SSR’s May 2016 Compliance News article entitled CMS Adopts the 2012 Codes provided breaking news along with numerous hyperlinks to assist organizations in assessing the impact of CMS’ adoption of the 2012 codes.

SSR’s June 2016 Compliance News article entitled CMS to survey 2012 codes starting November 1, 2016 passed along a few clarifications issued by CMS subsequent to the original final rule.

As of this writing, CMS and the Accrediting Organizations will start surveying to the 2012 Codes in three weeks. Although some health care organizations still think they do not have to start complying with the new codes and standards until November 1, 2016 when surveying starts, compliance to the new codes was actually required starting on July 5, 2016.  Hospitals should have already built a track record of compliance, complete with documentation proving compliance with the new codes.

Organizations must be aware of both the infrastructure and operational requirements of Life Safety Code® NFPA 101-2012®, the Health Care Facilities Code NFPA 99-2012, and dozens of referenced NFPA standards.

SSR’s September 2015 Compliance News Article “What about the other standards?” listed over a dozen of the numerous other referenced standards that will require modifications in compliance activities, including in many cases changes to existing inspection, testing and maintenance practices.

The short list of referenced NFPA standards with significant operational impact is repeated below. There are additional standards not listed below. Refer to NFPA 101-2012® and NFPA 99-2012 for further information.

NFPA Standard	Major Topic	Under NFPA 101-2000	Under NFPA 101-2012
NFPA 99	Health Care Facilities	1999	2012
NFPA 55	Compressed Gases	1998	2010
NFPA 10	Fire Extinguishers	1998	2010
NFPA 25	Water-Based Fire Protection	1998	2011
NFPA 20	Fire Pumps	2000	2010
NFPA 30	Flammable & Combustible Liquids	Not published	2012
NFPA 17A	Wet Chemical Extinguishing Systems	1998	2009
NFPA 96	Kitchen Hoods	1998	2011
NFPA 45	Laboratory Fire Protection	1996	2011
NFPA 72	Fire Alarm (and Signaling) Systems	1999	2010
NFPA 110	Emergency Power Supply Systems	1999	2010
NFPA 80	Fire Doors and Other Opening Protectives	1999	2010
NFPA 105	Smoke door Assemblies and Other Opening Protectives	1999	2010
NFPA 241	Safeguarding Construction, Alteration, and Demolition Operations	1999	2009

We recommend that organizations review at least the list of referenced standards, obtain those standards, and identify the specific changes that are required within existing processes. Needless to say, staff training and operational changes are warranted where newer requirements have resulted in changes to previous processes.  Both ASHE and NFPA have been offering webinars and publications dealing with many of the changes.  Remember, those new requirements took effect on July 5, 2016.

Questions related to this article may be directed to the author, David Stymiest PE CHFM CHSP FASHE at DStymiest@ssr-inc.com.