Inadequately maintained electrical systems are a leading cause of business interruption, poor energy efficiency, and premature equipment breakdown. A well planned and executed electrical preventive maintenance (EPM) program will reduce equipment failures, unplanned down time and unbudgeted expenditures. Unfortunately, many small businesses do not have the technical personnel experienced with EPM programs. This guide serves as an overview describing the basic components of an effective EPM program.

Safety

An EPM program involves working with electrically energized and mechanical equipment. Only personnel properly trained and qualified personnel should work on electrical equipment. All work associated with electrical power systems and equipment should be performed in accordance with applicable federal and local regulation, including OSHA electrical safety regulations and the equipment manufacturer’s instructions.

EPM programs

EPM programs are the scheduled inspection, testing and maintenance of critical electrical components and their support systems. The intent of an EPM program is to identify and address any issues before a failure occurs. For an EPM program to achieve long-term success, it must be well defined, well understood and properly implemented and documented. EPM programs require a financial commitment to spend a little now to prevent a major unexpected cost later.

There are three basic steps to make this happen:

Assess — What is the amount of lost time and product that can be attributed to failures? What in-house technical resources are available? Are one-line drawings of the power system available? Are the critical production components and their support circuits known? What is the age and overall condition of the equipment? These questions should be answered during the assessment stage.

Implement — This step involves both planning and accomplishing the work. The required maintenance activities and frequencies, as well as the procedures and schedules to accomplish the work should be documented. An individual should be assigned to oversee the program. Once these steps are completed, the work should be accomplished according to plan and the results documented.

Sustain — The ongoing execution of the program is critical. The program results should be reviewed and be utilized as an input to continuously improve the program.

Technical components of an EPM program

EPM programs involve maintenance and testing activities to keep electrical apparatus clean, cool, dry and tight. These activities should be scheduled based on the condition of the equipment, historical information concerning the equipment and the manufacturer’s recommendations. If no guidance is available, Hartford Steam Boiler Inspection and Insurance Company (HSB) recommends that electrical preventive maintenance be performed at three-year intervals. More frequent maintenance should occur if conditions warrant.

Keep it clean and dry

Electrical equipment rooms should be:

• Free of excessive dust and dirt
• Used for electrical equipment only and not for general storage
• Accessible only to qualified personnel
• Adequately illuminated
• Free from airborne contaminates
• Free from water or potential sources of water

Electrical equipment should be:

• Free from signs of moisture contamination
• Vacuumed to remove loose dirt or debris
• Maintained according to the manufacturers’ recommendations

Keep it cool

Minimize heat buildup in electrical apparatus and in equipment rooms by:

• Keeping outside surfaces clean
• Maintaining cooling fans or blowers
• Keeping ventilation openings clean and free from obstruction
• Maintaining any filters according to manufacturers’ recommendations
• Inspecting seals and gaskets and repairing or replacing as needed

Keep it tight

Electrical connections should be inspected for:

• Arcing
• Corrosion
• Hot spots using infrared thermography
• Proper tightness and connection torque values

The above suggestions are basic checks and inspections to minimize the most common and frequent problems. However, these checks and inspections do not constitute a comprehensive EPM program. Additional testing and maintenance activities based on a facility’s components and sensitivity to down time are required for a complete EPM program.

See Standard for an Electrical Preventive Maintenance (EPM) Program. Experienced electrical contractors and testing companies should also be consulted when deemed appropriate.

Conclusion

It is important to fully understand and implement an EPM program. An effective EPM program will reduce equipment failures as well as unplanned downtime. The time and effort to establish, implement and maintain an effective program is well worth the effort.

For further reading

Additional information is available by signing in to our Hanover Risk Solutions Partners page under Training Resources — Munich RE/Hartford Steam Boiler.

Copyright ©2017, The Hartford Steam Boiler Inspection and Insurance Company

This material is provided for informational purposes only and does not provide any coverage or guarantee loss prevention. The examples in this material are provided as hypothetical and for illustration purposes only. The Hanover Insurance Company and its affiliates and subsidiaries (“The Hanover”) specifically disclaim any warranty or representation that acceptance of any recommendations contained herein will make any premises, or operation safe or in compliance with any law or regulation. By providing this information to you, The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.

LC FEB 2019 10-416 H
171-0847 (01/19)

Visual Observations	Equipment	Definition	Observations
	Cables and bus	Distributes electrical power throughout a building, connecting various components of an electrical distribution system.	No sharp bends No physical damage No signs of heat No temporary wiring Free of moisture and oil
	Switchgear	Combination of electrical disconnect switches, fuses or circuit breakers used to control, protect and isolate electrical equipment. Switchgear is used both to deenergize equipment to allow work to be done and to clear faults downstream.	Covers in place Labeled Accessible No signs of water Vent openings clear
	Circuit breakers	Controlling power to a circuit as well as providing protection to equipment in that circuit by interrupting fault conditions.	Enclosed Labeled Accessible No physical damage No signs of heat No signs of distress No missing knockouts
	Transformers	Device that transfers electric energy from one alternating current circuit to one or more other circuits, either increasing (stepping up) or reducing (stepping down) the voltage.	Open and accessible No dirt accumulations No physical damage No signs of overheating No leakage (oil filled) Adequately protected

For a more detailed description on electrical maintenance and testing, consult Standard for an Electrical Preventive Maintenance (EPM) program.
 

This material is provided for informational purposes only and does not provide any coverage or guarantee loss prevention. The examples in this material are provided as hypothetical and for illustration purposes only. The Hanover Insurance Company and its affiliates and subsidiaries (“The Hanover”) specifically disclaim any warranty or representation that acceptance of any recommendations contained herein will make any premises, or operation safe or in compliance with any law or regulation. By providing this information to you, The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.

LC MAR 2019 13-349
171-1084 (3/14)

Any playground represents an opportunity for children to have fun, but also for injury. To adequately help reduce the risk of injury, it is imperative that staff in charge of playgrounds understand how to assess the hazards correctly and effectively reduce the potential for accidents.

Playground inspections should be carried out at least monthly, by someone trained to perform the inspections. During higher use periods (fall and spring), it is recommended that inspections be performed on a daily basis.

Using the checklist below for routine inspections on a regular basis as outlined above can aid staff in properly assessing risk and help reduce the risk of injury on the playground.

Any listed items judged inadequate should be addressed immediately.

Surfacing

• Adequate protective surfacing under and around the equipment
  • Install replace surfacing
• Surfacing materials have not deteriorated
  • Replace surfacing
  • Other maintenance
• Loose fill surfacing materials have no foreign objects or debris
  • Remove trash and debris
• Loose fill surfacing materials are not compacted
  • Rake and fluff surfacing
• Loose fill surfacing materials have not been displaced under heavy use areas such as under swings or at slide exits
  • Rake and fluff surfacing

Drainage

• The entire play area has satisfactory drainage especially in heavy use areas such as under swings and at slide exits
  • Improve drainage
  • Other maintenance

General hazards

• There are no sharp points corners or edges on the equipment
• There are no missing or damaged protective caps or plugs
• There are no hazardous protrusions
• There are no potential clothing entanglement hazards such as open S hooks or protruding bolts
• There are no crush and shearing points on exposed moving parts
• There are no trip hazards such as exposed footings or anchoring devices and rocks, roots or any other obstacles in a use zone

Security of hardware

• There are no loose fastening devices or worn connections
  • Replace fasteners
  • Other maintenance
• Moving parts such as swing hangers, merry-go-round bearings and track rides are not worn
  • Replace fasteners
  • Other maintenance

Durability of equipment

• There are no loose fastening devices or worn connections
• There are no rust, rot, cracks or splinters on any equipment; check carefully where it comes in contact with the ground
• There are no broken or missing components on the equipment, e.g., handrails, guardrails, protective barriers, steps, or rungs
• There are no damaged fences benches or signs on the playground
• All equipment is securely anchored

Leaded paint*

• Paint, especially lead paint, is not peeling, cracking, chipping or chalking
• There are no areas of visible leaded paint chips or accumulation of lead dust
  • Mitigate lead paint hazards

General upkeep of playgrounds

• There are no user modifications to the equipment such as strings and ropes tied to equipment swings looped over top rails, etc.
  • Remove string or rope
  • Correct other modification
• The entire playground is free from debris or litter such as tree branches, soda cans, bottles, glass, etc.
  • Clean playground
• There are no missing trash receptacles
  • Replace trash receptacle
• Trash receptacles are not full
  • Empty trash

The checklist above is adapted from the U.S. Consumer Product Safety Commission’s Public Playground Safety Handbook.

Visit the US Consumer Product Safety Commision's website for more information on leaded paint.
 

This material is provided for informational purposes only and does not provide any coverage or guarantee loss prevention. The examples in this material are provided as hypothetical and for illustration purposes only. The Hanover Insurance Company and its affiliates and subsidiaries (“The Hanover”) specifically disclaim any warranty or representation that acceptance of any recommendations contained herein will make any premises, or operation safe or in compliance with any law or regulation. By providing this information to you, The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.

171-0970 (01/14)

A sad, but all-too-common item in today’s news media deals with athletes and their exposure to excessive summer temperatures. Minnesota Vikings player Korey Stringer, who died of heat stroke in 2001, brought the topic to national prominence, and a number of other serious heat-related incidents since then have reminded us that this is a topic deserving of the attention of parents, coaches and team administrators. In the summer months of 2011, as much of the country has seen record-breaking periods of extreme temperatures, at least three heat-related deaths on practice fields have been reported, as high school football season approached. These included two high-school football players from Georgia and a coach in Texas, who have died amid sweltering temperatures.

The injury or death of an athlete will almost inevitably raise questions about the team’s program, which may result in a lawsuit against the team, the coaches, administrators and others. The nature of such a lawsuit will likely find its genesis in a claim of negligence against the defendants. Allowing for various jurisdictional differences, a successful claim for negligence will require the plaintiff to prove that the defendant(s) had a duty to the athlete, the defendant(s) breached that duty, the breach of the duty caused the injury (or death) to the athlete, and the plaintiff has suffered damages.

Simply stated, coaches and other individuals responsible for supervising athletes practicing or playing in extreme heat and/or humidity conditions need to observe caution, to avoid the risk of heat-related illnesses. This Topics sheet is intended to provide some general guidelines for teams to follow, to reduce their risk to the exposure of a heat-related incident.

1. Every team should develop or adopt some form of policy for dealing with the hot weather. This should include training for coaches, athletic trainers, and other staff. Training should include recognition of signs of distress and heat illness, and appropriate response techniques. Coaches and trainers should know the difference between the signs of heat exhaustion (symptoms which include heavy sweating, muscle cramps and spasms, headache, nausea, dizziness, and moist, pale skin that feels cool) and heat stroke (symptoms which include appearing flushed with dry, hot skin).
2. A means of measuring temperature and humidity levels should exist at the practice sites, along with established responses to thresholds when reached. For example, one state’s athletic association advises coaches and marching band directors to take precautions when the heat index tops 95, and to cut off activities when that measure hits 105, rescheduling the practice for a later day or later in the day. Another option may be to hold the practice at night, under lights, if the team can afford it. The WBGT (Wet Bulb Globe Temperature) Index is the most widely accepted measure of environmental conditions and is used as a monitoring guideline for activities in both athletics and industry. (More on this can be found at this Journal of Athletic Training’s article.)
3. Provide participants with frequent water breaks, and a trip to the scales at the beginning and end of each practice session. Some suggest that if a player’s weight drops 3 percent or more, it’s considered a sign of dehydration; losses of 5 percent could be seen as an indicator of heat-related illness.* Athletes should hydrate at least two days before games by drinking at least eight glasses of water a day for two days. While plain water is sufficient to replace fluids, athletes might drink more if the fluids are flavored and contain electrolytes and glucose.
4. Have an athletic trainer on the field at all times. That is, a person trained in sports medicine who not only can recognize the signs of heat-related issues but also treat them.
5. Be prepared for a heat stroke emergency, with body-cooling arrangements. If a heat illness is suspected, the athlete should be immediately removed from the hot environment, to a shady or air-conditioned area. Cold drinks should be provided, tight clothing loosened, and the person should be cooled by spraying or sponging with cool water.** An athlete who is immediately cooled can survive, but many coaches just call 911. It could be that while they wait for an ambulance the brain and vital organs continue to cook in the heat, while the body can only withstand such extreme conditions for about 30 minutes.
6. Give athletes’ bodies time to adjust, or acclimatize, to the environment and heat stresses. To decrease the number of heat related illnesses, the National Collegiate Athletic Association recently instituted a mandatory 5-day acclimatization period. The athletic practices’ intensity and duration should increase gradually, based on the time needed to acclimatize. (Most heat-related injuries to football players occur during the first three weeks of practice.) View The National Athletic Trainers’ Association detailed preseason heat-acclimatization guidelines for youth sports.

Athletics can be one of the most enriching components of a person’s life. With the right cautionary practices, teams can provide this service, without compromising safety, and while minimizing the risk of a heat-related injury. We encourage you to incorporate the items above into your Safety & Loss Control program. If you would like a visit from your Hanover Insurance Group Loss Control Consultant, to address this or any other Safety or Health issue, please contact your insurance agent.

Source:
* University Interscholastic League
** Mayo Clinic 

This material is provided for informational purposes only and does not provide any coverage or guarantee loss prevention. The examples in this material are provided as hypothetical and for illustration purposes only. The Hanover Insurance Company and its affiliates and subsidiaries (“The Hanover”) specifically disclaim any warranty or representation that acceptance of any recommendations contained herein will make any premises, or operation safe or in compliance with any law or regulation. By providing this information to you, The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.

LC JAN 2019 11-263
171-0903 (7/17)

Bleachers are a common feature for schools, especially those having competitive sports programs. While they come in many sizes and configurations, they typically fit into one of four categories according to the Consumer Product Safety Commission (CPSC): permanent/stationary, portable/movable, telescopic/folding, and temporary. Each year, thousands of bleacher-related incidents lead to emergency room visits and, sadly, sometimes result in fatalities. Many of these incidents involve falls from bleachers onto a surface below.

The following guidelines are based on CPSC recommendations developed after a comprehensive review in response to multiple fatalities and serious injuries involving children using bleachers. In addition to these recommendations, it would be prudent to consult with experts in local building codes as well as to inspect the bleachers to ensure they meet safety guidelines and are maintained in good condition

Chief among safety concerns involving bleachers is falling off bleachers and falling through openings in them.

Steps to help prevent falls from bleachers can include:

• Provide guardrails where the height of the bleachers’ footboard, seat board, or aisle is 30 inches or more above the floor or ground.
• Guardrails should be at least 42 inches above the leading edge of the adjacent footboard, seat board, or aisle.
• Guardrails should prevent the passage of a 4-inch sphere, which represents the approximate size of a baby’s head.
• Favor picket fence (vertical) guardrail designs as they discourage children from climbing over them.
• If in-fill guardrail members allow footholds, limit maximum openings to 1.75 inches.
• If the bleachers are against a wall as high as the guardrail height recommended, a guardrail is not needed if space between the bleachers and wall will not allow passage of a 4-inch sphere.

Steps to help prevent falls through bleachers:

• The 4-inch sphere concept also applies to risers protecting the space above footboards and below seat boards, where the footboard is 30 inches or greater above the ground or floor.
• According to the CPSC, rigid materials should be used to close openings between seating components, rather than chain link or other fencing material.

Bleacher inspection, maintenance, and additional considerations:

• Per the CPSC, bleachers should be inspected at least quarterly and any problems noted should be remedied immediately.
• A qualified person or firm should inspect bleachers every two years at minimum and provide a written “fit for use” certification at that time.
• Records of inspections and any maintenance should be maintained.
• If the structure is undergoing a retrofit, consider adding non-skid surfaces, handrails, aisles, and other features that may assist in accessibility and egress.

Material on this page derived from the U.S. CPSC’s Guidelines for Retrofitting Bleachers which can be found at https://www.cpsc.gov/s3fs-public/330.pdf for more information.

This material is provided for informational purposes only and does not provide any coverage or guarantee loss prevention. The examples in this material are provided as hypothetical and for illustration purposes only. The Hanover Insurance Company and its affiliates and subsidiaries (“The Hanover”) specifically disclaim any warranty or representation that acceptance of any recommendations contained herein will make any premises, or operation safe or in compliance with any law or regulation. By providing this information to you. The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.

171-1007 (12/21)   LC 2021-494

Fifteen-passenger vans are more likely to be involved in single-vehicle rollover crashes than any other type of vehicle. In response, the National Highway Traffic Safety Administration (NHTSA) has issued numerous safety advisories on these vehicles.

The good news is that such consumer alerts and educational efforts are apparently working to help reduce fatalities. Statistics show the number of deaths in 15-passenger van rollover crashes has been declining steadily since 2001. Still, these vehicles pose a safety risk to occupants, claiming the lives of 58 people in accidents in 2006.

Still, more can be done to alert operators about the vehicles’ high center of gravity — particularly when fully loaded — and ways to reduce chances of rollover. NHTSA continues to get the word out about this increased rollover risk, as well as what can be done to mitigate it.

Electronic stability control

Electronic Stability Control (ESC) is an on-board crash avoidance system designed to help the driver stay in control during an emergency maneuver like sudden swerving or braking. Results from a limited NHTSA study indicate that ESC installed in 15-passenger vans may have important safety benefits in some, but not all, on-road driving situations. As a result, ESC is a standard feature in all 15-passenger vans purchased after 2006. However, organizations that use 15-passenger vans to transport students, seniors, sports groups or other members, should still be aware of how to reduce rollover risks, avoid potential dangers, and better protect occupants in the event of a rollover crash.

Fleet safety program

A fleet safety program is recommended to facilitate the training of all drivers who operate 15-passenger vans. Take a proactive approach. At a minimum your program should include topics such as:

• Company safe driving policy
  • Use of electronic devices
  • Alcohol and drug policy
  • Seatbelts
• Driver qualification and record checks
• Driver training
  • Including the dangers of 15-passenger vans
• Tracking and rewarding safe driving behavior
• Written driver agreements
• Accident reporting
• Vehicle inspection and maintenance

All aspects of your fleet safety program should be reviewed on an annual basis and updated as needed.

Please contact your Hanover Risk Solutions Consultant for assistance with your fleet safety program.

Related links

• For free copies of 15-passenger van safety hangtags, as well as the latest NHTSA research and analysis, please visit their website. You may also contact NHTSA’s Vehicle Safety Hotline at 888-327-4236.

This material is provided for informational purposes only and does not provide any coverage or guarantee loss prevention. The examples in this material are provided as hypothetical and for illustration purposes only. The Hanover Insurance Company and its affiliates and subsidiaries (“The Hanover”) specifically disclaim any warranty or representation that acceptance of any recommendations contained herein will make any premises, or operation safe or in compliance with any law or regulation. By providing this information to you, The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.

LC JAN 2019 10-377 H
171-0893 (1/14)

The safety of elderly and special needs individuals while passengers on buses and vans has become a concern. A number of serious accidents have occurred to these individuals while passengers on, as well as while walking to or from, transportation vehicles. Whether you use 15-passenger vans or other types of vehicles, please follow these guidelines designed to help increase the safety of those being transported.

• Ensure that wheelchairs are fastened to the floor with wheelchair brakes locked and passengers strapped into their chairs.
• Check equipment for defects or other maintenance concerns. This includes the wheelchair lift, straps and tracks. Perform these checks pre and post trip.
• When passengers are loading or unloading (whether in wheelchairs or not) always choose a path that is flat, clear of debris and easily accessible. Ensure that the lift is on flat ground to help prevent wheelchairs from tipping.
• Before raising or lowering the wheelchair lift make sure brakes are locked and the gate is secure.
• Ensure that an appropriate number of staff is available to assist before, during and after transport.
• A cell phone or other means of communication should be in the vehicle in case of an emergency.
• Check tire pressure at least once a week. This is extremely important because proper tire pressure lessens the chance of a rollover accident, especially for 15-passenger vans.
• Require all occupants to wear seatbelts.
• If using a 15-passenger van, ensure that passengers as well as cargo are forward of the rear axle, to help reduce the chance of a rollover accident.
• Keep speeds under 50 miles per hour. Always observe posted limits. Be mindful of road conditions. Reduce vehicle speed during bad weather or when traveling on roads that are unfamiliar or hard to navigate.
• Only qualified drivers should be behind the wheel. Special training and experience are required to operate 15-passenger vans so ensure your drivers have both.

Fleet safety program

A fleet safety program is recommended to facilitate the training of drivers who may operate passenger transportation vehicles, including 15-passenger vans. Take a proactive approach to safe driving. Include the following in your fleet safety program:

• Organization’s safe driving policy
  • Cell phone use
  • Alcohol policy
  • Seatbelts
• Driver qualification and record checks
• Driver training
  • Include education on the dangers of 15-passenger vans
• Tracking and rewarding safe driving behavior
• Written driver agreements
• Accident reporting
• Vehicle inspection and maintenance programs (including all wheelchair tie-down apparatuses.) All aspects of your fleet safety program should be reviewed annually and updated as needed. Please contact your Hanover Risk Solutions Consultant for assistance.

Copyright ©2014

This material is provided for informational purposes only and does not provide any coverage or guarantee loss prevention. The examples in this material are provided as hypothetical and for illustration purposes only. The Hanover Insurance Company and its affiliates and subsidiaries (“The Hanover”) specifically disclaim any warranty or representation that acceptance of any recommendations contained herein will make any premises, or operation safe or in compliance with any law or regulation. By providing this information to you. The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.

LC JAN 2019 08-291
171-0946 (2/14)

Life safety systems are building components and systems that help protect building occupants during fires and other emergencies. In order to provide the level of protection they were designed for, these systems need to be inspected, tested and maintained on a regular basis.

This document summarizes some of the important recommendations of the National Fire Protection Association (NFPA). The primary NFPA code addressing life safety is NFPA Code 101, also known as the Life Safety Code®. NFPA 101 refers to several other NFPA codes for further details. The maintenance recommendations summarized here are not all-inclusive, but address some of the issues commonly encountered by The Hanover Loss Control Consultants.

Additional details and any further requirements should always be obtained from the manufacturer of your specific equipment and your local fire official.

In general, the term “inspection” refers to visual checks of the system, “testing” refers to functional or operational tests and “maintenance” refers to repair or replacement of components. Inspection, testing and maintenance is often abbreviated as ITM.

Fire alarm systems

Fire alarm systems are composed of the following components: initiating devices such as smoke detectors and manual pullboxes, occupant notification appliances such as horns and strobe lights, an annunciator panel, batteries for backup power, and a control unit that ties everything together. Some fire alarm systems interface with other building systems, for instance being initiated by sprinkler waterflow or causing fire doors to close or elevators to return to the ground floor. Most fire alarm systems also have a connection to an offsite central monitoring station or fire department. Each of these individual components must be inspected, tested and maintained. ITM requirements for fire alarm systems can be found in NFPA Code 72.

Due to the complexity of fire alarm systems, they should receive ITM at least annually by a qualified contractor. An extensive list of items to be checked and forms for documentation are found in NFPA Code 72. You should confirm that your fire alarm contractor is following this code, as well as the recommendations of your alarm system manufacturer.

There are several items that must be checked more often than annually. Some building owners will have their alarm contractor make these additional checks, and others will have their maintenance staff perform them (with proper training). Due to the number of items to be checked semiannually, many building owners contract for semiannual outside inspections. The following are examples of the additional inspections outlined by NFPA Code 72:

Daily

• Confirm integrity of central station alarm connection if provided (this is often done automatically)

Weekly

• Inspect alarm control equipment (if alarm, supervisory and trouble signals are not monitored offsite)

Monthly

• Inspect traditional (flooded) lead-acid and dry cell backup batteries
• Test any engine-driven generators used as a backup power supply

Quarterly

• Verify no obstruction of any “line of sight” detectors such as flame detectors

• Check any supervisory signal devices and waterflow devices used for initiation of the fire alarm system (such as sprinkler valve tamper and sprinkler waterflow devices)

Semiannually

• Check for trouble signals on alarm panel, even if these are monitored offsite
• Verify condition of annunciator panel
• Inspect all other initiating devices (other than “line of sight” detectors, supervisory signal devices and waterflow devices as noted above)
• Inspect all notification appliances
• Check transient suppressors on power supply, e.g. voltage surge suppressors
• Perform load voltage test of backup batteries (all battery types)
• Inspect sealed lead-acid and nickel-cadmium backup batteries
• Test specific gravity of traditional (flooded) lead-acid backup batteries
• Check any equipment interfaced with the alarm system such as elevator recall and guard tour “clock” systems
• Confirm condition of in-building fire emergency voice/alarm communications and mass notification systems if provided (“mass notification” systems are similar to fire emergency systems but can also be initiated by other types of emergencies)
• Test any flame detectors, spark/ember detectors or waterflow devices used for initiation of the fire alarm system (this is an operational test as opposed to the visual inspections noted above)

Smoke alarms and carbon monoxide alarms

Smoke alarms and carbon monoxide alarms are different from the fire alarm systems described above, in that they contain detection and warning devices together in the same piece of equipment. Smoke alarms and carbon monoxide alarms are self-contained units, while smoke detectors and carbon monoxide detectors are initiating devices in a fire alarm system and cannot operate independently. Smoke alarms and carbon monoxide alarms are commonly found in one- and two-family dwellings and within the living units of apartment buildings.

The ITM requirements for smoke alarms are found in NFPA Code 72, and those for carbon monoxide alarms are found in NFPA Code 720. Both of these codes require the annual testing of alarm units according to the manufacturer’s recommended procedure. This procedure generally involves pressing a “test” button on the alarm unit, but could also require use of a specialized “test smoke” or carbon monoxide sprayed from an aerosol can. These annual tests should be performed by qualified personnel, not by residential tenants. Some manufacturers also recommend an additional periodic test of the sensitivity of smoke alarms.

Most manufacturers also recommend more frequent, less comprehensive testing of smoke alarms and carbon monoxide alarms, which can generally be performed by residential tenants. Building owners should provide tenants with written instructions on the frequency and method of performing these tests. These are generally accomplished by pressing a “test” button on the alarm unit, on a monthly or weekly basis as recommended by the manufacturer.

Smoke alarms, and combination smoke/carbon monoxide alarms, should be replaced when they no longer pass the tests noted above or 10 years from their date of manufacture, whichever is sooner. Carbon monoxide alarms should be replaced when they no longer pass the tests noted above or when they reach the date recommended by the manufacturer, whichever is sooner. It is generally recommended that battery powered smoke alarms and carbon monoxide alarms be replaced by hard wired units with a battery backup. Another option may be to install a fire alarm system that uses battery operated low-power radio (wireless) detectors. This type of detector transmits a radio signal to the central control unit when its battery is running low.

If it is not immediately feasible to replace battery powered smoke alarms or carbon monoxide alarms, the monthly tests noted above should be performed by the building owner and be documented, rather than being performed by the tenant. Batteries should be replaced semiannually or as recommended by the alarm manufacturer.

Emergency lighting

ITM requirements for emergency lighting equipment are found in NFPA Code 101. Each emergency lighting fixture is required to be operationally tested for at least 30 seconds, at least once every 30 days. During this test, it should be verified that the bulbs are operational and properly aimed. In addition, it is suggested that each battery operated fixture be tested for 1 ½ hours at least once per year. Self-testing/self-diagnostic emergency lighting equipment is available for automation of these tests.

Batteries used to power emergency lighting fixtures should receive ITM per the manufacturer’s instructions. If a central battery system is used, rather than individual battery packs on the fixtures, a weekly ITM schedule should be established as detailed in NFPA Code 111.

For emergency lighting that is powered by a generator, the annual 1 ½ hour test noted above is replaced by more extensive operational testing outlined in NFPA Code 110. Some of the ITM requirements in NFPA 110 include:

Weekly

• Inspection and scheduled maintenance of generator per manufacturer’s instructions
• Inspection of generator starter battery

Monthly

• Specific gravity test for traditional (flooded) lead-acid starter batteries
• Exercising of generator under load, with the duration and loading dependent on various conditions outlined in NFPA 110
• Operation of transfer switch

Quarterly

• ITM of transfer switch as detailed in NFPA 110
• Load test of generator starter battery

Semiannual

• Exercising of circuit breakers

Annual

• Fuel quality test of generator fuel
• Thermographic inspection of transfer switch

Biennial

• Simulated overload of circuit breakers

Lighted exit signs

Exit signs must be illuminated per the specifications in NFPA Code 101. Various options are available:

• Illumination by the regular building lighting (this may be the only source of illumination if the building is not required to have emergency lighting)
• External illumination by emergency lighting fixtures
• Internal illumination by emergency lighting fixtures built into the signs
• Self-luminous signs, powered by a low-level nuclear radiation source
• Photoluminescent signs, which absorb and re-radiate light from the regular building fixtures

All of the above types of exit signs have some common ITM requirements: they must be physically present, clearly visible, indicating the correct direction of travel, and adequately lighted under non-emergency conditions. Exit signs can often become damaged over time, removable sections can fall out and therefore indicate an incorrect direction of travel, and signs can become blocked. Regular (non-emergency) lights near the signs can also burn out or be accidentally turned off. All types of signs require adequate illumination levels during non-emergency situations. For photoluminescent signs this is especially important, since they will not “glow” with adequate brightness if they do not receive sufficient light during non-emergency periods.

All of the above items should be inspected on a regular basis, for instance as part of a daily pre-opening inspection of the building. Even if the building is continuously occupied rather than being opened and closed each day, periodic self-inspections should be performed at least monthly. For signs that are internally or externally illuminated by emergency lighting fixtures, the ITM program must also include the emergency lights as outlined in the previous section.

Door self-closing hardware

Doors in fire walls and smoke barriers are required to be self-closing, and if they are the latching type, self-latching as well. Self-closing hardware and latches can easily get out of adjustment or break, and doors are often propped open by building occupants. Therefore, it is important to include fire and smoke doors in your ITM program.

Fire and smoke doors should be tested for proper operation at least annually, or more often depending on their level of use and abuse. For instance, doors that are often propped open by building occupants may need to be inspected daily. Ongoing problems with propped doors may need to be addressed by adding magnetic hold-open devices that are released by smoke detectors.

ITM requirements for fire and smoke doors can be found in NFPA Code 101, NFPA 80 (fire doors) and NFPA 105 (smoke doors).

This material is provided for informational purposes only and does not provide any coverage or guarantee loss prevention. The examples in this material are provided as hypothetical and for illustration purposes only. The Hanover Insurance Company and its affiliates and subsidiaries (“The Hanover”) specifically disclaim any warranty or representation that acceptance of any recommendations contained herein will make any premises, or operation safe or in compliance with any law or regulation. By providing this information to you. The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.

LC JAN 2019 13-04
171-1026 (3/14)

Article provided courtesy of Jackson Lewis

Charges and lawsuits brought under the Americans with Disabilities Act (ADA) are on the rise. In the last fiscal year, the Equal Employment Opportunity Commission (EEOC) received nearly 26,000 charges of disability discrimination, more than double the number of charges received by the EEOC five years ago. Those charges resulted in more than $100 million in payouts to complainants, excluding those complainants who took their case to court.  In court, verdicts against employers in disability discrimination lawsuits have grown to unprecedented levels. On May 1, 2013, as the result of a charge of disability discrimination filed with the EEOC by 32 men with intellectual disabilities against their employer, an Iowa jury awarded the agency $240 million – the largest verdict in agency history.

As such, employers should be aware of some of the most common liability concerns in this area and proactively work to avoid exposure. Below we address two common areas of exposure for employers: the use of fixed term leave policies and the failure to recognize the expanded definition of “disability” under the ADA following the ADA Amendments Act of (ADAAA).

The detriments of “fixed leave” policies

The EEOC repeatedly has gone after employers for inflexible leave policies that do not permit leave beyond Family and Medical Leave Act (FMLA) leave or fixed leave policies, such as a policy providing that no employee shall have leave for more than 12 consecutive months. Such strict policies run afoul of the ADA because, under the ADA, employers must be willing to provide an exception to a fixed leave policy as a reasonable accommodation. The following are some recommended compliance strategies for leave administration:

• Employers should follow a three-step analysis for every leave request, starting with asking what the employee is entitled to by the FMLA and under state leave laws, then asking what is the employee entitled to under company policy, and finally what reasonable accommodation the employer has to provide the employee.

• Employers should ensure that written policies communicate a willingness to consider additional leave as an accommodation under the ADA.

• Employers must not forget about ADA employees on leave; they should develop documentation to show that they considered return-to-work options along the way.

• Employers can leverage paid leave and benefit programs, such as enhancing rules for employee notice requirements, minimum increments of leave, medical examination rules and communications during leave.

These strategies can reduce employers’ potential exposure significantly to the growing incidence of disability discrimination claims. Indeed, from 2008 to 2011, the number of ADA claims filed by the EEOC has more than doubled (from 37 to 80). With the EEOC’s increased focus on disability discrimination, employers should redouble their efforts to comply with the ADA.

The expanded definition of “disability” under the ADA following the ADAAA

Just over two years ago, the EEOC released its long-awaited Final Regulations implementing the ADAAA. The Final Regulations reaffirmed the purpose of the ADAAA: to make it easier for individuals with disabilities to obtain the ADA’s protection. The ADAAA made clear that the primary focus in ADA cases should be on whether employers complied with their obligations under the statute and whether discrimination occurred, not whether individuals are disabled under the law. As such, the Final Regulations greatly expanded the definition of “disability” under the ADA.

Under the ADA, a “disability” is defined as: a physical or mental impairment that substantially limits one or more major life activities of such individual, a record of such an impairment, or being regarded as having such an impairment. 42 U.S.C. § 12102(1). The ADAAA provided several “rules of construction” with respect to this definition, a selection of which are highlighted below:

• The term “substantially limits” is to be construed broadly in favor of expansive coverage, to the maximum extent permitted by the terms of the ADA.   
• Whether an impairment “substantially limits” a major life activity should not demand extensive analysis.
• Except in the cases of ordinary eyeglasses or contact lenses, the determination of whether an impairment substantially limits a major life activity is to be made without regard to the ameliorative (beneficial) effects of mitigating measures.
• An impairment that is episodic or in remission is a disability if it would substantially limit a major life activity when active.
• An impairment that substantially limits one major life activity need not substantially limit other major life activities in order to be considered a substantially limiting impairment.

While careful to state that an individualized assessment is always required, the Final Regulations allow that some impairments involve “predictable assessments” which, in “virtually all cases,” will result in a finding that they are covered by the ADA. According to the ADAAA, impairments that should lead to “predictable assessments” include deafness, blindness, intellectual disabilities, partially or completely missing limbs or mobility impairments requiring the use of a wheelchair, autism, cancer, cerebral palsy, diabetes, epilepsy, HIV infection, multiple sclerosis, muscular dystrophy, major depressive disorder, bipolar disorder, post-traumatic stress disorder, obsessive compulsive disorder, and schizophrenia.

The most far-reaching provisions of the Final Regulations arguably can be found in the provision on coverage when one is “regarded as” having a substantially limiting impairment. The Final Regulations clarify that an individual is “regarded as having such an impairment” if the individual is subjected to a prohibited action because of an actual or perceived physical or mental impairment, whether or not that impairment substantially limits, or is perceived to substantially limit, a major life activity.

From a day-to-day management perspective, the Final Regulations means that many more individuals will be entitled to reasonable accommodations. Carriers should expect that ADA cases will proceed to a point where employers must defend decisions by showing individuals were not “qualified” because they could not safely or successfully perform essential job functions, with or without reasonable accommodations, or that the employers offered or attempted unsuccessfully to offer reasonable accommodations. Every adverse employment decision that is based on an individual’s inability to perform due to an injury or illness has the potential to lead to a contested ADA case. 

The recommendation(s) and contents of this material are provided for informational purposes only. This material does not purport to address every possible legal obligation, hazard, code violation, loss potential or exception to good practice. It should not be construed as indicating the existence or availability of any insurance coverage. Hanover Insurance Companies and their affiliates and subsidiaries specifically disclaim any warranty or representation that compliance with any advice contained herein will make any premises, property or operation safe or in compliance with any law or regulation. The Hanover Insurance Group with Eagle Icon is a trademark of The Hanover Insurance Group, Inc.

Hail damages equipment and your business

Hail storms can damage your roof top equipment and skylights. This damage can cause loss of heating and cooling, water damage and loss of use of the facility.

HVAC systems are very vulnerable to hail damage; hail impact on the fins of the coil assemblies causes the fins to become compressed. When the fins are compressed, the heat transfer function of the HVAC unit is diminished and the system does not function properly. In addition to the physical damage to the equipment, you will have interruptions to the heating and cooling of the building. If you have processes that require cooling, then ongoing operations may be compromised.

Be aware that hail damage can have a cumulative effect on your system. Repeated damage may result in replacement of the unit. The downtime needed to make changes or repairs to the roof, ductwork and controls may make replacement a significant project. Protection of your systems may be the best risk management choice.

Hail guards

Hail guards offer some protection for your HVAC systems. These guards provide a degree of protection from hail and other flying debris, though the size and velocity of hail can impact the performance of any hail guard. Most systems are designed around hail stones sized at 1 ½” in diameter or less.

If your local area has experienced larger hailstones, you should discuss with the designer of the hail protection system. They may change the materials, mounting and frame systems to compensate for heavier hail stones and higher impact forces.

The best solution is to purchase HVAC equipment with factory installed hail guards. These hail guards are engineered to provide the correct airflow through the system and to maintain the operating efficiency of the unit. They can be color matched to the factory finish for seamless appearance.

Frequently, this option is not specified for the HVAC units. What can you do now? The first alternative is to contact the original equipment manufacturer and see if they can supply hail guards. This helps ensure that the guards are properly engineered and will not compromise system performance.

The second alternative is to find a third party provider who can manufacture a protective system for your units. We recommend you consider the following points when making this choice.

• A simple panel of expanded metal over the coils seems like an easy choice to protect the coils. But what is the impact on airflow through the unit? Changing the airflow through the coils can change the efficiency and capacity of the system. You should consult with the manufacturer’s representative or a system designer to be sure the changes you are making will not impair system operations.
• Adding a system of louvers around the coils may be a solution. These can be engineered to maintain proper airflow and still deflect the hail from the coils. Proper mounting with the ability to remove the guard to service the unit are considerations.
• Systems that combine filtration and hail protection are also available. These systems use a tightly stretched filter media over a rigid frame. The frame is offset from the coils to allow the hail to bounce off of the filter surface. This system would keep the coils cleaner and improve system performance. The addition of the filter media means that routine cleaning is more important, but the external filter can be easily cleaned and the need to pressure wash coils is reduced.
• Consider the attachment of the system. Attaching a heavy guard to lightweight sheet metal may not provide the rigidity you require. How easy are the guards to remove for coil cleaning and system maintenance?
• If you need to build a framework to hold the hail guards, how will that frame be attached for wind resistance? Attaching to the building roof surface will require coordination with a roofer to maintain a waterproof surface.

Costs for hail guards are difficult to estimate. Factory supplied items vary widely by manufacturer and the age of the equipment may impact availability. Retrofitted materials are custom fabricated and require installation by either the supplier or your staff. The fabrication costs versus installation costs can vary by locality and the degree to which the units are accessible.

Our research indicated that retrofit systems may be in the range of $25-$30 dollar per square foot; a unit with two six foot square fan coil surfaces could cost over $2,000. The cost factors for the louver system and the filter based system are comparable. Estimating costs is difficult due to labor and material fluctuations.

Skylights

Skylights are another exposure to consider. The impact resistance of the glazing material in a skylight may not be equal to the impact energy of large hail stones. Adding a protective cover over the skylight may be the solution. Polycarbonate and acrylic materials may offer good impact resistance, but may not offer the best UV stability or scratch resistance. You need to balance the need for optical clarity with impact resistance. The costs for this protection will vary based on materials used, mounting method and accessibility of the skylight for installation. Costs may start at $25 a square foot for these covers.

Window films may offer some resistance to hail. They may not keep the glass from breaking, but the film can hold the glass in place. These films can be clear, tinted and may offer some UV filtering.

This material is provided for informational purposes only and does not provide any coverage or guarantee loss prevention. The examples in this material are provided as hypothetical and for illustration purposes only. The Hanover Insurance Company and its affiliates and subsidiaries (“The Hanover”) specifically disclaim any warranty or representation that acceptance of any recommendations contained herein will make any premises, or operation safe or in compliance with any law or regulation. By providing this information to you. The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.

LC JAN 2019 12-148
171-0859 (01/14)