In Compliance | NFPA 101
Creating effective emergency management programs for hospitals
BY RICH BIELEN
The recent earthquakes in Puerto Rico and the ongoing Australian wildfires are just a couple of examples of the kind of events health care facilities must plan for when developing emergency management programs, or EMPs.
NFPA 101®, Life Safety Code®, requires an evacuation and relocation plan for new and existing health care occupancies. This plan focuses on an evacuation and relocation action for conventional fire events, as well as drills that should be conducted for these events. It provides prescriptive requirements for procedures in case of a fire, as well as a fire safety plan, staff response, and other operational features to ensure patient safety.
As the earthquakes and wildfires demonstrate, however, planning for a conventional fire event is just part of a larger EMP. That’s where NFPA 99, Health Care Facilities Code, and NFPA 1300, Standard on Community Risk Assessment and Community Risk Reduction Plan Development, come into play. Both of these documents complement the Life Safety Code by addressing all hazards, including fire, and should be considered in any conversation about patient evacuation and relocation.
NFPA 99, Chapter 12, Emergency Management, requires users to conduct a hazard vulnerability analysis, which includes consideration of natural hazards and geological events, as well as human-caused and technological events, for health care facilities. Once the hazards are identified and prioritized, mitigation and preparation strategies must be developed. An emergency operations plan is then developed, which describes the command structure and addresses critical functions such as communications, resources and assets, safety and security, clinical support, essential utilities, exterior connections, and staff roles. The process described in NFPA 99 assists fire protection engineers and hospital administrators in identifying where the hazards are and how to plan accordingly. If evacuation or relocation are necessary, NFPA 101 provides the necessary requirements to implement these actions.
The new NFPA 1300 is a tool that addresses an all-hazards risk-assessment approach for communities, which can be defined by users and can range from a single facility to an entire state or region. This standard describes a process that helps users determine the hazards and risks facing their community or facility, and how to prioritize those risks. The advantage of using NFPA 1300 is that it makes users look beyond their own facilities and consider how they relate to the larger community. There may be hazards and risks presented by the community that can affect a health care facility, and the risk analysis described in NFPA 1300 is designed to identify these situations. As a bonus, when used in conjunction with NFPA 99, the standard can address the program provisions of the Centers for Medicare & Medicaid Services’ (CMS) rule for emergency preparedness, as CMS does not reference Chapter 12 of the 2012 edition of NFPA 99. However, when that chapter and NFPA 1300 are used together, they provide a methodology that addresses the CMS requirements.
Another important component of an EMP is crisis standards of care, or CSC. In situations that are truly catastrophic, such as widespread damage from tornados, floods, or hurricanes, facilities will not be able to provide a normal or standard level of care. In this case, the emphasis shifts from individual patient care to a larger community need. Many difficult decisions will need to be made during this crisis period—often marked by a severe shortage of resources—where coordination with multiple agencies is essential, which is why careful pre-planning is critical when considering CSC. NFPA 99 requires that CSC be developed through a communitywide approach, where triage and medical service allocation become very important.
Planning a patient evacuation and relocation is a complex process for a hospital or any other health care facility, but it is essential in our efforts to protect a vulnerable population. Resources such as NFPA 101, NFPA 99, and NFPA 1300 can provide users with important tools to create effective and comprehensive solutions.
Rich Bielen, P.E., is a former fire protection engineer at NFPA. NFPA members and AHJs can use the Technical Questions tab to post queries on NFPA 101 at nfpa.org/101.