LPAs want fire and earthquake drills but are these required?

According to DSS, the most cited deficiencies in 2015 were lack of or no initial staff training; excessive hot water temperatures; facility not clean, safe and sanitary; no annual medical assessment for dementia residents; improper storage of medications; toxic substances assessable to dementia residents; and no fingerprint clearances on employees.

   However, in 2016 and 2017, facilities are being cited for not conducting fire and earthquake drills every three months. Drills are ONLY required of facilities that have delayed egress doors or locked perimeter fence gates to prevent wandering (see 87705 and 80077.3). Why DSS is citing facilities without such devices is unknown, but we have encountered numerous LPAs insisting this is a requirement.

   In ARFs, Title 22 section 80023 requires all facilities to do drills, but once every SIX months. Under Health and Safety Code 1502.5 and Title 22 section 87100, RCFEs cannot be forced to comply with ARF regulations. RCFEs, under H&S Code 1569.1, are “carved out” from other community care facilities and are licensed as a completely separated entity. No drills unless “secured.”