Hooddhoodphillipsllccom
Scott Aronsonsaronsonphillipsllccom
Dave Hood President
dhoodphillipsllccom
![Life Safety Code Compliance.15 (2) [Read-Only] Safety Code Compliance... · The 2012 Life Safety Code ... & listed as meeting FM Approval Standard 6921. 5/5/2015 14 Categorical Waivers](https://img.dokumen.tips/doc/110x75/5c74c4c809d3f287228c19f5/life-safety-code-compliance15-2-read-only-safety-code-compliance-the.jpg)
