By Brad Keyes / Special to Healthcare Facilities Today

Q: My question is related to NFPA 25 and the frequency for annual testing. Our state authority will issue a citation if the pump is not tested within 365 days from the previous test. The contractor conducting the annual test feel they have 9-15 months to do the test and still meet the annual definition per NFPA. So what is the definition of Annual frequency ?  

A: NFPA 25-2011 does not define what ‘annual’ means, other than the obvious: Once a year. The definition of ‘annual’ is left to each individual authority having jurisdiction (AHJ) to interpret.

CMS defines annual to mean every 12 months, without going beyond 12 months from the last testing activity. Your accreditation organization may have a more liberal definition, such as 12 months from the previous activity, plus or minus 30 days, but CMS does not approve of the concept “plus 30 days”. They do not like anything beyond 12 months from the previous test activity because they believe that is what NFPA says.  

You must go by the most restrictive interpretation, which sounds like your state authority or CMS in this case. That is why you must manage the process and control the date that the contractor comes and tests your equipment. You must tell your contractor what edition they must use to test your equipment, and when they must complete their testing/inspection activities. Remember: They work for you – You tell them when to show up. If they don’t like it, find someone else.

Never trust a contractor for doing the job correctly: Review their reports to confirm they are using the correct standard & edition, and that they are conducting the correct test procedures and using the correct inspection methods. You have to be smarter than the contractor, because you are ultimately the individual responsible to ensure the service was conducted properly… not the contractor.

Use “Requests for Proposals” or RFPs and document in writing everything the contractor is responsible for and required to do at each test/inspection service. Then there are no misunderstandings what is expected of each party.  

Brad Keyes, CHSP, is the owner of KEYES Life Safety Compliance, and his expertise is in the management of the Life Safety Program, including the Environment of Care and Emergency Management programs.