Fire Safety Advocacy & Information

 

Update:

 

November 2007 – To all:

  1. Please keep in mind that all of this needs to go through the Legislative process and that this reflects proposed language.  I think it will be approved as stated.  However, the Nursing Home Sprinklering issue is one that will be driven by CMS as it is related to the time line.  I feel the Committee wanted to leave the door open to the Nursing Home Industry with respect to their ability to finance the retrofitting.

 

  1. I think everyone will just be glad to have consistency between agencies as it relates to Alcohol Based Hand Rub.

 

  1. I have also attached the latest and most up to date Michigan Amendments reflecting review to date.

 

  1. Below are segments of E-Mail from Mike Pachulski to the committee with respect to the two above items FYI only.

 

“Greetings fellow (fire safety board) members,

 

I have several items to report.  First, the vote requiring existing nursing homes to be fully sprinklered within 10 years (19.3.5.1) passed unanimously.

 

The second issue deals with alcohol based hand rub (ABHR) dispensers and the conflict with the proposed Michigan amendment.  I contacted Stephen Pelinski, who is the Safety Engineer for CMS Chicago and is the contact person for Michigan.  I was advised that CMS no longer has a distance requirement for ABHR from a source of ignition.  The distance issue has been addressed by the NFPA Technical Committee.  The committee advised “without substantiation, the current text which prohibits placement directly adjacent to an ignition source better serves the Code user.”   Pelinski advises that CMS will determine if an ABHR is too close to an ignition source if “1) The ABHR is above an ignition source, it is deficient and 2) if it is to the side of an ignition source a measured distance shall not be used to determine if it is too close.  We look for evidence of splash from the ABHR on the ignition source to determine if it is too close to the side.”

 

Based on this new information, the BFS policy has been revised.  The new policy (attached) is consistent with the interpretation of NFPA and CMS.  As BFS is no longer more restrictive than the 2006 LSC, the draft amendment has been changed and the ABHR language has been deleted.  I believe that this will address all of the concerns that we discussed at our last meeting.  Note that JCAHO still has a more stringent application in hospitals.  That is a JCAHO enforcement issue that does not reflect on our rules. 

 

The draft minutes from the 10/17/07 meeting are attached.  As the11/13/07 meeting has been cancelled, please review the draft and advise if any changes need to be made to them.

 

Work continues on the Regulatory Impact Statement. 

 

As always, if you have questions or concerns, feel free to contact me.

 

Mike

 

Bureau of Fire Services-Fire Marshal Division

Michael Pachulski, State Fire Marshal Supervisor”

 

September 2007 - A document that reflects NFPA rules from 1997 through 2006 and compares these to Michigan Amendments for 2008 is in DRAFT form and available for MiSHE Member review.  In order to assist

in the review process, wording is highlighted as follows: all changes and new items are in Red; yellow highlighted areas reflect potential issues for existing facilities; and blue highlighted areas are commentary. To review the document click on Michigan Amendments for 2008 and return any comments to Tim Tinney. It is important that all comments, questions, issues or proposed language changes from MiSHE members be taken back to the ad hoc committee. The next meeting is scheduled for October 17, 2007.

 

Meeting Schedule: October 17, November 13, and December 11, 2007

 

August 2007 – MISC information: Nursing Home, 100% sprinkler requirement will not go away.  A decision on an acceptable time frame i.e. 5/7/10 years to comply will be made.

429 - Nursing Homes in the State of Michigan

222 - Fully Sprinkled

206 - Partially Sprinkled (Hazardous areas by code)

1 - Un-sprinkled

 

 

Background

As an organization, MiSHE is involved with being an advocate for those issues that involve our members. One of these areas is Fire Safety. One of our members, Tim Tinney, is on the Michigan Fire Safety Board. The following information and updates are provided to involve of all of our members in this important area.

 

Letter from the Healthcare Representative to the Michigan Fire Safety Board

 

 

To All Members and those Attending the Member Seminar on April 13, 2007,

 

I am fearful that my request for MISHE members interested in participating created an expectation that several members of our society would be appointed.  In the end that clearly is not he case.  I apologize for creating any such expectation, but was encouraged to do so by the Chair of the Fire Safety Board.  It may be best to chalk this up to State politics.  On this page is a list of members on the Healthcare Ad Hoc Committee. I believe it to be a good cross section.  I am also pleased that Mike Pachulski from the Bureau of Fire Services is the Chair of the committed.  Mike was a State Trooper and I have worked with Mike on another project and find him to be practical and strait forward.  It is also in our interest to have Dave Guillaume on this committee, his record speaks for itself.  The committee will be reviewing the following documents linked on this page: Chapter 12 New Health Care Occupancies; Chapter 13 Existing Health Care Occupancies; and DCIS – 2001 Michigan Amendments from the Department of Consumer and Industry, State Fire Board, Health Care Facilities Fire Safety Division …

 

READ MORE

 

 

Information and Update Links

 

Current Issues and Action Required by MiSHE Members

Issue 1 – Facility owners, managers and operators understand and support the need for they’re to be codes and standards.   We know that NFPA does not address all aspects of healthcare building design, construction and related systems, but NFPA is focused on life preservation.  Other codes regulate and govern the balance of the structure.  Often times these codes overlap and create conflict and ambiguities that make it difficult or impossible to meet regulatory compliance.  In some cases this overlap causes undue financial burden on the healthcare industry and delays service to our customers.  These conflicts and ambiguities lead to designing and specification of excessive or blanket incorporation or inclusion of devices and or equipment that requires ongoing service, and mandated third party testing and certification.  Examples, being smoke damper and detection; and fire dampers.  NFPA 2000 does not require dampers within a 100% sprinklered facility, however the local Authority having jurisdiction may have a mechanical code that requires them to enforce damper compliance. 

  • Action Needed: We urgently need to know the specific code conflicts that you have with NFPA and other codes. This includes specific codes; the name and number of the code; and the NFPA conflict by name and number. You can send this information to Tim Tinney by email and email attachment.