While giving the Center for Medicare & Medicaid Services props for promulgating a new rule to require the sprinklering of long-term care (LTC) facilites that accept federal Medicare & Medicaid funds, one has to wonder at the agency's logic of sunseting requirements for smoke detectors. Sure, sprinklers help suppress fires and keep them from spreading, and installing sprinklers helps save lives. But fire suppression is only one-half of the fire safety equation:
Fire Detection + Fire Suppression = Fire Safety
As good as sprinklers are, it still takes a tremendous amount of heat to trigger their operation, and even "fast-acting" sprinkler heads suffer from thermal lag. By the time sprinklers are activated, a room may be filled with deadly smoke and the fire may have spread to a point that making evacuation of some occupants difficult, if not impossible. Let's face it – smoke/fire alarm detection systems are necessary and detect fires sooner than suppression systems. They also provide early notification, which is important for LTC facility personnel who need extra time to evacuate elderly and infirm residents. Even the National Institute of Occupational Safety and Health (NIOSH) admits that "the elderly, people with preexisting illnesses such as heart or lung conditions, smokers, and children may be more sensitive to the effects of smoke inhalation." Why unnecessarily overexpose residents?
NEMA made these points to CMS in written comments and in a joint presentation with the National Burglar and Fire Alarm Association (NBFAA) and the Automatic Fire Alarm Association (AFAA). The bright lining in CMS' rule is that the agency acknowledged the concerns that were raised and indicated that it "may consider the appropriateness of such a requirement [requiring smoke detection systems] in future rulemaking." Let's hope CMS gets it completely right next time.