Sunday, March 29, 2009

Compliance News: Unusual Observations

By Robert Trotter, CBO, CFM

Whether you complete your own life safety assessment for compliance with the Life Safety Code® or the work is performed by a third party, frequently an issue is discovered that is not described in the Statement of Conditions™. For the past several years we have been noting these issues as Unusual Observations. Starting in January 2009, as a result of The Joint Commission Standards Improvement Initiative, the new Life Safety Chapter incorporates an Element of Performance at the end of each individual standard to note other deficiencies. For example, under the Hospital Accreditation Program Standard LS.02.01.20 EP (32) states, “The hospital meets all other Life Safety Code means of egress requirements related to NFPA 101- 000: 18/19.2.” This Element of Performance gives you the latitude to create a Work Order or a Plan for Improvement (PFI) for any deficiency discovered that can not be associated with one of the Standard’s preceding Elements of Performance.

Regarding the example photograph, the Hospital Standard does offer Element of Performance (13) relative to the exit discharge and obstructions or impediments to the public way that may be acceptable for the landscape in the means egress. However, the full text and exceptions sends you NFPA 101-2000: 7.1.10.1 for means of egress reliability. Another key observation that may not be discernible in the photograph is the change in elevation in excess of 21 inches without a ramp or stair as required by NFPA 101-2000: 7.1.7.2. This would be an excellent example of when to cite noncompliance at LS.02.01.20 EP (32).

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