Attachment 35 - 2526-00_23_0227 - 03. DVA - ILSM Post 4-6-2018.pdf

Department of Veterans Affairs VA Connecticut Healthcare System

Healthcare System Policy No. SO-006 April 6, 2018

________________________Interim Life Safety Measures (ILSM)_______________________

I. POLICY:

A. VA Connecticut Healthcare System (VACHS) shall establish procedures, roles and responsibilities for determining when life safety features are compromised due to construction or alteration to buildings, operations or maintenance activities that render any component of the life safety protection system compromised or for the failure of any part of the system. It is the intent of the VA Connecticut Healthcare System to assure the safety of all building occupants during periods of construction or when deficiencies compromise the level of life safety protection provided.

B. This policy is to establish minimum requirements the VACHS is to provide for the healthcare system’s implementation of Interim Life Safety Measures (ILSM) as compensatory measures prescribed by The Joint Commission (TJC) and in accordance with National Fire Protection Association NFPA 101 (Life Safety Code).

C. Construction and/or alteration to buildings, operations or maintenance activities can critically diminish, and over significant periods of time erode the life safety features built into existing structures. Until such time as the deficiency is corrected, it is necessary to take action to compensate for the diminished occupant’s level of life safety. ILSM are a selection of administrative actions and building modifications that are required to be taken to temporarily compensate for hazards posed by life safety deficiencies. The intent is to provide a level of life safety comparable to that described in the National Fire Protection Association Life Safety Code (NFPA 101) current version.

II. DEFINITIONS:

A. Authority Having Jurisdiction (AHJ): An organization, office or individual responsible for enforcing the requirements of a code or standard, or for approving equipment, materials, and installation, or a procedure.

B. Competent Person (CP): a person designated by the employer to act on the behalf of the employer, who is capable of identifying existing and potential hazards in the workplace and selecting the proper control strategy, who has the authority to take prompt corrective measures to eliminate the hazard as specified in 29 CFR 1926.32(f).

C. Hazard Area: An area of a structure or building that poses a degree of hazard greater than normal to the general occupancy of the building or structure. The definition of high hazard area is designated locations that contains equipment, materials or process that have increased risks for fire, explosion or health hazard. High hazard contents shall be classified as those that are likely to burn with extreme rapidity or from which explosions are likely. On VACHS premises all compressed gas manifold rooms and storage areas are classified as Hazard Areas.

D. Interim Life Safety Measures (ILSM): Are a series of administrative actions or construction activities employed as needed to temporarily compensate for the hazards posed by existing NFPA 101 Life Safety Code (LSC) deficiencies or construction activities that cannot be mitigated and immediately corrected, or during periods of construction.

Healthcare System Policy No. SO-006 -2-

These measures taken that are designed to protect patients, staff, visitors and property from fire and smoke, products of combustion, or dust. These measures include but are not limited to the following:

1. Inspect exits in affected areas on a daily basis. The need to accomplish this task is necessitated by the impairment of normal means of egress, blocking of exits, or hazardous conditions not normally encountered in the means of egress.

2. Provide temporary but equivalent fire alarm and detection systems for use when a fire system is impaired. The need to accomplish this task is necessitated by the lack of a suitable fire barrier, the presence of patient or staff in the adjoining area, or other hazards that require the presence of alarms and detection not available by the existing systems.

3. Provision of additional firefighting equipment. The need to supply additional fire extinguishers is based on the level of combustibles presents, the use of hot work, and other hazardous conditions that can be contained by local fire extinguishment.

4. Temporary construction partitions shall be constructed to assure that the potential for transmission of smoke, dust and contagious organisms are minimized. The partitions shall be constructed of materials that are non-combustible and be smoke-tight. Rated partitions may substitute for a fire watch if compensatory ILSMs are implemented and no occupants are jeopardized.

5. Increased Hazard Surveillance or fire watch of building, grounds and equipment may be conducted to assure effective management of life safety risks. Areas of special concern are high hazard areas; storage areas, construction storage areas and areas with plumbed medical gas systems or compressed gas storage areas.

6. Reduction of flammable and combustible loads by reducing storage, housekeeping and debris-removal procedures shall effectively reduce the fire load to the lowest level necessary for daily operations. Excess material will be stored in suitable areas outside of the protected occupancy.

7. Staff in areas where compartmentalization or structural features of life safety are impaired shall receive additional training that addresses changes in fire response and fire safety management required to compensate for the reduced level of safety.

8. Additional fire drills shall be conducted when conditions warrant in accordance with The

Joint Commission (TJC) requirements and as determined by the Hospital’s interim life safety measures (ILSM) policy. The Medical Center Environmental Safety and Occupational Health Office (ESOH) will conduct one additional fire drill per shift per quarter as needed based on the project scope and complexity; the systems effected, and demonstrated need.

9. When the Medical Center identifies Life Safety Code deficiencies that cannot be immediately corrected or during periods of construction, the Medical Center ESOH office will ensure temporary but equivalent fire alarm and detection systems are installed and tested monthly or as required by the device. The completion dates of the tests are documented.

Healthcare System Policy No. SO-006 -3-

The Medical Center determines when these inspections and tests are needed. The need for these inspection and tests is based on the scope of the project, its complexity, and the overall impact of the reduced existing or normal fire alarm and suppression systems.

10. Organization-wide safety education or Hospital-wide life safety training programs will be presented to develop awareness of any life safety deficiencies and construction hazards and the offsetting of ILSM. This is accomplished when the scope of the project is facility wide.

11. Posting signage identifying locations of alternative exits to everyone affected

E. Life Safety Code (LSC): The Life Safety Code is a set of minimum guidelines for the construction and operation of buildings, intended to provide and ensure a reasonable degree of safety to life during emergency situations. The Life Safety Code is prepared, published and periodically revised by the National Fire Protection Association (NFPA). The latest version of NFPA code is applicable to this policy.

F. Life Safety Systems: Include the following components:

1. Means of egress, the exit enclosure, and the public way

2. Life safety electrical circuits

3. Partitions or zones that compartmentalize the structure

4. Fire detection and alarm system

5. Fire extinguishers

6. Automatic fire suppression systems

G. Occupational Safety and Health Administration (OSHA): One of the Authority Having Jurisdictions for worker safety and health.

H. The Joint Commission (TJC): One of the accrediting bodies used by the VA Healthcare System.

III. RESPONSIBILITY:

A. When building deficiencies compromise the level of life safety protection identified during an inspection by VACHS Environmental Safety & Occupational Health Staff (ESOH), VACHS Facility Management Services Staff (FMS), VACHS Facility Engineers, VISN Staff during site inspections, Accreditation Surveyors, or any other Authority Having Jurisdiction, the Chief of FMS, the Chief of Construction Design Development in cooperation with the Chief of Environmental Safety & Occupational Health or their designee is responsible for determining if ILSM are required and to what extent to manage the impairment of the level of life safety until necessary repairs, modifications, or equivalencies can be effected.

B. When construction, demolition, renovation, or normal maintenance activities results in an impaired level of life safety, the Chief of Facilities Management Services, the Chief of Construction Design Development in cooperation with the Chief of Environmental Safety and

Healthcare System Policy No. SO-006 -4-

Occupational Health or their designee is responsible for determining which ILSM are required to manage the impairment of the level of life safety until the activity that created the impairment is completed.

C. ILSM is a shared responsibility as follows:

1. Medical Center Director (or appointed designee). Responsible for providing resources to maintain compliance with the Life Safety Code at all times.

2. Service Chief and Supervisors. Responsible for:

a. Participating in annual fire/life safety education and training.

b. Participating in the review and assessment of Interim Life Safety Measures when requested.

c. Protecting patients, visitors and staff from injuries by making immediate notification through the chain of command when conditions are identified that have or could compromise life safety within the work area.

3. Chief Facility Management Services and Chief of Construction Design Development (or appointed designee). Responsible for:

a. Conducting Pre-Construction Risk Assessment for each renovation, construction project or maintenance activity that will impact fire and life safety per established healthcare policy and notifying Safety Office prior to starting the work.

b. Ensuring that appropriate Interim Life Safety Measures (ILSM) are implemented on all renovation and construction work in accordance with TJC, Environment of Care and Life Safety Chapters.

c. Ensuring the construction safety, security and infection control program includes periodic construction hazard surveillance activities with subject matter expert membership of the Construction Safety Team based on scope for each project.

4. Chief Environmental Safety & Occupational Health Service (or appointed designee):

Responsible for:

a. Conducting review and final approval of all ILSM Assessments, ILSM Plans and Interim Life Safety Measures.

b. Completing inspections of life safety deficiencies when these deficiencies are identified outside of planned maintenance work or construction activities.

c. Maintaining a database and system of recordkeeping of all assessments, active and inactive ILSM’s and inspections.

d. Development and delivery of education and training in support of the ILSM program.

Healthcare System Policy No. SO-006 -5-

IV. PROCEDURES:

A. For all Life Safety Deficiencies, the basic procedure is the same.

1. Attachment A is an Assessment Worksheet used to ascertain and document ILSM need.

a. If any one of the conditions in the Assessment Worksheet is answered yes, the need for and identification of appropriate interim measures will be completed and submitted to the Chief of Environmental Safety & Occupational Health Service or designee for review and approval.

If none of the Assessment Worksheet questions are answered in the affirmative, “yes”, the form will be noted and submitted to the Chief of ESOH.

2. Attachment B is used to plan and implement ILSM.

3. Attachment C is used to document ILSM measures implemented until project completion.

4. The duration of ILSM requirements is determined based on assessment of risk and projected mitigation date. All active ILSM will be reviewed perordicly for any changes and have a limited issuance date. They will not exceed 180 days in duration before reevaluation for validity and activity status.

5. The ESOH staff will notify VISN and local Fire Department when a fire alarm or sprinkler system is out of service more than 8 hours for alarm and 10 hours for suppression system in a 24 hour period in an occupied building, a fire watch will be initiated. The ESOH staff will notify the local Fire Department. Notification and fire watch times will be documented. The ILSM will be posted in the affected areas and at entrance of the construction area. The impacted services and occupants will be notified the life safety deficiencies and ILSM.

6. A fire watch is an assignment of a person or persons to an area for the express purpose of notifying the fire department, the building occupants, or both of an emergency; preventing a fire from occurring; extinguishing small fires; or protecting the public from fire or life safety dangers. The contractors will be responsible to conduct fire watch in the construction areas. The area occupants will be responsible for fire watch in their working areas outside the construction barriers. In weekend and after normal working hours, VA Police or other supporting staff from FMS or EMS may be called for support on fire watch in non-occupied areas. The frequency of the fire watch (e.g. hourly) will be determined by ESOH staff in the ILSM based on the life safety risk assessment (e.g. fire detection system, fire and smoke barrier configuration, impact on egress, occupant population, high risk patient care or business occupancy, etc.).

B. When building deficiencies are identified during an inspection, the Chief of Facilities Management Service (FMS) in cooperation with the Chief of Environmental Safety and Occupational Health (ESOH) or their designee is responsible for determining which of the ILSM are required to manage the impairment of the level of life safety until necessary repairs, modifications, or equivalencies can be affected.

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C. Construction Activities:

1. All construction activities will be done under the supervision of the Chief of FMS or Chief of Construction Design Development.

2. During the Design Development stage of a project the Chief of Environmental Safety and Occupational Health and Construction Safety Committee will review the plans.

When needed an ILSM plan assessment will be conducted for the specific project with the help of the Architect or Engineer assigned to the project using Attachment A and B. The ILSM plan will be reviewed by the ESOH safety engineer or fire & life safety specialist for technical content and thoroughness.

3. When no Architect or Engineer is associated with a project, the Project Manager will meet with the ESOH safety engineer or fire & life safety specialist who will assist in the completion of Attachment A and B.

4. ILSM plan is provided as part of a contract package, the contractor will be required to submit a specific written plan, which represents the Interim Life Safety Measures that they will be providing for the project, in compliance with the general plan. The FMS Project Manager and ESOH safety engineer or fire & life safety specialist will jointly recommend approval or rejection of the proposed measures.

5. Contractor’s ILSM plan will be reviewed and approved by both the Chief of FMS and

Chief of ESOH or their designees prior to starting the work.

6. The Contractor’s representative will inspect the construction area daily to audit routine compliance and unusual conditions. Conditions not in conformance with the inspection checklist (Attachment C) will be reported to the Chief of ESOH and the Chief of FMS or Construction Design Development. Weekly, the Contractor, Project Manager or ESOH Construction Safety Engineers will sign the ILSM inspection forms and submit a copy of the signed forms to the ESOH office.

D. Planned Maintenance Activities:

1. Prior to the commencement of any planned maintenance activities that will cause impairment of any life safety system, the Project Manager or Shop Foreman is responsible to initiate an ILSM evaluation by using the attached written Assessment Work Sheets, Attachment A and B. The ILSM plan will be reviewed by the ESOH safety engineer or fire & life safety specialist for technical content and thoroughness.

2. The Assessment Worksheet is designed to evaluate the project or deficiency for impact on existing, compartmentation, fire detection and alarm system, ignition sources, storage, debris, emergency access and other potential concerns.

3. Completed Assessments are to be delivered to the Chief of ESOH or designee.

4. If any one of the conditions in the Assessment Worksheet is answered yes, the need for and identification of appropriate interim measures will be completed and submitted to the Chief of Environmental Safety & Occupational Health Service or designee for review and approval. If none of the Assessment Worksheet questions

Healthcare System Policy No. SO-006 -7-are answered in the affirmative, “yes”, the form will be noted and submitted to the Chief of ESOH.

D. Inspection period activity: The Project Manager or COR that is tasked with initiation of the ILSM assessment is responsible to conduct inspections of active ILSM code measures during the duration of the LSC deficiency. ESOH safety engineer or fire & life safety specialist will also provide additional surveillance. Copies of the Inspection shall contain the project identification number or physical location where the deficiency is occurring. All inspection records shall be copied to the Chief of ESOH and maintained in project files for construction projects.

1. Gaps or deficiencies in the ILSM shall be immediately brought to the attention of the Project Manager for immediate corrective action. Inspections shall be completed according to the following frequency:

a. At project initiation.

b. Hourly tours when Fire Watch is implemented. This work is performed by the contractor’s personnel, and monitored by medical center staff.

c. Daily; inspection of exiting for access, and integrity. This work is performed by the Competent Person (CP), a duty of the contractor, and overseen by medical center staff.

d. Weekly; inspection of construction sites for fire and smoking barrier integrity, storage, debris removal, fire protection system integrity and extra firefighting equipment.

e. Monthly; testing of additional detection and firefighting equipment.

V. REFERENCES:

➢ The Joint Commission, Hospital Accreditation Standards, Life Safety chapter, current edition

➢ National Fire Protection Association NFPA 101 “Life Safety Code”

➢ Occupational Safety & Health Administration (OSHA) 29 CFR 1910 and 1926

➢ VA Fire Safety Guidebook

➢ VA Fire Protection Design Manual

➢ VA Master Specifications on the Technical Information Library (TIL):

http://www.cfm.va.gov/TIL/

➢ VA CEOSH Website: http://vaww.ceosh.med.va.gov/01FS/Pages/SpecificTopics.shtml

➢ Healthcare System Policy No 138-073, “Safety, Life Safety and Infection Control

Assessment and Procedures During Construction.”

➢ VHA Directive 7715 “Safety and Health During Construction” http://www.cfm.va.gov/TIL/ http://vaww.ceosh.med.va.gov/01FS/Pages/SpecificTopics.shtml

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VI. RESCISSION:

Healthcare System Policy No. SO-006 dated December 12, 2013.

VII. REVIEW SERVICE DATE: April 6, 2021 Safety Office

GERALD F. CULLITON

Director, VA Connecticut Healthcare System

Attachments:

Attachment A: Assessment Worksheet Attachment B: Interim Life Safety Evaluation Form Attachment C: Interim Life Safety Inspection Form

Attachment A to Healthcare System Policy SO-006

VACHS ILSM Requirement Assessment Worksheet

1. These criteria will be used to evaluate smoke compartments in which a Life Safety code deficiency has been identified, or in which construction, renovation or alteration activities are planned. Any “Yes” answers below may require ILSM to address occupant safety.

a. Documentation of any methods and measures under comment section.

b. Completed form shall be maintained in project files with a copy maintained by the

Chief of ES&OH or designee.

Project Name: Submitter/Project Manager Name:

Project #: _______ Date Submitted: _____ Building: ________ Expected Project Start Date: _ Floor & Room# Projected Project Completion Date: _

CRITERIA YES NO

The scope of work (SOW) will alter or significantly compromises exit, exiting access, exit discharge building elements, or emergency forces access to area(s)

The SOW will alter or compromises building compartmentation including fire or smoke walls, floor/ceiling assemblies, corridor walls, use area doors or other defend in place locations

The SOW will alter or significantly impair the building Fire Detection System (Fire alarm) for more than 4 hours in a 24 hour period. (Alarm out of service 8 or more hours in 24 hours requires fire watch and Fire Dept. notification)

The SOW will alter or significantly compromise the building Fire Suppression System (Sprinklers, fire pumps, standpipes) for more than 10 hours in a 24 hour period (requires fire watch and Fire Dept. notification)

The SOW requires the use of temporary construction partitions constructed to be smoke-tight, made of non-combustible or limited-combustible materials that will not contribute to the development or spread of fire.

***************All ‘No’ response indicates ILSM is likely not required

2. A “yes” answer to any of the above criteria indicates that an ILSM may be initiated.

3. Use the Interim Life Safety Measures Check Sheet and Assessment Worksheet to determine ILSM measures and equivalencies that will be required based on the compromise to the VACHS Life Safety System.

4. ILSM measures require review and approval by the Chief of FMS, and Chief of ESOH or their designee.

5. Copies of all written records associated with the ILSM program shall be provided to and maintained by the Chief of ESOH. Documents that are related to project records need to be maintained in the project folder.

6. If an ILSM is not required, provide the completed assessment to the Chief of ESOH for review and approval. Maintain a copy of the approved form in the project file.

Description of Work and Anticipated Duration of System Impairment:

Attachment A to Healthcare System Policy SO-006 -2-

Assessment of Life Safety Risks:

In the space below, identify the Life Safety impact or problem that will require an Interim Life Safety Measure. Typically these are degradations of existing systems, but they may be long standing LSC deficiencies as well. Some examples of risks are found on the Y axis of Attachment B.

Interim Life Safety Measures: Select measures from Attachment B, X axis intersection with Y axis risks. Items listed with a P for planned against likely deficiencies that will be encountered during construction, renovation, or maintenance activities are for example only. If the planned items for your work are above or below those normally encountered based on a risk assessment, write it up below in the space provided. The definition for these actions is listed in the body of this policy. Each project will have its own sheet for checks, with a space for initials and date in the last block. If the entire row is not applicable to the project, strike out from the table.

Policy dictates that during specified work elements, that the VISN be apprised of the work to be done, its duration, and the effect it will have on patients, Staff, and Visitors. VISN notification will be made by ESOH staff. If the scope of work will impair the building Fire Protection System for more than 8 hours in a 24 hour period for alarm and 10 hours for suppression system in an occupied building, a fire watch will be required. The ESOH staff will notify the local Fire Department. Notification and fire watch times will be documented in the project file.

Inspection frequency and responsible parties:

The space and protective features are inspected daily by the contractor, and at least weekly by the VA Project Engineer (COR) or the Environmental Safety & Occupational Health Service safety engineer or fire & life safety specialist. Copies of checklists are maintained on the shared drive. Originals are maintained in the Project Binder. If the frequency of inspection is modified from this standard, please list here:

An updated ILSM assessment will be required if the scope of work changes in building ___, Rooms __________________________________________________________________.

Reviewed By:___________________________Chief, FMS (or designee) Date:___________ Approved By: ___________________________Chief, ESOH (or designee) Date:___________

Attachment B to Healthcare System Policy SO-006

Project Name: ___________________ Expected Duration: _ ________ Project No: Building: ___________ Floor: _ _Room#:___ ________

All notifications and staff training to be performed by ESOH staff.

Inspection or acceptance date: 101 101 TJC ILSM measures to compensate for deficiency

Project Manager/COR: VA VA VA Select P (plan) item if applicable, enter I (implemented) if ESHO agreed needed by risk assessment

Interim Life Safety Measures Matrix Assessment Tool

Significant Life Safety Code Deficiencies or Construction Related Conditions

N o ti fi c a ti o n t o F ir e

D p a rt m e n t

In s ti tu te F ir e W a tc h

E n s u ri n g a lt e rn a te e g re s ig n a g e v is ib ili ty a n d v ia b ili ty

V

IS

N N o ti fi c a ti o

F ir e R e s p o n s e T e a m ti fi c a ti

In s p e c t e x it s i n a ff e c te re a s o n a d a ily b a s is b

P ro v id e t e m p o ra ry b u t e q u iv a le n t fi re a la rm a te c ti o n s y s te m s c

P ro v is io n o f a d d it io n a l fi re fi g h ti n g e q u ip m e t.

T e m p o ra ry c o n s tr u c ti p rt it io

In c re a s e d h a z rd u rv e ill a n c e f)

R d u c ti o n o f fl a m m a b le d c o m b u s ti b le l o a d in g

A d d it io n a l s ta ff tr a in in in ff e c te d a re h

A d d it io n a l fi re d ri lls i ff e c te d a re a a ja c e n t z o n e s i)

T m p o ra ry L

S C s y s te m te te d m o n th ly j)

O rg a n iz a ti o n w id e s a fe ty u c a ti o n o r h o s p it a l w id e L

S C t ra in in g

1. Altering an approved exit. (Stairwell door, corridor, etc.) P P P P P P

2. Driveway to ER or back door entrance blocked. P P

3. Fire service equipment is blocked. (Fire hydrants, standpipes, etc.)

P P P

4. Firefighting equipment impaired. (Fire hydrants, standpipes, etc.)

P

5. Sprinkler system down after normal duty hours. P P P P P P P P P

6. Sprinkler system down over 10 hours for testing, repair, or maintenance in an occupied building.

P P P P P P P P P P P P

7. Sprinkler system down during construction replacement. P P P P P P P P P P P P P

8. Fire alarm system shut down after normal duty hours. P P P

9. Fire alarm system down for over 8 hours for testing, repair, or maintenance in an occupied building.

P P P P P P P P

10. Fire alarm system during replacement. P P P P P P P P P P P P P

11. Renovation involving demolition of walls and/or ceilings. P P P P P P P

12. Hot work operations performed. See FMS Policy # 30 P P P P P

13. Flammable gasses, liquids, or solids utilized. P P P P

14. Renovation involving at least an entire zone P P P P P P

15. Ceiling tiles removed on both sides of a smoke barrier. P P P

16. Smoke fire barrier breached. P P P

Attachment C to Healthcare System Policy SO-006

VACHS ILSM Inspection Form

Project Name & Number: Project Manager/COR Name:

Building/Floor/Location: ________ ILSM Surveillance Date: _ ILSM Tracking No.: _ Surveillance Conducted by: _

INTERIM LIFE SAFETY MEASURES

(remove if not used)

Compliance Status (Yes/No/NA) Name of Responsible

Person Sat Mon Tue Wed Thur Fri Sun

1 Notification to Fire Department or other emergency response group and initiates a fire watch when fire alarm systems is out of service more than 8 hours in a 24 hour period in an occupied building.

1a Notification to Fire Department or other emergency response group and initiates a fire watch when fire sprinkler systems is out of service more than 10 hours in a 24 hour period in an occupied building.

1b Has Fire Watch been provided to the impaired fire protection system in the occupied building/area and fire watch times documented?

2 Exits are inspected on a daily basis and are free and unobstructed. No construction materials, equipment, or debris block free use of all exits adjacent to the construction site or are impacted by the project.

3 Temporary exit signs are in place and proper signages are in the paths that are affected.

4 Provide temporary, but equivalent fire alarm and detection system.

Provides additional fire-fighting equipment (fire extinguishers). Equipment is functional and tests are up to date.

6 Temporary construction partitions are smoke tight, or made of noncombustible material, or made of limited combustible material that will not contribute to the development or spread of fire.

7 Temporary fire rated barriers are used with additional fire detection equipment in lieu of fire watch. Barrier is complete from outside wall and deck to deck.

8 Surveillance is increased of buildings, grounds and equipment with special attention to construction areas and storage, excavation and field offices.

9 Enforces storage, housekeeping and debris removal practices that reduce the building’s flammable and combustible fire load to the lowest feasible level.

10 Additional training is provided to those in the hospital on the use of fire-fighting equipment.

Training is documented.

11 One additional fire drill per shift, per quarter is conducted.

12 Temporary systems are tested and inspected monthly, and the completion dates for these tests are documented.

13 Education is conducted to promote the awareness of building deficiencies, construction hazards and temporary measures implemented to maintain fire safety

14 Training for those who work in the hospital is done to compensate for impaired structural or compartmental features.