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:
- Bad Air Day - testing emergency generators
- Hot water temperatures and log books
- In-House maintenance - working on Fire protection systems
Signatures needed on House letter urging President-elect
to
include hospital issues in economic recovery package
The first priority of the Obama administration when it takes office in two weeks is to enact an economic recovery package. Reps. Robert Brady (D-PA) and Joe Wilson (R-SC) are asking their House colleagues to sign a letter urging the President-elect to include relief for hospitals in the plan. Has your representative signed? The letter cites the "necessity of maintaining the economic health of our nation's hospitals" and notes that hospitals are among the nation's largest employers—five million jobs nationwide.
Download the pdf document for full information.Changes to NFPA 99
YOUR OPPORTUNITY TO COMMENT ON PROPOSED REVISIONS TO NFPA 99
Brief summary of main points of the revised standard
Chapter 8 Electrical Equipment
Proposed reduction in frequency and specific testing intervals of leakage current testing for medical equipment and appliances.
Chapter 4 Electrical Distribution
Complete re-write of chapter and Annex A & C
Chapter — New
Consolidates common elements from
- Chapter 10 — Laboratories
- Chapter 6 — Environmental Safety
- Chapter 5 — Piped Gas
- Chapter 9 — Gas Equipment
Chapter — New — Technology
Space, environmental, reliability of technology and communication systems.
Includes data, voice, patient monitoring, nurse call, IT, digital imaging, security, building automation, life safety, and teleconferencing.
Chapter 5 Medical Gas and Vacuum
Vacuum pumps compatible with O2 if used for WAGD.
Instrument air section deleted.
Go to ASHE NFPA 99 Proposals to review all changes and make any comments.
Refrigeration Plant Manning Alert
The following links are for Word documents relating to Refrigeration Plant Manning Alert:
More on Emergency Generators
Click here for more info on emergency generators.
DEP ANNOUNCES EXEMPTION FOR HOSPITALS
TO NEW TESTING PROHIBITION RULE
In a letter to HFMSNJ President John Di Girolomo, NJDEP Director, Division of Air Quality, William O'Sullivan clarified the Department's position on testing emergency generators. In response to the HFMSNJ advocacy effort and recent letter to the Department seeking clarification, O'Sullivan responded:
"The Department agrees that the operational testing required by the Department of Health and Senior Services (DHSS) and the testing required for accreditation by the Joint Commission, meet the exemption to the bad air day test prohibition in N.J.A.C. 7:27-19.2(d)."
O'Sullivan also encouraged hospitals to continue to check the air quality forecasts prior to testing and where possible avoid testing during periods of "unhealthy" air quality. This will help improve air quality at hospitals and their neighbors.
Hospital engineers had been concerned that DEP enforcement would not recognize the Joint Commission testing requirements as mandated by a Federal authority and thereby eligible for the exemption. This letter specifies the Joint Commission as a Federal AHJ.
Read the complete letter from Mr. O'Sullivan.
ADVOCACY SUCCESS IN FIRE ALARM TESTING
Advocacy efforts by the Healthcare Facility Management Society of New Jersey (HFMSNJ) have resulted in a significant improvement in fire safety in New Jersey hospitals.
For many years, the New Jersey Department of Health and Senior Services (DOHSS) enforced regulations on the frequency of testing fire alarm systems at ambulatory care and acute care facilities. The frequency of testing was greater than recommended by NFPA 72, Fire Alarm Code. To comply with the DOHSS regulations, parts of the system would be taken out of service for testing up to four times a year.
Believing modern fire alarm systems are so reliable that testing at the frequency recommended by NFPA 72 is protective of patients, HFMSNJ communicated our concerns and recommendations to the Commissioner of DOHSS. In two letters from the HFMSNJ President, we outlined our advocacy for patient safety, understanding of alarm technology, and recommendations for regulatory change.
The Commissioner has just advised us that DOHSS regulations will be amended in 2008 in accordance with our recommendations. The NFPA 72 recommendations on testing frequency will be incorporated into the regulations. Prior to adoption of the new regulations, individual healthcare facilities may request a waiver and, if granted, may test at NFPA 72 recommendations starting immediately.
Download a dhss waiver application form to request change in fire alarm testing frequency:
Click here for DoHSS form CN-28 as MS Word document
Click here for DoHSS form CN-28 as PDF document