As if biomeds didn’t have enough to keep us busy, the issue of relocatable power taps (RPTs) keeps dogging us. Let’s take a little refresher to bring us up to date on the concerns surrounding this issue.
To understand the controversy, it’s worth remembering that hospitals are old. Many of them (at least parts of them) were built 20, 30, 40, or more years ago. Even 10 years ago, their designers didn’t envision how many electrical devices would one day need to be plugged into the wall outlets. So patient care areas were built with just a few 110 volt duplex outlets each. They were then conveniently placed in the center of each wall, so that each room had six or eight outlets per room.
Of course, intensive care areas received a few extra outlets. Surgery units were given even more. Designing additional outlets was a matter of balancing their cost with the necessity and convenience of better accessibility. You see, when more outlets are added, more wires must be run, more circuit breakers must be added, and larger breaker panels must be installed. The seemingly small cost of adding an extra outlet (or six) to a room can soar once the design engineers begin calculating loads, capacity, and other building costs. Therefore, as with many building features, the numbers of outlets were often kept to a conservative number.
Enter the explosion in the volume of medical devices—and computers, and personal electronics, and interface boxes, and all manner of IT-related communications. In the past, many of these items could be unplugged and stored in the corner when they were not actually being used. Now most devices have batteries that require them to stay plugged in to be charged. And some of these devices communicate with other systems 24 hours a day, also demanding that they remain connected to a power source.
In many cases, our need for electrical outlets has grown far beyond the hospitals’ initial design. And, unfortunately, nobody on the facilities side has become aware of or managed this challenge, nor have they submitted plans to keep up with the rising demand in most areas of the hospitals.
As electrical outlets became scarce, there were only a couple groups that stepped forward to solve the problem—the nurses themselves and the biomeds. Unfortunately, the lack of a complete understanding of power safety meant that immediate problems were often solved with little or no thought given to the big picture or the impact on critical patient care equipment.
Nurses could, and did, easily purchase consumer-grade outlet strips from office supply companies when they ordered pens and Post-it pads. Biomeds later bought high-priced outlet strips from electrical supply companies. These were of much better quality, but they did not solve the long-term problems.
The dangers associated with these short-term solutions were correctly identified by the Centers for Medicare and Medicaid Services (CMS) several years ago. Ganging many more devices into an outlet than the original design calls for risks tripping the circuits and cutting power to important patient care equipment. Using low-quality outlet strips with poor design and inferior materials can lead to electrical faults. Placing these outlet strips directly on the floor could expose them to water infiltration and corrosion or faults. Using outlet strips with their own circuit breakers and on/off switches introduces additional points of failure, especially for poor-quality devices. Finally, mixing consumer electrical devices with medical devices could cause high leakage currents or circuit breaker trips.
Power Strips and CMS
These risks are why, in December 2011, CMS issued an order prohibiting the use of any multiple outlet strips in the patient care areas of any hospitals where they had jurisdiction. This absolute and total ban also applied to previously allowed outlet strips that were mounted to medical devices or secured to IV poles, not just those lying on the floor. The memo was not accompanied by any guidelines for implementation or any timeline for completing the changeover. The document was obviously an ill-thought-out, knee-jerk reaction that failed to take into account the realities of time constraints or finances in hospitals.
Then, in September 2014, CMS issued a “Categorical Waiver for Power Strips Use in Patient Care Areas.” This document softened the original memo and was the result of hundreds of hours of education and lobbying by numerous individuals and organizations related to medical devices and healthcare. The guidelines in the new memo include the following:
- CMS identified a new category of outlet strip called a special relocatable power tap (SRPT). This strip is defined by UL 1363A and is the only type that may be used to provide power to patient care equipment.
- Patient care and nonpatient care equipment may not be powered by the same SRPTs in a patient care vicinity.
- SRTPs in a patient care vicinity must have all unused outlets blocked so that no additional equipment can be plugged in.
- The ampacity of all equipment connected to an SRPT must be measured and calculated so as not to exceed 75% of the flexible cord ampacity.
- All SRPTs must be placed on a regular maintenance program to verify and document the mechanical and electrical integrity of the assembly.
- All SRPTs must be permanently attached to an item of equipment.
- SRPTs may not be “daisy chained” together.
Please read the complete September 2014 memo for more details and exact verbiage.
I have not polled a large number of hospitals to see how they are coming along in their progress toward CMS compliance. I suspect that a few are complete, many are still getting started, and others are in denial, hoping that the problem will be replaced by another concern before they are written up for this particular infraction. I also suspect that a good many have implemented incomplete solutions that will be ineffective in meeting the intent of the CMS guidelines.
There are several ways to meet the CMS protocol. The most direct is what I call the “brute force” method. Many hospitals seem to employ no thought—they just go out and buy hundreds of SRPTs to replace all the low-grade outlet strips throughout their hospital and clinics. They then place the new strips on their preventive maintenance program and provide the ongoing surveillance that CMS requires. Combined with measuring current draw and locking out unused outlets, this approach meets the CMS mandate. But the cost is very high: The cost of initial purchase is high, the cost of deployment is high, and the cost of annual testing and documentation is high.
There are other ways. One approach I prefer is to think a little. First, identify where all the existing outlet strips are currently in use. Then eliminate as many as possible before running out and buying a bunch of SRPTs that will cost a lot to maintain. The use of multioutlet strips can be reduced in several ways.
- There are two- and three-headed power cords that are not multioutlet strips, but they may help reduce the number of plugs to match the available outlets.
- Engineering can add additional surface-mounted, plug-mold outlets that are acceptable to CMS.
- Fifteen to 20 feet long power cords would enable equipment in one location to reach an available outlet in another part of the room.
- Finally, equipment that is not required in its present location can be relocated.
I have found that using these strategies can eliminate the need for multioutlet strips (or RPTs) in patient care areas by as much as 80%.
After as many RPTs as possible have been eliminated, then is the time to go out and purchase SPRTs from the quality companies that manufacture them. Because they are now fewer in number, they are less costly to deploy and much less costly to maintain. And the outlet strips you have eliminated require no maintenance at all. Your annual preventive maintenance hours should increase by only a few hours per year.
Please do not ignore this problem. I understand that hospitals are receiving written notices of deficiencies for unmanaged outlet strips throughout their facilities. CMS acted rashly in its initial memo, but subsequently corrected its error. The agency’s current rules are sound and, if followed completely, will eliminate all the previously mentioned problems in their entirety.
Patrick Lynch is a biomedical manager with over 40 years’ experience managing HTM programs. For more information, contact chief editor Jenny Lower at firstname.lastname@example.org.
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