Healthcare Facilities Management Society of New Jersey

Advocacy

The Advocacy committee solicits members input on issues for advocacy action. If you are aware of local, State, Federal or any authority having jurisdiction regulation, or proposal that in you view would impose unwarranted interference in facility management, unreasonable costs, or duplicate existing rules, please contact the Advocacy Committee with the particulars.

Items are listed in reverse chronological order based on when received and/or the deadline date for responses.

Below are links to responses and comments from previous advocacy efforts:


QI ASHE Advocacy Liaison Webinar

Click here to download the document.


Proposed Assembly 4139 drinking water

Click here to download the document.


Q3 ASHE Advocacy Webinar

Click here to download the document.


CMS adapts the 2012 edition of the Life Safety Code

Click here to download the document.


Joint Interim Guidance
HVAC in the Operating Room and Sterile Processing Department

Click here to download the document.


ASHE recommends you Register all WMTS Devices


Comment period for NFPA 99 and 101 (LSC) 2012 ending June 16th

CMS is proposing to adopt both NFPA 99 and 101(LSC) 2012 editions but they are not going to adopt all of NFPA 99 and have taken important exceptions to 101.

The proposed rulemaking is in the comment period that ends June 16, 2014.

Please look at the two above referenced documents provided by ASHE. Go towards the back of each document and look at the questions as they will help guide you in determining how you might be impacted by these proposals.

Again, make your “C” suite aware of this proposal.

Please submit comment by June 16.

If you have ideas for a comment and cannot do it yourself, contact me.

I’ll submit for you.

Don’t wait.

Advocacy action needed by FEBRUARY 25th

From Our Advocacy Chairman, Robert, N. Roop. P.E., CBIE

What you need to do is send a response to the address below even if you only limit to one provision of the rule.

Please Respond No later than 5 p.m. on February 25, 2014

Last week I attended an ASHE Advocacy conference call on the proposal from CMS on emergency management.

We first heard about it from our friend Dan Chisholm and the provisions requiring 4 hour generator testing every 12 months.

ASHE explored the proposal in much more detail and discovered many objectionable provisions.

It adds another layer of regulation on top of what you already do under NFPA and JC. As you know ASHE has been on a campaign to coordinate regulations and codes, eliminate duplication and inconsistencies.

This needs as many responses as possible.

Attached are documents for your possible review:

Look at the CMS Proposed EM rule to get talking points. Customize as many as you can to your facility and send comment to CMS.

The response should not just be a cut and paste or it will be regarded as a junk mail letter campaign.

ASHE says financial impact will be considered as a comment but it must be supported with more than just “it costs too much”.

If you can, copy me and I will draft a Chapter response. You may submit electronic comments on this regulation to http://www.regulations.gov. Follow the “Submit a comment” instructions. In commenting, please refer to file code CMS-3178-P. More ways to submit are listed in the documents attached.


Refrigeration Plant Manning Alert

The following links are for Word documents relating to Refrigeration Plant Manning Alert:

Lead Regulations

Update on EPA’s Lead Renovation, Repair, and Painting Rule - Deadlines Approach for Hospitals!

More on Emergency Generators

Click here for more info on emergency generators.