Joint Commission may expect more than local codes

Pendleton Memorial Methodist Hospital in New Orleans pointed out that it had met all local building and safety codes regarding its emergency generators, but that may not be a high-enough standard. The Joint Commission in Oakbrook Terrace, IL, has expectations regarding emergency preparedness that may exceed any local requirements.

The Joint Commission has two standards that concern emergency generators, says Jerry Gervais, CHFM, CHSP, BSME, associate director engineer with The Joint Commission, who worked as an engineer in hospitals for more than 30 years. The first applicable standard is "EC.02.05.03 — The hospital has a reliable emergency electrical power source." That standard has six elements of performance that outline the locations in the hospital that must be supplied with emergency power. The next standard is "EC.02.07 — The hospital inspects, tests, and maintains the emergency power systems." Exactly where to install the generator is not prescribed by The Joint Commission in any standard, but Gervais says the standards require that the hospital be able to generate emergency power in an emergency, and the New Orleans experience shows that placement can be critical to that effort.

Gervais spent 2½ years inspecting hospitals in the New Orleans area after Katrina, looking at how systems failed, what might be learned from the experience, and ensuring hospitals could safely reopen. Generators were a key issue, he says.

"Exactly where they are placed is governed by the authority that has jurisdiction to approve their plans, most typically the state. Installing these things in the lower levels is very common, but in areas that are prone to flooding, these problems can occur," he says. "Why do they install them in lower levels? It's just physics. These things weigh tons and tons. It's a big, giant diesel engine."

Moving the engine and fuel supply to a higher level can require extensive reinforcement of the structure, and some states will not allow fuel storage above ground, especially within a hospital building, because of the fire hazard. That may mean there is no easy solution, but Gervais says hospitals in some communities will have more obligations to site the generator appropriately because of their local conditions.

The emergency generators in New Orleans survived the hurricane, which is a common risk in that region, but they were not located in such a way that they could remain operational once the levees broke and the city flooded. The placement had been approved by local authorities, apparently with the reasoning that such a flood was not a high enough risk to justify a different placement, Gervais explains.

Gervais advises risk managers to study the utilities requirements in the hospital's licensing act, searching for guidance on placement. Any new facility design should consider the local potential for disasters and place the generators out of harm's way.

"Obviously, installing these generators below sea level with no way to protect them from flooding was a recipe for disaster, and that is what occurred," he says. "I was standing on the second floor of a hospital in New Orleans and looking at the generator in the subbasement, so it was under four floors of water."