The regulations were amended to read, “Fire and evacuation drills shall be conducted at least monthly.”  While we understand and appreciate the spirit behind the added requirement of monthly fire and evacuation drills, we have a concern as to the impact this requirement will have on the best interests of the individuals we serve.  With additional types of drills that are regularly completed (tornado, earthquake, etc.), requiring a monthly fire drill has the potential to negatively impact the wellbeing of individuals by disrupting daily structure or even reinforcing any ideologies of surveillance or feelings of disenfranchisement.  Furthermore, a monthly frequency of fire drills have the potential to reduce the sense of urgency residents feel should an actual fire emergency occur.  We believe each individual’s safety and security can be better reinforced by conducting fire drills quarterly and within 10 days of a new individual moving into a residence.  Furthermore, as part of the provider’s risk assessment and quality improvement plan, we suggest that providers regularly evaluate if and when additional drills are required.     

We are further seeking clarity regarding Section (B) of the regulations which reads, “The provider shall evaluate each individual and, based on that evaluation, shall provide appropriate environmental supports and adequate staff to safely evacuate all individuals during an emergency.”  In order to implement this provision in a uniform and complete manner we seek clarity regarding the standard at which “appropriate and adequate” is based upon.  Is the standard of appropriate and reasonable to be set by each provider?  If not, we are seeking guidance as to what standard meets the expectations of the Department so to uniformly comply with this provision across the state.

Finally, we are seeking clarification on Section (J)(3) of the regulations which state, “At least one smoke detector in any area adjacent to any bedroom in locations with bedrooms.”  Our interpretation of this provision is that “any area adjacent to any bedroom in locations with bedrooms” would require properties in which a master bedroom with an adjacent bathroom to place smoke detectors in the bathroom of the bedroom.  Does this interpretation capture the intent of the provision?