106-710 Traffic Pattern..

The provider shall enforce the traffic pattern.

Feedback: Extreme overreach. Unrealistic in many settings and especially leased facilities or buildings where space is integrated/shared with other offices or businesses.  Providers are not authorized as traffic enforcers nor staffed to provide traffic enforcement or address the safety needs of the general public.

106-710 Personal necessities

C. In service locations where appropriate, when individuals are incontinent or not able to use the toilet independently:

4. Staff shall thoroughly wash their hands with warm soapy water immediately after assisting a child or themselves with toileting.

Feedback: Staffs assist children and adults with toileting.  Nobody assists themselves with toileting.

106-810 Emergency Preparedness & response plan

b.Maintenance of a 24-hour phone line which can be used for communication duringemergencies.

Feedback: (b) is overly prescriptive.  Consider modifying to allow flexibility in how to maintain the capacity for 24/7 communication during emergencies. This may be achieved in ways other than a 24/7 telephone line

4. d.Policy and procedure for repatriation following evacuation including any necessary site inspections required before repatriation can take place.

Feedback: substitute “return” for “repatriation.”

106-820 Access to telephone....

A landline telephone shall be accessible for emergency purposes. The telephone shall be a line capable of operating during a power outage.

Feedback: Overly prescriptive.  Consider modifying to allow “telephonic communication shall be accessible for emergency purposes and capable of operating during a power outage.

Thank you!