K222 is trending as the third highest K-tag cited in Ohio in 2019. The most common citations includes: having more than one action to open a door, lack of proper signage (i.e. push 15 secs door will open), delayed egress not releasing, painted doors of secured dementia units, missing fire label on door/door frame, wedged open doors, and damaged doors.
The egress door locking requirement states that doors in a required means of egress shall not be equipped with a latch or a lock that requires the use of a tool or key from the egress side unless using one of the following special locking arrangements:
Clinical Needs or Security Threat Locking
Where special locking arrangements for the clinical security needs of the patient are used, only one locking device shall be permitted on each door and provisions shall be made for the rapid removal of occupants by: remote control of locks; keying of all locks or keys carried by staff at all times; or other such reliable means available to the staff at all times. 18.2.2.2.5.1, 18.2.2.2.6, 19.2.2.2.5.1, 19.2.2.2.6
Special Needs Locking Arrangements
Where special locking arrangements for the safety needs of the patient are used, all of the Clinical or Security Locking requirements are being met. In addition, the locks must be electrical locks that fail safely so as to release upon loss of power to the device; the building is protected by a supervised automatic sprinkler system and the locked space is protected by a complete smoke detection system (or is constantly monitored at an attended location within the locked space); and both the sprinkler and detection systems are arranged to unlock the doors upon activation. 18.2.2.2.5.2, 19.2.2.2.5.2, TIA 12-4
A Life Safety Code Transition Course from the Centers for Medicare & Medicaid Services (CMS) is available to view on the Integrated Surveyor Training Website. This resource can be used as education for maintenance staff.
Life Safety Code information can be found on the Centers for Medicare & Medicaid Services Life Safety Code webpage and on the Ohio Department of Health webpage.
If you have questions related to life safety code or emergency preparedness, please email Stephanie DeWees, Quality & Regulatory Specialist for Long Term Care at sdewees@leadingageohio.org.