HEALTHCARE INFRASTRUCTURE CODE ISSUES Mark Jelinske, P.E. ASHRAE Technical Conference May 2, 2014
Agenda Applicable Codes and AHJs Fire/Life Safety Codes NFPA 99 FGI Guidelines ASHRAE 170 Common areas of confusion
POV of Speaker Always check with the Authorities Having Jurisdiction (AHJ). o o
Confirm codes adopted and amendments Multiple AHJ in Healthcare
Be aware of liability of ignoring the code, even if the AHJ “lets” you. This presentation based on what the code says, not any specific AHJ interpretation. mostly
Existing building vs. new? AHJs have different ways of looking at the code>>>
CODES AND AHJs Colorado Department of Public Safety, Division of Fire Prevention and Control For healthcare facilities licensed by the State Health Department. 2012 International Codes 2011 NEC 2010 FGI Guidelines, including 2008 ASHRAE 170 with addenda issued as of July 1, 2013 2012 NFPA 101 and referenced codes. 2012 NFPA 99
CODES AND AHJs Centers for Medicare and Medicaid Services (CMS) Healthcare Facilities seeking reimbursement for Medicare and Medicaid 2000 NFPA 101 (Life Safety Code) and associated referenced codes/standards. Proposed adopting 2012 NFPA 101 Public Review Comment Period NOW!
CODES AND AHJs The Joint Commission (TJC) Formerly known as JCAHO – private accreditation agency, used by insurance companies to qualify healthcare facilities. 2000 NFPA 101 Expected to follow CMS to the 2012
2010 FGI Guidelines Expected to adopt 2014 “shortly”
CODES AND AHJs Local Building/Fire Departments All Buildings 2009 – 2012 International Codes
CODES AND AHJs Healthcare must observe the “worst case” of ICodes and NFPA 101 2000 NFPA 101 supersedes 2012 version in conflicts where CMS is an AHJ Multiple versions of referenced standards NFPA 99 – 1999, 2005, 2012 NFPA 13 – 1999, 2007, 2010 NFPA 70 (NEC) – 1999, 2008, 2011,2014
OCCUPANCY TYPES I CODES (Local AHJs) B (Business) – Typical Dr. Office. Can include treatment and fancy imaging. B, plus Ambulatory Healthcare – “…provide …care on a less than 24-hour basis to individuals who are rendered incapable of self-preservation by the services provided.”
OCCUPANCY TYPES I CODES (Local AHJs) I-2 - “medical care on a 24-hour basis for more than five persons who are incapable of self-preservation. This group shall include, but not be limited to, the following: Foster care facilities Detoxification facilities Hospitals Nursing homes Psychiatric hospitals
NFPA 101- Business An occupancy used for the transaction of business other than mercantile.
NFPA 101- Ambulatory Healthcare A building or portion thereof used to provide services or treatment simultaneously to four or more patients that provides, on an outpatient basis, one or more of the following: (1) treatment for patients that renders the patients incapable of taking action for self-preservation under emergency conditions without the assistance of others; (2) anesthesia that renders the patients incapable of taking action for self-preservation under emergency conditions without the assistance of others; (3) emergency or urgent care for patients who, due to the nature of their injury or illness, are incapable of taking action for selfpreservation under emergency conditions without the assistance of others.
NFPA 101- Healthcare An occupancy used for purposes of medical or other treatment or care of four or more persons where such occupants are mostly incapable of self-preservation due to age, physical or mental disability, or because of security measures not under the occupants’ control
MIXED USE AND OCCUPANCY NFPA 101 - Healthcare must be separated from non healthcare by a 2 hour Fire Barrier, 1 hour for Ambulatory Healthcare. 2000 version - openings between Healthcare and other occupancies only in Corridors
IBC - If non-separated, must use worst of construction and area requirements. “Accessory Use” if < 10% of area If separated Fire Barriers at separations
MIXED USE AND OCCUPANCY Fire Barriers or Smoke Partitions at specific areas NFPA 101 – Hazardous Areas IBC – Incidental Use Areas ROOM OR AREA
FUEL FIRED EQUIPMENT OVER 400 MBH; BOILERS OVER 15 PSI AND 10 HP; REFRIGERANT MACHINERY ROOM
SPRINKLERED BUSINESS - SMOKE PARTITION NON-SPRINKLERED BUSINESS/AHC - 1 HOUR HEALTHCARE - 1 HOUR
SOILED LINEN ROOM
NFPA HEALTHCARE - 1 HOUR NFPA SPRINKLERED AHC, BUSINESS – SMOKE PARTITION NFPA NON SPRINKLERED AHC, BUSINESS - 1 HOUR IBC I-2, AHC, - 1 HOUR IBC B – OVER 100 SF UNSPRINKLERED -1 HOUR IBC B OVER 100 SF SPRINKLERED – SMOKE PARTITION
STORAGE OVER 100 SF
NFPA HEALTHCARE - 1 HOUR NFPA SPRINKLERED AHC, BUSINESS – SMOKE PARTITION NFPA NON SPRINKLERED AHC, BUSINESS - 1 HOUR IBC IF LESS THAN 10% FLOOR AREA - NONE
Fire/ Life Safety Plans Shaft Enclosure Fire Walls Fire Barriers Fire Partitions Smoke Barriers Smoke Partitions Construction capable of resisting the passage of smoke
Horizontal Assemblies o Floor/Ceiling o Roof/Ceiling Horizontal Exit Exit Enclosure Exit Passageway Fire Area
Make sure these are identified on FLS plans using the code language. Identify NFPA vs. IBC required FLS features
Smoke Resistance Rated Construction SMOKE BARRIERS (Defend-in-place strategy) NFPA: Healthcare or Ambulatory Healthcare Floor below HC/AHC as well 2012 Revision – not if mechanical only
No dampers for ducted penetrations. NFPA 90A Requires Smoke Dampers to isolate AHU
I Codes: I-2 or B with AHC HC/AHC floor only Smoke Dampers at transfer and ducts Exception steel ducts serving only one smoke compartment.
Also a 1-hour Fire Barrier
Smoke Resistance Rated Construction Smoke Partitions o Healthcare/I-2 and Ambulatory Healthcare
corridors, or where Hazardous Areas/Incidental Use Areas utilize the sprinkler exception o No Fire rating o IBC – To Deck, Smoke Dampers in transfer openings, not ducted penetrations o NFPA – To lay-in ceiling, Therefore there is no barrier above ceiling
ASHRAE 170 ASHRAE 170 is integrated into 2010 FGI Guidelines, and 2012 NFPA 99. Joint Commission Reference Not adopted by CMS (yet) Continuing Maintenance
Not limited to Hospitals. Scope based on use of facility Can include outpatient if similar space use
FGI Guidelines Facility Guidelines Insitute Guidelines for Design and Construction of Healthcare Facilities. Consider it Code where it applies State – licensed Facility The Joint Commission Code language, new vs. renovation, partial upgrades, interpretations, equivalencies ALL types of Healthcare – Hospital, Psych/Rehab, Outpatient, ASC, Endo, Imaging
FGI Guidelines Planning Design Construction and Commissioning: Functional Program Infection Control Risk Assessment (ICRA) Acoustics
FGI Guidelines Table 1.2-2 Minimum-Maximum Design Criteria for Noise
FGI Guidelines Commissioning Basis of Design Pre-functional Checklists Functional Performance Tests TAB O&M
Common elements Toilet Rooms Handwashing Windows (operable not required) Finishes Ceilings
FGI Guidelines Common elements - MEP Plumbing 25 ft max non-recirc hw no dead ends Bedpan washers Handwash sink size, faucets Wrist Blade OK, auto not required. Scrub sinks – knee, foot, or auto
No storage under sinks Med Gas – NFPA 99 Outlet requirements here
Electrical – NEC, NFPA 110, receptacle count, Nurse Call, Paging, IT systems, 24 hours on site generator fuel storage “Where stored fuel is required”
FGI Guidelines Common elements - MEP HVAC Room pressure monitors – Isolation, Bronchoscopy No Duct Liner in specific critical areas Where allowed, in-room units must have a central, filtered OA system Natural Ventilation limited, Mech vent still required
ASHRAE Standard 170-2008 Ventilation of Health Care Facilities Continuous Maintenance Standard CDPS - addenda issued up to July 1, 2013.
ASHRAE 170 Redundancies for Equipment and Essential Accessories serving critical areas. OR, LDR, Recovery, ED, ICU, Nursery, Patient Rooms o Subject to breakdown or routine maintenance. o Heating: N+1 Heating Sources Pumps and return units Fans Not controls o Cooling: Level of redundancy required to “meet Facility
Plan” o Domestic Hot Water
ASHRAE 170 Air Handling System Components OA Intakes 6’ above grade, 3’ above roof, 3’ above bottom of areawell Min 25 feet from contamination sources Exhaust discharge 10’ above roof Isolation, Bronch, ED, Fume Hood, …
ASHRAE 62 Radiant/Chilled Beam - dew point control Humidifiers – Steam only.
ASHRAE 170 Air Handling System Components Filtration: MERV 7 pre, MERV 14 final most inpatient care, ALL B and C Surgery Protective Environment – MERV 7/HEPA MERV 14 – Class A Surgery, lab MERV 7 most other
Ducted return for areas requiring pressure relationships, PACU, Diffuser types: Non Aspirating (Laminar) - Surgery (all), Trauma, Protective Environment, Wound/Burn. Mixing or laminar – all others
ASHRAE 170 Class A surgery: provides minor surgical procedures performed under topical, local, or regional anesthesia without preoperative sedation. Excluded are intravenous, spinal, and epidural procedures, which are Class B or C surgeries. Class B surgery: provides minor or major surgical procedures performed in conjunction with oral, parenteral, or intravenous sedation or performed with the patient under analgesic or dissociative drugs. Class C surgery: provides major surgical procedures that require general or regional block anesthesia and/or support of vital bodily functions.
ASHRAE 170 Space Ventilation Room Pressure relationships: Clean to Dirty Maintained at all times, including unoccupied
Air Change per Hour (ACH) Requirements Must be maintained whenever occupied Spaces with pressure relationships may be reduced, but can not be shut off.
Minimum means minimum – VAV reheat, packaged units.
ASHRAE 170 Addendum d
ASHRAE 170 Patient Room 6 ACH, reduced to 4 ACH for supplemental heat or displacement ventilation Addendum ab revised to 4 ACH as standard
OR – Class B and C Primary array of laminar diffusers, over table + 12” all around, min 70% coverage, 25-35 fpm face velocity, Low return, min 2 separated as far as possible, additional high ones acceptable.
ASHRAE 170 Isolation Room Monitor required Neg pressure required at all times, switching to neutral or positive is not allowed. Can go to 6 ACH when not used for Isolation Exhaust in ceiling or wall near head HEPA in lieu of 12 ACH exhaust in renovation only where “impractical” Dedicated exhaust unless HEPA Anteroom optional
NFPA 99 Healthcare Facility Standard/Code Referenced by I-Codes for Medical Gasses Referenced by NFPA 101 for Electrical, Med Gas, Anesthetizing Locations Fully adopted by State, and proposed by CMS (2012)
1999, 2005, 2012 versions all in play
NFPA 99 Electrical Required Emergency Power Generator Fuel requirements (also NFPA 110)
IT/Nurse Call (2012) Plumbing (2012) – Plumbing Code, grey water requirements. HVAC (2012)- ASHRAE170 Equipment Emergency Planning, other Administrative issues Fire Protection Sprinkler zones match smoke compartments
Medical Gasses ASPE Seminar
NFPA 99 Anesthetizing Location Smoke Evacuation (1999 version, CMS proposal) “Windowless” rooms wherever use of inhalation anesthetics are intended Disregard “windowless”
Automatically vent smoke with no recirculation Can’t remove smoke from a real fire, CMS/State has allowed neg pressure for fire mode room CMS/State has allowed both use of HVAC system and dedicated system Combined with I-Codes = smoke control
Infection Control risk
Common Areas of Confusion Outpatient FGI, ASHRAE 170, NFPA 99 are applicable where the program has functions covered by those standards Question is when are they enforced? Depends upon Licensure and/or Accreditation
I vs. B vs. AHC vs. HC vs. Business MEP indirectly impacted by Occupancy MEP directly impacted by Function – see above
Common Areas of Confusion
Sequence of Control for Smoke/Fire Dampers Consider effect of damper closure on HVAC system Consider effect of damper closure on smoke migration Code minimum vs. something that works Engineered smoke control vs. just damper control Fire Alarm vs. BAS control
Common Areas of Confusion Medical Gas Rooms IFC – Triggered at 512 CU Ft. (2 E-cylinders) NFPA 99 – 3000 Cu. Ft. (12 E-cylinders) IFC – over 3000 Cu. Ft, H-3 occupancy, and this reduces with above or below grade floors IFC – Exterior wall louvers or dedicated exhaust and makeup in 2 hour enclosure to the exterior o Dampers not allowed
1999, 2005 NFPA 99 – Up to 3000 cu ft 2 exterior wall louvers, each 72 in2, or dedicated exhaust at 1cfm/sf. 3000 cu ft dedicated exhaust required. 2012 NFPA 99 – 2 exterior louvers, each 24 in.2/1000 ft3, or exhaust (not dedicated), or exhaust at 1 cfm per 5 ft3 (mis) Interpretation of NFPA 99 – Electric heat can not be inside med gas room.
Common Areas of Confusion Life Safety Plans Not all rated construction is treated the same. Not all fire resistive construction requires dampers o Fire Stop usually is required
Use IBC/NFPA terminology, not just “1 hour wall” or “Smoke Rated” Maintain and update Statement of Condition/ Record Documents.