The Center for Medicare and Medicaid Services (CMS) recently published a 120-page proposed rule that would mandate a four-hour generator test be performed every 12 months, according to a blog on the Electronic Construction & Maintenance website.
There is no mention of a minimum percentage of nameplate rating, minimum exhaust temperature, or a requirement that all automated transfer switches be transferred during the test, the blog said.
The proposed rule applies to 4,982 hospitals across the country, 15,157 long-term care facilities and 1,322 critical access hospital facilities.
According to the blogger, the cited economic impact is flawed in each case.
"In each case, 72 gal per hr, per facility is used for assumed fuel consumption. This equates to an approximate 960kW generator load per facility. Six man-hours are used for the amount of time it would take to conduct the annual test (supporting clinical and facility staff time not included). The figures used for economic impact, not including the "Information Collection Requirements burden," are underestimated by 45% even using CMS figures
"The proposed rule flies in the face of established National Fire Protection Association 99 and 110 standards for triennial tests, as well as those published by accreditation organizations. The triennial 4-hour test has been tried and proven; plus, there has been no empirical evidence that more frequent tests are necessary," Dan Chisholm Sr. president of MGI Consulting, wrote.
Read the blog.
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