December 29, 1989

Mr. Thomas J. Frericks, Jr.
President/General Manager
Copp Systems, Inc.
123 South Keowee Street
Dayton, Ohio 45402

Dear Mr. Frericks:

this is in response to your letter of September 8, addressed to former Acting Assistant Secretary Alan C. McMillan, concerning nurse call systems. We regret the delay you have experienced in receiving our reply.

In order to respond more adequately to the question raised in your letter, we contacted the Underwriters Laboratories, Inc. (UL) and discussed nurse call systems. Their explanation and the Occupational Safety and Health Administration (OSHA) requirements are as follows:

Nurse call systems are tested against the provisions of UL Standard 1069, Hospital Signaling and Nurse Call Equipment, or its equivalent. this testing is the basis for certification and/or approval by a Nationally Recognized Testing Laboratory (NRTL). Such a certification and/or approval is what OSHA requires. Pocket paging systems are normally only tested for fire and electrical shock producing hazards and are not tested as extensively as a nurse call system which is also tested for reliability of operation and performance.

If a nurse call system interfaces with a pocket paging system, each whole system (the nurse call system plus the pocket paging system) must be tested against the provisions of UL 1069 or its equivalent. Otherwise the NRTL certification and/or approval is not valid and it will not meet OSHA requirements.

Special electrical equipment, such as the nurse call system, is acceptable to the Assistant Secretary of Labor, and approved within the meaning of Subpart S of the OSHA General Industry Standards 29 CFR 1910, if it is accepted, or listed, or labeled, or otherwise determined to be safe by a NRTL.

September 8, 1989

Department of Labor
Assistant Secretary for Occupational
Safety and Health
Washington, DC 20210

Attn: Alan C. McMillan, Assistant Secretary

Dear Alan:

Enclosed is a copy of a letter you authored and sent to Frank K. Ktzantides of the National Electrical Manufacturers Association. Your letter was in response to NEMA's request for clarification on the government's position as to nurse call systems and their need to be certified and/or approved by a nationally recognized testing laboratory.

We are a contractor that installs nurse call systems in southwest Ohio and are confused as to the statements being made by the different nurse call manufacturers as to the certification of nurse call systems connected to pocket paging systems. In these types of systems when a patient places a call to the nursing station the call annunciates to the appropriate pocket pager worn by a nurse. Several manufacturers have had interfaces for pocket paging systems listed by U.L. under the nurse call listing - UL 1069. This listing, however, does not include the pocket paging system itself; only the interface.

The question to you is can a pocket paging system be used to annunciate patient calls in a nurse call system without violating OSHA regulations? We have some manufacturers telling us yes, while we have others saying no.

The primary concern of the manufacturers that have not produced a pocket paging interface is that there is presently no way to insure that the nurse, with the pocket pager, would ever get the patient call (dead battery, out of range, etc.). But other manufacturers are suggesting that this system is a supplementary system and as such does not require the redundancies that are required under UL 1069. If it is true that the pocket paging system is considered as a supplementary system, is it still a supplementary system if the nurse or unit clerk at the nurse call master station is not present and the call, automatically, is forwarded to the nurse's pager unit?

We would appreciate your time in this matter in that our interpretation of the laws have already cost us one job.

If there are any questions please don't hesitate to call.

Sincerely,



Thomas J. Frericks, Jr.
President/General Manager