Navigating “Safety” in Long-Term Care Facilities: Separating the Roles of OSHA and the Life Safety Code

Compliance; OSHA; Safety

OSHA’s regulations overlap with many Centers for Medicare and Medicaid Services (CMS) and state requirements in various areas, but perhaps the most common crossover occurs between certain Occupational Safety and Health Administration (OSHA) regulations and the Life Safety Code (LSC). This article will focus on the common area of overlap with Electrical Safety.  

Electrical Safety-Overview: 

  • OSHA: OSHA's electrical safety standards (29 CFR 1910 Subpart S) apply to workplaces, including long term care facilities. OSHA provides guidelines for the safe use of electricity, proper wiring, and equipment standards to protect employees from electrical hazards. 
  • LSC: The LSC also addresses electrical safety within the overall framework of building safety. It includes requirements for wiring, electrical equipment, and in some cases, emergency power systems, to ensure the safety of residents and staff during power outages or other emergencies. 

Electrical Safety - Compare and Contrast: 

Life Safety Code:

The LSC, often referred to as NFPA 101, is a comprehensive set of standards developed by the National Fire Protection Association. While its primary focus is on fire safety, the LSC also addresses other aspects related to the well-being of occupants in buildings, including electrical safety. 

Key Components of LSC for Electrical Safety: 

  1. Wiring Requirements: The LSC outlines specific requirements for electrical wiring in buildings, including nursing homes. Properly installed and maintained wiring is crucial to prevent electrical hazards and ensure a reliable power supply. 
  2. Equipment Standards: The code addresses the standards for electrical equipment within the facility. This includes guidelines for the use and maintenance of electrical devices to minimize the risk of malfunctions or failures that could pose a threat to residents and staff. 
  3. Emergency Power Systems: Reliable emergency power systems are also outlined by the LSC. These systems are designed to supplement functions and systems during power outages, ensuring that critical functions such as lighting, medical equipment, and communication systems remain operational. 

OSHA Compliance:

In parallel with the LSC, OSHA sets and enforces safety and health standards including electrical safety. In the context of nursing homes, staff members are integral to the daily operations and are often exposed to electrical applications that may present a hazard, such as PCREE (Patient Care Related Electrical Equipment.  

Key Components of OSHA's Electrical Safety Standards (29 CFR 1910 Subpart S): 

  1. Electrical Installations: OSHA provides specific standards for electrical installations in the workplace. This includes guidelines for the design and installation of electrical systems to prevent shocks, fires, and other hazards. 
  2. Equipment Guidelines: Similar to the LSC, OSHA addresses the safe use and maintenance of electrical equipment. This involves proper training for staff members in the correct handling of electrical devices to mitigate risks. 
  3. Safe Work Practices: OSHA emphasizes the importance of safe work practices when it comes to electrical tasks. This includes protocols for de-energizing equipment before maintenance, using personal protective equipment, and implementing lockout/tagout procedures. 

Differences and Synergies: 

While both the LSC and OSHA regulations address electrical safety, they do so from different perspectives. The LSC takes a holistic approach, considering the safety of the overall facility, including all occupants. OSHA, on the other hand, is specifically focused on workplace safety and the well-being of employees. 
In LTC, compliance with both sets of regulations is essential to create a comprehensive safety program. The LSC ensures that the facility is designed and maintained with the safety of residents in mind, while OSHA safeguards the well-being of the workforce responsible for delivering care. 
In the intricate landscape of safety regulations, LTC facilities should consider both the Life Safety Code and OSHA regulations when implementing electrical safety systems and policies. By doing so, they create an environment that not only meets the standards for fire safety and overall life safety but also ensures that the electrical systems are designed, installed, and maintained in a manner that minimizes risks for employees. 
For more information on CMS’ Life Safety Code, visit AHCA's Fire and Life Safety website.  For more information on OSHA requirements, visit AHCA/NCAL’s OSHA website.  ​