Even in the worst of times, when everything in the world appears to be going wrong, healthcare facilities must get it right. Society has a life-or-death dependency upon hospitals being open and fully capable of treating any needs that arise. The COVID-19 pandemic is an excellent example of our reliance on the healthcare industry. As the virus spread worldwide, hospitals were pushed to their limits in patient capacity and in the demand on electrical systems that operated critical equipment providing ventilation and oxygen to patients who otherwise struggled to breathe.
A Science Direct research articletitled “From Blackouts to Breakthroughs: Examining Electricity’s Relevance in Healthcare during COVID-19 and the Future Role of Renewable Energy” states:
During the COVID-19 pandemic, the dependence on electrical consumption by hospitals and the healthcare sector became even more evident…especially noticeable in invasive and noninvasive ventilatory support in patients with COVID-19, significantly increasing the critical load on hospital electrical systems. Approximately 15 percent of patients diagnosed with COVID-19 require oxygen support, which requires electricity to operate.
While reliance on healthcare electrical systems reached a climax due to the immediate needs of the pandemic, it further established how crucial properly operating electrical systems and equipment are to society as a whole. Though the normal day-to-day operations at healthcare facilities may not see the number of patients they did during the pandemic, the lives they touch are just as valuable. This drives the need to take a proactive approach to proper maintenance to ensure healthcare electrical systems are functional, reliable, and safe when called upon.
NFPA 99: CURRENT USE AND EVOLVING MAINTENANCE REQUIREMENTS
NFPA 99, Health Care Facilities Code provides the code and requirements for what hospitals and other healthcare facilities must do. Many hospitals in the United States perform services that look to Medicare and Medicaid programs for compensation through the Centers for Medicare & Medicaid Services (CMS). Medicare is a federal program that typically provides health insurance to those age 65 and older; Medicaid is a joint federal and state program that provides healthcare coverage to those with limited income and resources. Although transitioning to the 2024 edition of NFPA 99 may not be on the horizon just yet, the reality is that CMS currently holds hospitals accountable to meet the requirements found in the 2012 edition of NFPA 99 as part of the Conditions of Participation (CoPs) agreement to receive payment for services rendered through the Medicare and Medicaid programs.
Chapter 6 of NFPA 99–2012, which specifies the requirements for electrical systems within hospitals, contains 23 references to items that must be maintained, including the essential electrical system (EES), alternate power sources, transfer switches, circuitry, and batteries. While many items are mentioned, the 2012 edition of NFPA 99 does not specify any overall programs encompassing maintenance as a whole.
PHOTO COURTESY OF COREY HANNAHS
Fast forward another three editions, and Section 6.9 was added to NFPA 99–2021 to address electrical preventative maintenance (EPM). In this more comprehensive preemptive approach, all components of an electrical system that serve a Category 1 and Category 2 space must be included within the EPM. From an NFPA 99 standpoint, Category 1 spaces are those where failures of systems or equipment could cause major injury or death to patients, staff, or visitors. For example, a loss of power or an equipment breakdown in an intensive care unit (ICU) could take the life of a patient. Category 2 spaces are those where system or equipment failures could cause a minor injury.
Don’t get lost in the acronym flip here, but the 2024 edition of NFPA 99 modifies Section 6.9 from requiring electrical preventative maintenance (EPM) to now requiring a full-on electrical maintenance program (EMP). Utilizing an EMP clearly helps establish a proactive program for ensuring electrical maintenance within healthcare facilities. While the elements and some other details are different, the EMP required by NFPA 99 also mirrors the requirement for an EMP that is found in and is the focus of NFPA 70B, Standard for Electrical Equipment Maintenance.
NFPA 70B: IMPLEMENTATION AND ENFORCEMENT
For almost 50 years, NFPA 70B was utilized as a recommended practice, meaning that the practices specified in the standard were recommendations — not requirements.
Implementation
NFPA 70B was first issued in May 1973 after five years of development. It was issued as a recommended practice known as NFPA 70B-T, Tentative Recommended Practice for Electrical Equipment Maintenance. While typically on a three-year cycle, NFPA 70B was delayed for four years between the 2019 edition and the most recent 2023 edition as it was converted from a recommended practice to an enforceable standard. NFPA 70B–2023 became an approved American National Standard on January 16, 2023, and was announced as being effective, superseding all previous editions, by the NFPA Standards Council.
PHOTO COURTESY NFPA
Enforcement
Now that NFPA 70B has become a standard, who will enforce it? It’s an interesting question. Many codes and standards are enforced legislatively by being incorporated by reference into local and state laws and statutes. NFPA 70®, National Electrical Code® (NEC®) is a great example as it is enforced on a governmental level within all 50 states, typically via state and municipal inspectors. When we look at NFPA 99, the 2012 edition is essentially enforced via the CMS requirement that mandates its use for healthcare facilities to collect Medicare and Medicaid funding. Rather than attempt to determine WHO will enforce NFPA 70B, a better approach may be to start by discussing who CAN enforce it.
Codes and standards are regularly enforced by an authority having jurisdiction (AHJ). This is usually a municipal or state inspector who has been charged with inspecting building installations to determine whether they meet the requirements of specific codes and standards that have been incorporated into local law. While this is the most common type of AHJ, it is important to note that inspectors are not the only people who can act in the role of the AHJ.
NFPA regulations define an AHJ as:
…an organization, office, or individual responsible for enforcing the requirements of a code or standard, or for approving equipment, materials, an installation, or a procedure.
This definition is important in determining who can enforce NFPA 70B because it clarifies that the AHJ does not have to be a person employed as an inspector. The AHJ can be someone at a company who has been charged with enforcing the standard because company management has deemed that using it is beneficial. For example, a company with an electrical safety program (ESP) that has been developed in accordance with NFPA 70E must also use NFPA 70B to establish a condition of maintenance, and someone like a safety director could act as the AHJ in its enforcement on behalf of the company. Additionally, if a healthcare system wanted to utilize NFPA 70B within all its facilities to keep its employees safer and systems more reliable, it could develop an EMP at each facility and appoint an AHJ at each location or it could name someone to oversee the implementation of NFPA 70B at all locations.
NFPA 70B: Electrical Maintenance Program (EMP)
NFPA Section 4.2.1 requires the equipment owner to implement and document an EMP that directs activity appropriate to safety as well as operational risks. The EMP is required to address the current condition of maintenance of equipment and the safety risks posed to those tasked with maintaining and/or operating the equipment. From a healthcare facility standpoint, the safety of the doctors and nurses who may be using specific medical equipment for procedures must be considered, and proper maintenance must be performed.
The EMP must define the principles it is based on and the goals that are desired to be achieved by utilizing it. In a tie back to NFPA 70E, the EMP must be designed to work in conjunction with an ESP. Because the NFPA 70E ESP also requires the condition of maintenance of equipment and systems to be considered, there is a direct connection to needing to use NFPA 70B and NFPA 70E concurrently. The EMP must identify what controls will be used to measure and monitor the program’s effectiveness. Constant feedback and refinement must take place by capturing information from electrical safety incidents, equipment malfunctions, unintended operations, alarms, and triggering of protective devices to determine where safety can be improved upon and risk can be mitigated. NFPA 70B also requires the EMP to be audited a minimum of every five years to ensure it remains in compliance with the requirements of the standards.
The heart of the EMP is supported by nine required elements that keep the program functional and in good health:
- An electrical safety program that addresses the condition of maintenance
- Identification of personnel responsible for implementing each element of the program
- Survey and analysis of electrical equipment and systems to determine maintenance requirements and priorities
- Developed and documented maintenance procedures for equipment
- A plan of inspections, servicing, and suitable tests
- A maintenance, equipment, and personnel documentation and records-retention policy
- A process to prescribe, implement, and document corrective measures based on collected data
- A process for incorporating design for maintainability in electrical installations
- A program review and revision process that considers failures and findings for continuous improvement
NFPA 70B requires an EMP coordinator to be selected and identified as the person responsible for coordinating the implementation and operation of the EMP. At NFPA, we have identified the need for an EMP coordinator to oversee the program and an AHJ responsible for ensuring that NFPA 70B requirements are met. While NFPA 70B does not say that the EMP coordinator cannot manage both roles, it may make more sense to have separate roles within the company as a means of checks and balances. Not doing so could blur the lines by essentially having the EMP coordinator oversee and monitor themselves as it pertains to properly implementing NFPA 70B requirements for the company.
CONCLUSION
Without question, healthcare facilities play a significant role in the survival or demise of the communities they are a part of. Ensuring that the electrical equipment within these facilities stays functional, reliable, and safe is in everyone’s best interest. Until a newer edition of NFPA 99 is required by CMS, there is no specific requirement for healthcare facilities to implement an EMP.
Understanding how NFPA 70B can benefit healthcare facilities in the present moment and beyond by keeping its electrical systems and equipment reliable and ready to use when called upon is doing right by society’s needs. When minutes can make the difference between life and death, being proactive about electrical equipment maintenance is a much better approach than having to react in the moment. Utilizing this approach will help healthcare facilities stay ahead of the emergency.
NFPA continues to provide important information to the public on how best to implement and utilize NFPA 70B, including this recent webinar from the author of this article, Corey Hannahs, and fellow NFPA senior electrical content specialist, Dean Austin.
Important Notice: Any opinion expressed in this column is the personal opinion of the author and does not necessarily represent the official position of NFPA or its Technical Committees. In addition, this piece is not intended, nor should it be relied upon, to provide professional consultation or services.
REFERENCES
Joaquín Lazo, Carolina Escobar, David Watts. “From Blackouts to Breakthroughs: Examining Electricity’s Relevance in Healthcare during COVID-19 and the Future Role of Renewable Energy,” Energy Research & Social Science, Volume 103, 2023, 103224. Accessed at https://www.sciencedirect.com/science/article/pii/S2214629623002840.
NFPA. NEC Enforcement. Accessed at https://www.nfpa.org/education-and-research/electrical/nec-enforcement-maps.
NFPA.Regulations Governing the Development of NFPA Standards. Accessed at https://www.nfpa.org/for-professionals/codes-and-standards/standards-development/regulations-and-policies.
Corey Hannahs is a Senior Electrical Content Specialist at the National Fire Protection Association (NFPA). In his current role, he serves as an electrical subject matter expert in the development of products and services that support NFPA documents and stakeholders. Hannahs is a third-generation electrician, holding licenses as a master electrician, contractor, inspector, and plan reviewer in the state of Michigan. Having previously held roles as an installer, owner, and executive, he has also provided electrical apprenticeship instruction for over 15 years. He was twice appointed to the State of Michigan’s Electrical Administrative Board by former Governor Rick Snyder and received United States Special Congressional Recognition for founding the BOP (Building Opportunities for People) Program, which teaches construction skills to homeless and underprivileged individuals.