Q: Can clean paper towels/toilet paper be stored in a housekeeping closet with an EVS cart and service sink?
A: It depends on the interpretation of an EVS janitor’s sink closet. If the AHJ says the janitor’s sink closet is a dirty environment because of the sink and mop bucket, then I would say no. But if it is decided the janitor’s sink closet is not a dirty environment, then I would say yes, provided the door to the closet resists the passage of smoke and latches.
You should ask your AHJs what their interpretation is. If they are non-committal, then you can decide for yourself. Do a risk assessment; Is the janitor’s closet a clean environment or a dirty environment? Document your answers and why you believe it is one or the other. Submit your risk assessment to the Safety Committee and the Infection Control committee for their review and approval.
If a surveyor attempts to cite you for having clean supplies in a dirty environment, then show them your risk assessment. They are under no obligation to accept your risk assessment but they may, especially since you demonstrated to the surveyor that you gave this some attention and discussion.
Personally, I would say no, don’t do it. But if you can convince the surveyor that the janitor’s closet is a clean environment (and it may be), then you should be able to store clean supplies in there.
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.
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