Answers on business occupancies, power taps and monthly load tests
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January 19, 2020
By Brad Keyes, CHSP (www.keyeslifesafety.com)
Q: If I have a new freestanding business occupancy that is licensed, would CMS enforce the provisions of the 2012 edition of NFPA 101 (LSC)? I wasn't able to find anything in the Conditions of Participation that specifically addresses this. I know that The Joint Commission (TJC) would not enforce their Life Safety (LS) chapter, but wasn't sure if CMS had a different take on this.
A: I don’t agree with your statement that TJC would not enforce their LS chapter at a freestanding business occupancy that is part of the hospital’s CMS Certification Number (CCN). On the contrary, I know that TJC will expect compliance with their LS chapter standards at off-site business occupancies (since I was a TJC surveyor) and their standards EC.02.03.01, EP 4 and EC.02.03.03, EP 2 support that. What you may be referring to is that TJC will likely not send their LS surveyors to the off-site business occupancies, but instead they will send other surveyors who will look for basic LS issues.
Brad Keyes, CHSP, owner of Keyes Life Safety Compliance, answers questions about life safety.