Hospitals prohibited to use power strips with medical devices

[Methoselah]

Hospitals are shocked to learn that they can no longer plug their medical devices into power strips and surge suppressors. Joint Commission earlier this month (June 2014) announced they have been advised by the Centers for Medicare & Medicaid Services (CMS) of this prohibition, which is consistent with how CMS always surveyed Long Term Care (LTC) facilities for compliance with NFPA 101-2000 (see page 15, Publication 100 07, Transmittal 27 dated August 17, 2007). CMS cites LTC facilities and hospitals of these violations under K-Tag K0147. Both LTC facilities and Hospitals fall under the same occupancy chapters in the Life Safety Code – “New/Existing Health Care Occupancies.” Therefore, it is not surprising that CMS’s position on such matters would be the same for both. So beware when a vendor tries to sell you a "hospital grade" or "medical grade" power strip.

Hospitals usually use them in operating rooms as a centralized source of power for surgical equipment in order to avoid tripping hazards, and they mount them on IV poles for infusion pumps.

CMS requires hospitals to comply with NFPA 101, “The Life Safety Code” (2000 Edition), as a condition of participation (CoP) in their Medicare and Medicaid programs.

- Title 42 CFR § 482.41(b)(i) = Condition of participation: Physical Environment​

NFPA 101-2000, Section § 2.1, incorporates the following publications, among others, as part of the Life Safety Code:

- NFPA 70-1999 Edition = National Electrical Code
- NFPA 99-1999 Edition = Standard for Healthcare Facilities​

Relocatable Power Tap (RPT), is a classification used by Underwriters Laboratory (UL) to include power strips, surge suppressors, and similar types of multi-outlet devices. UL is one of several nationally recognized testing laboratories (NRTL). RPT’s can be UL “listed” as standalone power taps or a UL “recognized” power tap to be part of a listed assembly:

UL 1363 Listed = Power Strip
UL 1449 Listed = Transient Voltages Surge Suppressor (TVSS) or Surge Protective Device (SPD)
UL 1363A Recognized = Special Purpose Relocatable Power Tap (SPRPT)
UL 1778 Listed = Uninterruptible Power Supply Equipment (“SPD that has a battery backup feature”)
UL 60601-1 Listed = Medical grade power strip​

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1. Stand-alone Relocatable Power Taps (RPT) are prohibited with medical devices in hospitals, because:

A. "Relocatable power taps have not been investigated for use with medical equipment in general or critical patient care areas of health care facilities. These areas are defined in Article 517 of the National Electrical Code ® (NEC)."

1) The Code Authority newsletter. (2008) = Underwriters Laboratory: Using Relocatable Power Taps in Health Care Facilities​

B. You would be using a flexible cord “… as a substitute for the fixed wiring of a structure.”

1) NFPA 70-1999 § 400-8(1) = National Electrical Code
2) Title 29 CFR 1910.305(g)(1)(iv)(A) = OSHA​

C. “There shall be sufficient receptacles located so as to avoid the need for extension cords or multiple outlet adapters.”

1) NFPA 99-1999 § 3-3.2.1.2(d)2 = Standard for Healthcare Facilities​

2. Special Purpose Relocatable Power Taps (SPRPT). These power taps are not designed to be stand-alone power strips for medical devices. They are designed to “… supply power to plug-connected components of movable equipment assemblies.” It needs to be pieced togther with other components as an integral part of a cart assembly by the manufacturer and tested by UL before being placed on the market as a “Listed Assembly.” UL further states, "SPRPTs have not been investigated for stand-alone use in patient care vicinities." Thus, you can't use them by themselves outside of a listed assembly.

A. UL 1363A § 1.2 (2010, 3rd Ed.) = Underwriters Laboratory: Special Purpose Relocatable Power Tap
B. The Code Authority newsletter. (2008) = Underwriters Laboratory: Using Relocatable Power Taps in Health Care Facilities​

3. Operating Rooms. Both stand-alone Relocatable Power Taps (RPT) and extension cords are prohibited for use with medical equipment in an anesthetizing location such as an operating room, because:

A. “Flexible cord for portable lamps or portable electric appliances operating at more than 12 V between conductors, intended for use in anesthetizing locations, shall be continuous and without switches from the appliance to the attachment plug… “

1) NFPA 99-1999 § 7-5.1.2.5 = Standard for Healthcare Facilities​

4. Computers. Computers and peripherals can be plugged into a surge suppressor/protector because you would be using it as a “device” consistent with its UL listing (UL 1449) of surge protection for nominal voltage equipment, and not as a substitute for fixed “wiring.” In other words, you’re using this specific type of RPT for its protective properties, as opposed to using it simply for the sake of having more power outlets!

5. Temporary. All relocatable power taps are considered temporary. With exception of SPRPT's (UL 1363A), a person should be able to remove them without a use of a tool. You can't affix them to a desk, wall, cart, podium, etc. with screws, zip ties, or industrial glues. Hook and loop fasteners (VELCRO®) are OK.

 

[DanEE]

This area seems to be a problem in general where code accepted solutions and equipment are not available to meet real world demands in today's complex computer, network and instrumentation areas that undergo constant configuration change as a part of their operation.

Even in my rather complex at home main work area with multiple computers, video security, audio/video equipment, it takes five power strips to run everything.. Some portions powered 24x7, some with power controlled by remotely via security system operation and some on local control as needed by use, and some devices on a central commercial UPS and other items on house power.

I can't conceive of an in wall, permanent solution to this as moves and changes occurs, same problem in commercial IT server sites. Power strips are needed to handle the numerous, but small current demand devices that are in almost constant state of configuration change.

I have regularly seen the same problem in IT server farms and PBX installations, some in Joint Commission certified hospitals.