Q: What are the requirements or standards for a remote power tap (RPT) preventive maintenance procedure?

A: NFPA 99-2012, section 10.3.1 requires the physical integrity of power cords to be confirmed by visual inspection. The Annex section A.10.3.1 specifically says this visual inspection is not required to be a formal inspection or documented, but intended for all users to be observant of the condition of the power cords. Now, each AHJ can interpret this as they see fit, and while I have not seen any AHJ cite an organization for not having a formal, documented visual inspection program on their power cords, I can see where an AHJ could expect such a documented program since the Annex section is not part of the formal code of NFPA 99.

CMS and the accreditation organizations (AOs) require the healthcare facility to comply with the manufacturer’s recommendations regarding preventative maintenance procedures. Therefore, if the manufacturer has a recommendation that says the remote power tap (RPT) must have preventive maintenance activities accomplished at certain frequencies, then that is what you must do. CMS and the AOs could cite you for not following the manufacturer’s recommendations if that is the case. However, there is an exception that is rather difficult to comply with: The CMS Alternate Equipment Management (AEM) program. This AEM program allows you to deviate from the manufacturer’s PM recommendations on certain equipment, provided you comply with all of the conditions CMS has set forth in their AEM program.

The AEM program is not for everyone. It is very time-consuming and the small to medium sized facilities will have difficulty complying with all of the conditions CMS has imposed on the program.