1. Meeting the CMS Requirements Simply, Easily and Cheaply Patrick Lynch Global Medical Imaging plynch@gmi3.com

2. Who am I? CBET, CCE, CPHIMS, CHTS-PW, fACCE 40 years in Biomed Managed large In-house, ISO and corporate Biomeds Active in certification of BMETs and CEs 1 st Pres of NCBA (North Carolina branch) - 1980 President, HTMA-SC Treasurer – HTMA-GA Member of all Biomed Associations (honorary NC, KY, Utah) Board Member – META, SC, GA Advisor – OH, KY, TN, UT, VA, NC, Texas Writes monthly for TechNation and BI&T (AAMI) - Heineman Medical Foundation (Guatemala) Currently, works for GMI is sales development, who sponsors my activities 2

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5. An operating room with at least 10 overhead booms. No cords on the floor. 5

6. A small, but typical OR. 6

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8. The Problem Extension Cords and Multiple Outlet Strips (Relocatable Power Taps - RPTs) Nobody had assigned responsibility for them. Nobody tests them regularly. Many low-quality RPTs may compromise the safety of otherwise safe medical equipment. Comingling of medical devices and consumer items may trip breakers, removing power to necessary medical equipment. 8

9. CMS’s reaction Ban RTPs and extension cords totally. Well, not really, we were premature in our total ban. Here is what you need to do to use them: 9

10. Problems with Outlet Strips Daisy Chaining Overloading Wound or knotted cords No UL label Plug is hanging out of the receptacle Device is HOT to the touch Melted, frayed, discolored wires It is used as permanent wiring (over 90 days) Ground pin missing Ref – www.nachi.org.power-strips.htm 10

11. Short Power cords will not reach an available outlet. – Patient areas - little problems, lots of outlets. – Large ORs do not allow power cords from tables to reach the wall. – If a cord reaches an outlet, it is already used by other items. Non-medical devices compete with medical devices for power. 11

12. Too few wall outlets exist – The quantity of medical devices has multiplied since the electrical designs were made for existing building. – As the uses for medical spaces change, outlets are often in the wrong place, not where needed. 12

13. Home-made and WalMart outlet strips are often of poor quality. 13

14. The Real Problem Sometimes the extension cords are to mate dissimilar plug to one another. 14

15. Worst Case Homemade 15

16. Everybody overlooks the Outlet Strips and extension cords. – Facilities test the outlet in the wall annually. – Biomed tests the equipment to the end of its power cord. – Nobody inventories, monitors, tests, or documents anything regarding RPTs or extension cords. 16

17. Too many items plugged into a single wall outlet or RPT can trip breakers. – Patients use hair driers, and other consumer electrical devices. – These can affect the electrical supply, or increase leakage to important medical equipment. 17

18. CMS Waiver Ref S&C:14-46-LSC 9-26-2014 CMS is permitting a categorical waiver to allow for the use of power strips in existing and new health care facility patient care areas, if the provider/supplier is in compliance with all applicable 2012 LSC power strip requirements and with all other 2000 LSC electrical system and equipment provisions. 18

19. CMS Waiver Ref S&C:14-46-LSC 9-26-2014 Power strips may be used in a patient care vicinity to power rack-, table-, pedestal-, or cart-mounted patient care-related electrical equipment assemblies, provided all of the following conditions are met, as required by section 10.2.3.6: 1) The receptacles are permanently attached to the equipment assembly. 2) The sum of the ampacity of all appliances connected to the receptacles shall not exceed 75% of the ampacity of the flexible cord supplying the receptacles. 3) The ampacity of the flexible cord is suitable in accordance with the current edition of NFPA 70, National Electrical Code. 19

20. CMS Waiver Ref S&C:14-46-LSC 9-26-2014 4) The electrical and mechanical integrity of the assembly is regularly verified and documented through an ongoing maintenance program. 5) Means are employed to ensure that additional devices or nonmedical equipment cannot be connected to the multiple outlet extension cord after leakage currents have been verified as safe. 20

21. CMS Waiver Ref S&C:14-46-LSC 9-26-2014 Power strips providing power to rack-, table-, pedestal-, or cart-mounted patient care-related electrical equipment assemblies are not required to be an integral part of the manufacturer tested equipment. Power strips may be permanently attached to mounted equipment assemblies by personnel who are qualified to ensure compliance with 10.2.3.6. 21

22. CMS Waiver Ref S&C:14-46-LSC 9-26-2014 If power strips are used in any manner, precautions as required by the LSC and reference documents are required, including, but not limited to: 1.installing ground fault and over-current protection devices; 2.preventing cords from becoming tripping hazards; 3. connecting devices so that tension is not transmitted to joints or terminals; 4.no “daisy chaining” power strips” using power strips that are inadequate for the number and types of devices, and 5.no overloading power strips with high-load devices. 22

23. CMS Waiver Ref S&C:14-46-LSC 9-26-2014 Power strips providing power to patient care-related electrical equipment must be Special-purpose Relocatable Power Taps (SPRPT) as listed in UL 1363A or UL 60601-1. 23

24. Action Plan 1. Replace all detachable power cords with 15 to 20 foot long ones. – Buy a bunch of them from a commercial company. – Increase wire size from original gauge to 16 or 14 gauge to reduce voltage drop due to longer length, as needed. – As you sweep the hospital, remove all RPTs that become unnecessary due to these longer cords. – Especially focus on Surgery, Critical Care and NICU. This step should eliminate 80% of all RPTs. 24

25. For items with hard-wired power cords (video carts, OR tables, exam tables, etc.) 1.Purchase male and female twist-lock plugs. 2.Cut the power cord about 6 inches from the machine. 3.Install a male twist-lock to the equipment cord. 4.Make a new power cord, 15 to 20 feet long, with a straight-blade male plug and a female twist lock.  Now you have a longer power cord, and have not had to take the time to actually go inside the unit to make time-consuming changes. 25

26. ORIGINAL CORD Medical Equipment with standard power cord. 6 or 10 foot cord 26

27. Medical Equipment with modified power cord. 15, 28, 20 or 25 foot cord Male and female twist- Lock connectors 27

28. Easily purchased from Lowes or Grainger. Quickly installed without opening the equipment. Now you have a modified power cord, NOT an extension cord. 28

29. Where you legitimately need RPTs: – Purchase Special RPTs from AIV or Tripp Lite – They meet extra standards and have long power cords. – Inventory them, – risk-rank them, – put them on your PM schedule, as per their risk ranking. 29

30. How to comply Extra steps required for Special RPTs: – Measure current draw to RPT when all connected devices are fully operational. Current may not exceed 80% of capacity. – Plug all unused outlets to prevent the addition of other equipment which could increase the current draw, or increase leakage current. – Use child-proof outlet protectors Tripp Lite makes one that is unremovable except with a special tool. 30

31. Label all High-Current or Life-Support Device Cords 31 Plastic White on Red Engraved approx. 2”x4” tie-wrapped to cord near electrical plug. Important for Ventilators and Anesthesia Machines

32. How to test current draw of an SPRPT 32 1.Must have all equipment plugged in and turned on. 2. Use clamp-on ammeter and line cord splitter.

33. How to comply Collect all unapproved outlet strips and send them to Biomeds Without Borders for distribution to third world countries. 33 www.BiomedsWithoutBorders.com

34. Long Power Cords, detachable – AIV, 18 or 25 feet long, 16 or 14 gauge Twist Lock electrical plugs – Lowes, Hubbell, L5155PZ and L5155CZ Clamp-On Ammeter – Lowes, Southwire, 21060T AC Line Splitter – Extech 480-172 Outlet Plugs, unremovable – Tripp Lite, HGOUTLETCVR SPRPT – AIV –Powwermate www.aiv-inc.com – Tripp Lite – PS-415-HGULTRA www.tripplite.comwww.tripplite.com 34

35. Pat Lynch plynch@gmi3.com 704-941-0116 35