The
cost of mission-critical emergency generation in health-care
facilities appears to be on its way up. A jury in a trial that
commenced in Louisiana in early January will decide whether
administrators at the Pendleton Methodist Hospital in New Orleans
should have located a backup generator and related equipment above
the flood level before Hurricane Katrina. The hospital’s failure to
do so is alleged to have caused a life-support ventilator system to
stop working, resulting in the death of a 73-year old patient, Althea
LaCoste. Other systems affected by the loss of power included
life-critical systems such as infusion pumps, lighting, HVAC,
elevators, and other building systems. Doctors and nurses attempted
to provide care by manually operating life-support machinery and by
evacuating patients without elevators, but the task proved
overwhelming for “human power.” The Pendleton Hospital argues
that its emergency generation satisfied all applicable codes and
standards and that it had a well-developed emergency system but that
it was impossible to be completely flood-proof particularly when
faced with one of the greatest natural disasters in American history.
The Louisiana Supreme Court ruled in 2007
that LaCoste’s family could sue the hospital for negligence, which
does not cap damages instead of for medical malpractice, for which
claims are limited to $500,000. This case is believed to be the first
of approximately 200 lawsuits that have been filed relating to deaths
in hospitals or nursing homes during the flood after Katrina. This
case could set precedent affecting both the Katrina-related lawsuits
awaiting trial in federal or state courts and lawsuits based upon
future catastrophes, since disaster planning is far different than
providing medical care.
Regardless of the
decision of the jury, the LaCoste lawsuit and similar litigation is
likely to give rise to a theory of general tort liability against
health-care institutions predicated upon their installation of
emergency generation that fails to operate in widespread disasters. A
verdict in favor of LaCoste’s family could impose an expensive
burden upon many other U.S. hospitals to protect against threats
whether realistic or unrealistic. The emergence of this new theory of
liability against health-care institutions based upon lack of
emergency preparedness has not gone unnoticed by insurers, whose
requirements (and, more to the point, premiums) affect the actions of
insured hospitals.
Hospitals often operate on
thin profit margins and struggle to meet the demands imposed on them.
Deciding whether to purchase critical machines for intensive care or
protect generating units has been described as a zero sum game. Will
hospitals be forced to choose between protecting backup generators
against every type of disaster that might possibly affect the region
and meeting other urgent health-care requirements? The answer of the
New Orleans jury to that question may well be “yes.”
This
type of liability presents a special challenge to specifying
engineers and hospital administrators. Health-facility backup
generators have historically been required to power critical
health-care facilities in the event of short-term electric grid
failures. For example, the National Fire Protection Association
Standard for Emergency Power (NFPA 110) requires backup generation to
provide immediate life safety, such as ensuring necessary power to
complete medical and procedures in which cessation presents a danger
of harm or even death to patients.
Health-care
facility operators who meet no more than the required regulations and
oversight organization standards must also be prepared for
after-the-fact allegations that the operator should have gone beyond
such standards. An important issue in lawsuits such as this is to
what extent health-care operators can be held liable for not
effectuating measures that exceed such regulations and standards. An
example of such an allegation is the LaCoste family’s claim that
the hospital should have installed or specified a fuel pump that was
submersible to serve a generator that was located above the flood
line. The fuel pump was designed to provide fuel from a fuel tank to
the elevated generator, but floodwater caused the pump to stop
working.
The tragic events caused by Katrina
and other events during which a loss of grid power negatively
impacted clinical operations, such as the Northeast blackout in 2003,
flooding in Houston during 2001, and other major hurricanes such as
Ivan and Jean in 2004 and Rita in 2005, combined with the increasing
role of electronic equipment in critical patient care, have led to a
reassessment of what should be taken into account when installing
hospital emergency generation. Such considerations include which
steps are necessary to protect existing emergency generation against
potential disasters (such as elevating generators above possible
flood levels), providing fuel storage that anticipates lengthy grid
outages, and determining the appropriate duration of grid outage to
protect against.
Existing standards, or at
least recommendations, are changing in response to these realities.
The majority of American hospitals are accredited by the Joint
Commission [formerly the Joint Commission on Accreditation of
Healthcare Organizations (JCAHO)]. Following its review of the
experiences of health-care facilities in disasters such as the
Katrina flood, an alert circulated by the Joint Commission advised:
“… recent experiences demonstrate that
emergency power systems that meet [existing] standards are not always
sufficient during major catastrophes [since] they can only support
the power needs of a small percentage of the needed equipment . . . ,
or they are unable to supply power for an extended period of time.
For example, in the wake of Hurricane Katrina, many health-care
organizations did not have sufficient emergency power to cool or
ventilate their facilities. In other instances, evacuation of
patients was delayed because only one or two elevators could be
operated. To assure optimal safety during catastrophes, health care
organizations are encouraged to go beyond the minimum NFPA life
safety requirements . . . ”
The Joint
Commission also recommended the following risk reduction strategies
in that alert:
“. . . assure optimal
location of the generator, fuel tank, and support equipment (for
example, in flood prone areas, above potential flood levels) and
proper redundancy (multiple generators feeding loads versus loads
dedicated to a single generator)…assure that emergency power feeds
critical systems, heating, air conditioning and fan units in intense
climate regions; and air handlers in isolation rooms (to minimize the
risk of airborne infections), in protective environment rooms, and in
. . . pharmacy hoods.” Joint Commission, Preventing adverse events
caused by emergency electrical power system failures, Sentinel
Event Alert, Issue 37, Sept. 6, 2006,
http://bit.ly/857SMq.
A problem in assessing
the extent of possible liability is that while some dangers may be
present and known, such as an earthquake in Los Angeles or a flood in
New Orleans, the probability of such events occurring may be low. For
example, a flooding event similar to the one caused by Katrina had
not previously occurred in the modern history of New Orleans, largely
as a result of levee construction by the U.S. Corps of Engineers. The
low likelihood of some disasters complicates the disaster planning
since the process must necessarily include 50 or 100-year events
potential that may bring disaster far in the future. How should a
hospital weigh improbable events when making costly renovations to
its existing generation system or adding cost to a new installation,
especially since the severity of the consequences of the event is
also unknown?
In the LaCoste case, the
Pendleton Hospital’s planning process did consider the risk of a
flood and the evidence of that forms part of the case presented by
the plaintiffs in the lawsuit. Three years prior to Katrina, a New
Orleans city health official questioned city hospitals as to which of
their emergency generators would be subject to failure in the event
of a flood in light of the experiences of the Texas Medical Center,
when emergency generators were flooded during Hurricane Allison. The
Pendleton Hospital responded that one of the of the generators was on
a roof but the other, located lower, would be non-functional in 2
feet of water. At the time a Pendleton Hospital official estimated
that it would cost approximately $7.5 million to relocate the
generators and fuel supply and take other protective measures, but
that project was never done. It appears that other New Orleans
hospitals with facilities located below potential flood levels also
did not take such steps either in light of the prohibitive
cost.
Since a lesson of these disasters is
that backup generation may be required to operate for extended
periods of time when deliveries of diesel fuel are unavailable,
siting and constructing on-site storage for a substantial amount of
fuel presents an array of questions and difficulties. Backup
generation operated over a prolonged period of time can consume great
amounts of fuel. During a 38-day post-flood recovery period at the
Memorial Hermann Hospital campus in the Houston area, 36 portable
generators consumed an estimated 10,000 gallons of fuel each
day.
The disconcerting reality confronting
hospitals is that the cost of not anticipating disasters might be far
greater than the cost of providing appropriate protection for their
emergency generators and sufficient fuel for prolonged operation.
Health-care facilities should now take potential liability into
account in any cost-benefit analysis of providing protection for
their emergency generation systems and providing for a sufficient
on-site supply of fuel. This column does not consider the
availability or cost of securing insurance, but the universe of costs
addressing potential liabilities must include the availability and
cost of insurance.
A consequence of our
system of law demonstrated by this New Orleans case is that
regardless of their likelihood certain risks may be elevated above
others as a result of liability. Despite the fact that a continuous
supply of electric power is important to virtually every aspect of a
health-care facility’s ability to provide patient care, it is clear
that additional monies invested in emergency generation systems to
protect against remote disaster events might well detract from a
hospital’s ability to provide other urgently needed services. While
there is no ready solution to this problem, engineering, medical. and
legal evaluation of the risks and possible remedies is essential.
This article and the information in it do not
constitute legal advice, is not intended to be comprehensive and is
provided for informational purposes only. Readers should consult with
their legal counsel for advice regarding the information contained
herein.
Katrina's Legacy Includes New Threats of Liability Litigation
February 1, 2010
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Peter Funk is a partner at Funk & Zeifer where he practices in the area of energy law with a focus on energy generation and energy management\conservation projects. Funk’s column Legal Perspectives discusses legal issues pertaining to energy generation and conservation.
Phyllis J. Kessler is an attorney at
Duane Morris LLP. Both practice in the area of energy law with a
focus on energy generation projects. Daniel J. Bauer, associate,
Duane Morris, LLP, helped write and research this column.