Generators: Electric Power and Ashe Members

[pic] Regulatory Advisory A service to members, advisories are produced whenever there is a significant development that affects the job you do in your community. A Message to ASHE Members: The Joint Commission (JCAHO) is conducting a Field Review of its proposed addition to standard EC. 7. 40 on the inspection, testing and maintenance of emergency power systems. JCAHO proposes to add a new Element of Performance (EP) requiring annual testing of each emergency generator for four continuous hours, under load.ASHE members are encouraged to take full advantage of this opportunity to: †¢ Provide your input on the actual need for this new requirement, †¢ Comment if this requirement will assure greater reliability, †¢ Inform JCAHO of the specific impact to your facility from implementing this requirement as it is proposed. The Field Review will close on February 20, 2006 Standard EC. 7. 40 – Proposed Element of Performance #5The [organization] tests each emergency gen erator at least once every 12 months for a minimum of four continuous hours. This test shall be conducted under a load (dynamic or static) that is at least 30% of the nameplate rating of the generator. The Field Review is being conducted on the JCAHO website at: www. jcaho. org/accredited+organizations/hospitals/standards/field+reviews/ec740_std_fr. htm The notice contains background information that identifies emergency electrical generators as a critical resource for delivery of safe care.The background information further explains that â€Å"Testing generators for sufficient lengths of time increases the likelihood of detecting generator reliability problems and reduces the risk of losing this critical resource when it (is) most needed†. A key question ASHE members should comment on is: As it is written – will the proposed requirement lead to more effective detection of generator reliability problems and in doing so reduce the risk of failure under emergency conditi ons? † The Field Review is organized to challenge both the premise for and the wording of the proposed standard.The survey questions and ASHE’s guidance on responding to these questions are on pages 2 and 3 of this alert. All answers should be for your specific facility based on your experience. In addition to providing input on whether this standard will meet its intent, you should focus on possible obstacles to complying with this requirement including resources (fuel and labor costs), disruption to services and patient care during the test, and air emission regulatory compliance issues. ASHE urges you to seize this opportunity to comment!Your input is essential to ensure this proposed revision is well thought out and will actually improve system reliability. JCAHO Field Review – Proposed Emergency Power Testing Standards The Field Review is an on-line survey launched from the Field Review web page at: www. jcaho. org/accredited+organizations/hospitals/standard s/field+reviews/ec740_std_fr. htm The actual survey is conducted through surveymonkey. com with results compiled for JCAHO. Below are the survey questions with guidance on how to respond to each question 1.Name – this is listed as optional but we suggest you provide your name 2. Organization – again this is optional but we suggest you provide this 3. In which one of the following categories are you primarily responding? – there is a list provided to chose from – in most cases you will select the first choice as being a ‘Joint Commission Accredited Organization’. 4. If you are primarily representing a Joint Commission accredited organization, which one category best describes your role in that organization? similar to the previous question this is a list – most ASHE members will choose ‘Facility Maintenance’, Facility Design’, or ‘Safety Management/Security Management’. 5. For which accredited program ar e you responding to this field review? – a list is provided of each of the JCAHO programs for which this proposed standard will apply. Please select your primary facility (e. g. Hospital). If you have multiple care settings, please consider filling out a survey for each different type of care setting. 6. Does your organization rely on an emergency generator to provide care, treatment, and services during electrical power outages? Yes/No 7. Would your organization rely on an emergency generator to continue care, treatment, or services for four hours or more during extended electrical power outages? – typically this is Yes unless your program allows for the discontinuation of services and facility evacuation 8. Are the proposed revisions illustrated in â€Å"Element of Performance #5†, understandable or clear to your organization? – this is where the â€Å"rubber hits the road†. Comment on the proposed standard as it is written – don’t read into it what you think it is trying to say.If it is not clear please take the time to comment on what is unclear and/or if there is a better way to clearly state what they want you to do. 9. Regarding â€Å"Element of Performance #5†, is the required frequency for testing emergency generators appropriate? – the real question is – should this be an annual test? The 2005 edition of NFPA 110 – Standard for Emergency and Standby Power Systems – requires Level 1 EPSS (Emergency Power Supply Systems) to be tested for at least 4 hours, at least once within every 36 months.ASHE members are represented on the technical committee of NFPA 110 along with manufacturers and designers. This technical committee has voted that a 4 hour test, every three years provides adequate assurance of reliable performance. If you agree with NFPA 110 you should select No. 10. If you indicated no, what would be the appropriate frequency of testing? – NFPA 110 require s 36 months (NFPA 110 – 2005, section 8. 4. 9) 11. Do you feel that a load of 30% of the nameplate rating of the generator required in â€Å"Element of Performance #5† would adequately assess the generator’s fueling and cooling systems during the test? NFPA 110 requires the test load to be the EPSS load running at the time of the test. This is to test the ability of the EPSS to deliver the required power to the outlets, lighting, and systems that are on the emergency power system rather then to simulate it with a load. As written, EP 5 could be met through use of a resistive load bank without testing other vital components of the EPSS including transfer switches and paralleling switchgear. This is a fundamental question – will â€Å"cooking† the engine for 4 hours adequately test he fuel and cooling systems and therefore enhance system reliability? Or is should the entire EPSS be tested? If you feel that the entire system should be tested as requir ed by NFPA 110 – 2005, section 8. 4. 9. 1, answer question 11 as No and list your reasons in the provided space for comment. 12. Would the proposed revisions in â€Å"Element of Performance #5† be burdensome for your organization? – ASHE recommends that you discuss this issue with your administration and safety committee to fully identify all the implications of performing this test annually.Issues to discuss include additional resources (fuel consumption and labor to conduct the test), increased amounts of air emissions from the test (state or regional clean air regulations), and disruption to services during the test such as computer based systems on emergency power, lighting, transportation systems, and ventilation systems. Organizations that have experienced any difficulty in scheduling and performing the currently required monthly tests must ensure that all stakeholders are fully informed and supportive of the scheduling and performance of this proposed 4 h our test. 3. If â€Å"Element of Performance #5† became effective immediately, how long would it take for your organization to be in compliance? – this question only allows one of four responses, with a maximum of 12 months. Your response should be informed by the discussion from question 12. If you feel that none of the listed time frames are adequate, utilize the â€Å"additional comments† area at the end of the survey to discuss the compliance timeframe 14. Would your organization utilize outside sources to perform this test required by â€Å"Element of Performance #5†? For example, would your organization need to utilize a load bank to meet the 30% test load requirement? ) – Consider if you have the available staff, the available expertise on staff, and/or the available current load to perform this test without taking on additional outside expenses. If you anticipate additional expenses, provide a ‘best-guess’ of that cost. For que stions or comments contact Dale Woodin at [email  protected] org or 312-422-3812 https://www. premierinc. com/safety/safety-share/05-06-downloads/11-ashe-fda-bed-rail-entrapment-05-06. pdf