We want to thank David for writing the article, “Smooth Start”, appearing in the latest issue of Health Facilities Management. Commissioning of the Emergency Power Supply System (EPSS) should indeed be a separate sub-task of the normal commissioning process and performed by those with several years OJT in healthcare plant operations. With over 500 full EPSS commissioning projects (both new and retrofit) under our belt we can attest to the accuracies of David’s statements.

Q. We are trying to come to grips with the requirement in NFPA 70E for an arc flash analysis every five years.  Does that mean we must do one immediately or do we have a specific time to get the first one done?  Is this being enforced by a regulatory agency (other than NFPA) such as OSHA?  Can someone refer me to the code?  We have a proposal from an electrical contractor but the cost seems very high.

Petitioners filed for review of two EPA rulemakings that revised the National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines (the RICE NESHAP). Under the terms of the proposed settlement agreement, by April 20, 2012, the Agency will sign a notice of proposed rulemaking that includes a proposal to revise the RICE NESHAP and the stationary internal combustion engine new source performance standards (ICE NSPS) to allow owners and operators of emergency stationary internal combustion engines to operate emergency stationary internal combustion engines in emergency conditions, as defined in those regulations, as part of an emergency demand response program for 60 hours per year or the minimum hours required by Independent System Operator tariff, whichever is less. The notice of proposed rulemaking may also allow for more hours of operation. In addition, under the terms of the proposed settlement agreement, by December 14, 2012, the Administrator of EPA will sign a final action on this proposal, which may include signature of a final rule by the Administrator.

EPA Proposed Settlement Agreement

Recently there has been a discussion regarding "single station" smoke detectors per the requirements of LS.02.01.34 EP-4 and the NFPA Life Safety Code.  LS.02.01.34 EP-4 is a catch-all phrase directing you to the Life Safety Code; i.e. “The organization meets all other Life Safety Code (LSC) fire alarm requirements related to NFPA 101-2000: 18/19.3.4 and is a C scored item.”  Looking at LSC reference 19.3.4 Detection, Alarm, and Communications Systems section 19.3.4.2 *Initiation section discusses initiation by manual or detection devices,  manual pull boxes in patient sleeping areas, and commercial cooking protection.  There is an appendix statement in 19.3.4.2 which states “It is not the intent of this Code to require single station smoke-detectors, which might be required by local codes, to be connected to initiate the building fire alarm system.”  This statement could then be translated to mean unsupervised sleeping areas require battery powered single station smoke-detectors.  Looking at section 19.3.4.3 Notification section talks about automatic notification and discusses audible and visual alarms in critical care areas, and visual alarms in patient sleeping areas approved by the AHJ.

Thanks to the efforts of several of our readers the negotiations with the EPA concerning increasing the 15 hours/year for emergency Demand Response (DR) are going very well.  In addition, the EPA issued an approval for reconsideration of the NRECA petition which is asking for Peak Shaving relief.  Soon there will be a Federal Register (FR) notice asking for comments.  At that time we will prepare a write-up explaining what to comment on, when to submit the comments, and where they need to be sent.  We can also provide some boilerplate language you can use in crafting letters to the EPA.  The FR notice should appear in a few weeks.

Note:  Caution should be exercised before committing EPSS assets to long term DR contracts.  Four of the ten major points to consider include: age of equipment, critical load isolation, system redundancy and local air permitting issues.

NRECA Approval Letter

Dan Chisholm, Sr.
Emergency Power Consultant
Healthcare/Mission Critical Systems
PO 2474
Winter Park, FL 32790
407.421.7189

Q.  The State is asking for the HP ratings of the generators existing on-site.  Our records have the kW rating, and I see some of the manufacturer’s literature gives a range of HP depending upon use level.  How do I answer the HP question without over stating the HP, and the emissions, from the generators?

Q: Does medical gas alarm signal wiring (i.e. wiring from sensors/transducers to master or area alarm warning panels) have to be installed in conduit?

We never run our generator each week.  However, we do a weekly inspection and visual check each day.  We also do a full load test once a month.  Is it common practice to run it each week?  If so, would running it without load for a minute or two be ok?

Caterpillar introduces the 3516C-HD — the first 2MW+ diesel generator set with Tier 4 Interim certification. Offering an integrated engine and after treatment solution, benefits include highly efficient fuel consumption rates, compact footprint and lower emissions for prime power, peak shaving, standby and mission critical applications. Cat® Tier 4 Interim generator sets are capable of integrating into larger power systems including UPS, Switchgear and ATS.

A new, or edited, paragraph will appear in the 2012 edition of NFPA 110.  ASTM D975 will become the de facto standard for diesel fuel testing.

Please send email to This e-mail address is being protected from spambots. You need JavaScript enabled to view it for a 6 page template RFP/RFQ to be used when soliciting pricing and laboratory qualifications for testing of fuel, oil and coolant.  It is very important that when creating the RFP/RFQ that the client specify (where applicable) the specific ASTM test method required for performing tests. For many of these tests there are faster, less accurate ways to test samples for specific properties. If the client does not specify the method, they run the risk of low-quality bidders coming in at very low prices and then providing essentially useless data because the methods utilized in testing are substandard. There are a some laboratories that are notorious for this and it is important to protect the hospital from getting trapped into a program that will cost them money without providing beneficial/actionable information.

Q. Is there a code requirement for medical gas alarm panel testing?  Monthly, quarterly, etc?

MGC, Inc. Announces Availability of Online ASSE 6040 Certification Course to Offer Greater Convenience and Flexibility in Attainment of Medical Gas Piping Certification and Overall Compliance

Web-based course allows qualified individuals to access medical gas training courses, compliant with ASSE 6000 series standard and NFPA 99, which are designed to train and certify individuals involved with repair, operation, maintenance, and periodic testing of medical gas and vacuum systems

MGC’s Web-based ASSE 6020 Certification Course Offers Self-paced Training Modules, More Convenience in Achieving Medical Gas Systems Certification, and Overall Compliance

Online certification course, offered by leading medical gas training innovators MGI Systems and Certified Medical Gas Systems, allows more flexibility in gaining ASSE 6000 series certification, NFPA 99 compliance, and more flexibility to individuals seeking certification in the inspection and testing of medical gas systems.

Q: Regarding corridor clutter, items cannot be present  “more than 30 minutes unattended” even though it is not supported specifically within the code references.  So, where did the 30 minute rule come from?  Secondly, if there is no applicable code reference to time constraints and it is clear that the item is “in use” or for use and not “storage”, is this a debatable compliance issue?

Q: Our facility has egress in an elevator bank.  Smoke doors close off this area and a door also accesses the basement.  So, egress becomes the stairs at the hallway prior to the smoke doors.  The estimated width is 24 feet by 20 feet.  Sometimes nurses put beds or wheelchairs in the elevator area.  Is this acceptable?

Q: What triggers an “Immediate Threat to Health or Safety” condition in the environment of care?

We are pleased to announce that Mr. Jonathan C. Willard, president and owner of Certified Medical Gas Services (CMGS), has been selected to present at the National Fire Protection Association 2011 Annual Conference & Expo.  The NFPA Conference is being held June 12-15, 2011 at the Boston Convention & Exhibition Center in Boston, MA.  His educational session is an overview of “Developing and Maintaining a Comprehensive Medical Gas System Operation and Management Program” for health care facilities.  He will be presenting the session on Monday, June 13 at 4:15 pm.

Birthing an Electrical Design in the Developing World

I have been designing electrical systems for hospitals in the United States for over forty years. During that time, I have designed a number of such systems in the developing world as a volunteer for EMI. So, one would think that by now I would have it all figured out. Nothing is further from the truth! Designing in the developing world requires much more skill, patience, ingenuity and diplomacy – and each project is very different.

On December 7 the U.S. EPA published a notice in the Federal Register requesting comments on the Notice of Reconsideration regarding the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Reciprocating Internal Combustion Engines in response to a petition filed in May 2010.  The EPA is accepting comments only on the 15 hour per year limit on the use of emergency engines in emergency demand response programs.  The  petition requested the EPA to change this limit to a maximum of 60 hours per year, or the minimum hours required by the Independent System Operator (ISO) tariff, whichever is less.  Comments are due on February 14, 2011.

By Jonathan C. Willard, CMGV, PMP

Developing a code-compliant operations and management (O&M) program for a medical gas system can be a difficult and time-consuming process. However, the following information provides a framework to make the job of creating such a program easier.

Click here to read more.

If you would like additional information on taking the ASSE 6000 Medical Gas Certifications Online please go to www.medgascerts.com.