Skilled nursing facility providers may not think they work directly with the Florida Fire Prevention Code (FFPC) that often, but the requirements in that code play a part in facility operations everyday. The FFPC is made up of the NFPA 1, Fire Code, and the NFPA 101, Life Safety Code (LSC). Providers will be very familiar with the LSC, and the fact that it makes up half of the FFPC should impart just how frequently providers are working within its requirements. While Agency for Health Care Administration (AHCA) surveyors do reference the FFPC from time to time, providers are more likely to have the local Fire Marshal’s office evaluate their facility for compliance with the FFPC. The Fire Marshal’s office is now enforcing certain requirements from the 8th edition of the FFPC – Chapter 11.10.2 – which says:
“In all new and existing buildings, minimum radio signal strength for emergency services department communications shall be maintained at a level determined by the Authority Having Jurisdiction (AHJ), and based on the existing coverage levels of the public safety communication systems utilized by the jurisdiction, measured at the exterior of the building.”
What does compliance with the FFPC 8th Edition 11.10.2 mean for health care providers?
The answer to that question will vary by jurisdiction, but a detailed answer requires information from several different sources. Local fire department, FCC (Federal Communications Commission) license holder, city and county code requirements, as well as NFPA 1, NFPA 101, and NFPA 1221 code and standard requirements, all come together to give providers the requirements of minimum radio signal strength in new and existing buildings. Navigating those requirements to have testing performed at the facility level has many steps for coming into compliance with 11.10.2, and this article will offer recommendations for taking those steps.
Compliance with the minimum coverage requirements for public safety radio signal strength is essential for the local fire department, police, and emergency medical services (EMS) to execute a well-coordinated, in-building emergency response. Many people have likely experienced a loss of cellular phone service when entering a hospital or nursing home, and this same loss of service also exists with public safety radio coverage. While onsite, facility staff use cellular phones or commercial radios working on commercial frequencies. First responder radios use specially allocated public safety frequencies. The signal strength of these public safety frequencies inside of skilled nursing facilities, and all new and existing facilities in Florida for that matter, is the main focal point of the requirements of FFPC 8th Edition 11.10.2.
To highlight why these requirements are becoming a focus for Fire Marshals in Florida, we need look no further than a recent survey from the International Association of Fire Chiefs. This survey found that 98% of firefighters and 84% of EMS personnel experienced in-building communication problems, and 65% of first responders stated they experienced an in-building communication failure within the past two years.
The communication problems noted in the survey are due to insufficient in-building radio signal strength coverage while first responders were inside a facility, and what 11.10.2 (FFPC 8th Edition) addresses.
If a provider has not been contacted by the local Fire Marshal’s office about this radio signal strength testing requirement, they are encouraged to review their jurisdiction’s testing requirements and begin to research testing vendors. Once a vendor has been selected, the provider should be part of the discussions and coordination of testing between the vendor and the local Fire Marshal’s office. Coordination between the provider, testing vendor, and local AHJ is critical for many reasons, but highlighting the importance of this coordination is the fact that each jurisdiction may maintain a specific list of public safety radio channels that are active for testing on a given day. Accurately determining the correct testing frequencies helps ensure that the resulting public safety radio coverage survey would be acceptable by the local fire department – AHJ, but this is not always done by the testing vendor. A coordinated approach with all parties can help avoid this pitfall, as well as ensure the testing is done in a fully compliant manner.
Even with a code compliant survey, along with the fire department – AHJ’s written determination that your facility meets all first responder radio coverage requirements, it can still take months to receive a certificate of radio coverage. This delay is due to the need for testing result evaluation, possible retesting, and the potential requirement for the certificate to be signed and stamped by a Radio Frequency Professional Engineer (PE).
The timeline for compliance can be even longer, sometimes 6-12 months or more, if the coverage testing results show non-compliant public safety radio signal strength inside the facility. Insufficient public safety radio signal strength will likely require the installation of signal amplification systems.
The importance of this testing, from a first responder standpoint, is clear: ensuring public safety radio communications coverage within Florida’s health care facilities is more than just a code, it is a critical need.
FHCA members with questions or concerns about this process can contact the Association’s life safety consultant, Clinton Slier at Integrity Health Care Systems.