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Articles by Jonathan Flannery
Healthcare proposals help shape 2027 I-Codes
The International Code Council (ICC) wrapped up the 2027 ICC code cycle with the Online Governmental Consensus Vote this past summer and is now in the process of publishing the 2027 editions of the I-Codes, with six of the 15 codes already available digitally. The ICC Committee on Healthcare (CHC) submitted a total of nine proposals for consideration and cosponsored an additional eight proposals with the Building Code Action Committee and others.
OSHA extends deadline to comply with new HazCom rule
On May 20, 2024, the Occupational Safety and Health Administration (OSHA) finalized its update to the Hazard Communication Standard (HCS) with an employer implementation date of July 20, 2026. However, OSHA has determined it is necessary to extend the initial compliance date by four months to allow time for it to publish the necessary guidance materials and for the regulated community to review those materials before the revised provisions take effect.
Prioritizing worker safety during the ‘dog days’ of summer
Just what is meant by the idiom the “dog days” of summer, and when do those days occur? While this phrase may bring about memories of lazy afternoons playing in the sprinklers or watching a baseball game, the idiom actually is a historical phrase used to describe the hot, sultry and typically inactive period of midsummer. According to The Old Farmer’s Almanac, the exact period occurs from July 3 to Aug.
OSHA updates it heat hazards program
The Occupational Safety and Health Administration (OSHA) has updated its National Emphasis Program that protects workers from outdoor and indoor heat. By analyzing the labor statistics data from 2022 to 2025, OSHA has identified industries with high rates of heat-related illness and industries. Heat illness remains a serious hazard for indoor and outdoor workers, leading to preventable injuries and fatalities every year.
Using new tech while adhering to older codes
As noted by Chad Beebe, AIA, CHFM, CFPS, CBO, FASHE, deputy executive director of the American Society for Health Care Engineering (ASHE), in a previous article on staying current with code updates, “In the complex world of health care facilities management, staying up to date with the latest codes and standards isn’t just a best practice, it’s essential.” The ASHE Regulatory Affairs Team strives to assure that evolving codes and standards provide not only a safe environment for patients,...
ICC committee advances key code changes
The International Code Council (ICC) held code action hearings for the administrative, general and structural sections of the International Building Code, International Existing Building Code, International Property Maintenance Code and the International Zoning Code from Oct. 22-30. The ICC Committee on Healthcare (CHC) testified in support of 33 proposal comments — 12 of which were for proposals submitted by the CHC — and opposed comments on 21 other proposals.
ICC posts proposal comments ahead of next committee action hearing
The International Code Council (ICC) posted the comments for its upcoming committee action hearing for the administrative, general and structural sections of the International Building Code (IBC) along with the International Existing Building Code (IEBC), the International Property Maintenance Code and the International Zoning Code. The ICC Committee on Healthcare (CHC) submitted comments on a total of 28 proposals.
Operating and maintaining ventilation infrastructure
The guideline addresses health care HVAC systems as a comprehensive whole while providing consistency in the maintenance and operations of these systems. Over the last several years, one of the leading survey findings within the physical environment has been the control of ventilation systems throughout health care facilities.
CMS provides shared space guidance for critical access hospitals
On Nov. 20, the Centers for Medicare & Medicaid Services (CMS) released guidance on expectations related to space sharing arrangements, including time-sharing and leased space agreements between critical access hospitals (CAHs) and other health care entities. In QSO-25-08-CAH, CMS states, “Current access to care challenges in rural communities call for flexibility in health care partnerships, while simultaneously protecting the safety and quality of care for patients.
Committee advocates for changes to 2027 I-Codes
The International Code Council (ICC) held its second code action hearings in Long Beach, Calif., in October to consider updates and improvements to several of the proposals originally disapproved during its first code action hearings for the 2027 International Codes. Participants in the hearings debated over proposed changes to the 2027 editions of the International Fire Code (IFC), International Building Code (IBC), International Plumbing Code (IPC) and International Mechanical Code.
Why ‘can do’ is a ‘must do’ for innovation to flourish
Let’s be honest with ourselves; So much of our lives are beyond our control. The era when we are born. The families of which we are a member. The geography of where our home resides. And yet, despite the thousands of details of our life that are beyond our control, every moment of every day, we are presented with a choice, an endless question. How do we choose to respond to the factors in our lives that are within our control?
ICC committee continues code alignment efforts for 2027 cycle
In 2011, the International Code Council (ICC) and the American Society for Health Care Engineering came together to form the Committee on Healthcare (CHC). The objective of this committee is to develop code change proposals to the International Codes (I-Codes), which will result in the most contemporary, effective and efficient provisions for health care facilities to assure the highest level of safety for all users of such facilities.
Top 10 physical environment findings
Health care facilities professionals should develop a greater understanding of the requirements that apply to their organizations. Health care facilities are under continual scrutiny by various regulatory authorities, most notably the Centers for Medicare & Medicaid Services (CMS). CMS allows health care facilities to be accredited by third-party organizations that are deemed by CMS to have requirements that are comparable and at least as stringent as the CMS Conditions of Participation (CoPs).
The ICC Committee on Healthcare successfully advocates for changes to 2027 codes
The International Code Council (ICC) held public hearings in Orlando, Fla., in May to consider updates to several ICC codes. Participants in the hearings debated over proposed changes to the 2027 editions of the International Fire Code (IFC), International Building Code (IBC), International Plumbing Code (IPC) and International Mechanical Code. The ICC Committee on Health Care (CHC) submitted 14 proposals for consideration and provided testimony for 35 other proposed changes.
The ICC’s Committee on Healthcare continues code alignment efforts
In 2011, the International Code Council (ICC) and the American Society for Health Care Engineering (ASHE) came together to form the Committee on Healthcare (CHC). The objective of this committee is to develop code change proposals to the International Codes (I-Codes) to help produce the most contemporary, effective and efficient provisions for health care facilities, ensuring the highest level of safety for all users of such facilities.
Three steps to identify unknown risks in facilities
Risk, or the possibility of an adverse action occurring, exists in every system whether the system is mechanical, electrical, human or something else. In his book The Unknown Known: A Memoir, Donald Rumsfeld stated: “There are known knowns. These are things we know that we know. There are known unknowns. That is to say, there are things that we know we don’t know. But there are also unknown unknowns.
EPA proposes new rule for managing ethylene oxide in facilities
Certain products containing ethylene oxide (EtO) are considered pesticides under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) because they can be used to kill viruses and bacteria. For instance, EtO can be used as a pesticide to sterilize certain equipment, including some medical devices like implants and surgical tools that cannot be sterilized using alternative methods such as steam or radiation due to lack of compatibility with certain materials.
Incorporating MEP into a broader cybersecurity strategy
In 2015, the National Institute of Standards and Technology (NIST) released the Framework for Improving Critical Infrastructure Cybersecurity (“Cybersecurity Framework”) in response to a requirement of Executive Order 13636, Improving Critical Infrastructure Cybersecurity.
CMS memo provides clarification on end of PHE-related waivers
In a QSO memorandum issued May 1, the Centers for Medicare & Medicaid Services (CMS) clarifies the termination dates of specific public health emergency (PHE) waivers, including waivers regarding the physical environment.
Wearable devices call for investment in wireless infrastructure
When it comes to patient care, detailed monitoring of a patient’s condition is necessary to not only keep the patient safe but to also properly diagnose the patient’s condition. Patient monitoring via medical telemetry plays a profoundly important role in the care of patients. Studies demonstrate that patients with cardiac risk factors who are monitored have significantly better outcomes than those who are unmonitored.
CMS releases guidance to help hospitals improve quality performance
Quality Assessment & Performance Improvement (QAPI) Conditions of Participation (CoP) deficiencies are the third most frequently cited of the 24 CoPs for Medicare-certified hospitals. In its ongoing effort to promote and advance a proactive culture of safety, the Centers for Medicare & Medicaid services has developed updated interpretive guidance on QAPI programs.
Chemical plant fire could impact water, wastewater systems
The Environmental Protection Agency (EPA) issued a notice regarding the impact of the fire at the Carus Chemical Company plant in LaSalle, Ill., on the morning of January 11. The EPA specifies that: “Due to the fire, potassium permanganate and sodium permanganate production at the LaSalle facility have been severely impacted. The Carus facility in LaSalle is the only producer of potassium permanganate and sodium permanganate in the Western Hemisphere.
HHS updates its list of hazard vulnerability analysis tools
The Assistant Secretary for Preparedness and Response (ASPR) Technical Resources, Assistance Center, and Information Exchange (TRACIE) updated its Evaluation of Hazard Vulnerability Assessment (HVA) Tools, which highlights similarities and differences among applicable HVA tools used by public health and health care organizations.
Debate examines conflicts between life safety and infection prevention
Jonathan Flannery of ASHE led a debate-style session on infection prevention versus life safety. Image courtesy of ASHE The 2022 ASHE Annual Conference in Boston saw a first-ever formal debate regarding the impact that life safety requirements can have on infection prevention efforts and vice versa. While this was the first time that a debate style session was included at the ASHE Annual Conference, debating has been around for as long as opinions have been.
Resources to combat smoke intrusion
Smoke intrusion into health care facilities is not only a significant health concern but can be an extremely impactful event. As an example, a critical access hospital was evacuated earlier this year due to smoke from faulty wiring in a construction project. While there was no active fire, the smoke damage was serious and required the hospital to remain closed over the weekend. Another facility had to shut down its operating room suite due to smoke infiltration from work performed on the roof.
ASHE publishes revised infection control risk assessment guide
The use of ICRAs during health care facility design and construction projects has been evolving for several decades.
ASHE provides clarification on FDA medical device guidance
FDA seeks comments on draft guidance for remanufacturing of medical devices by September 22, 2021 Per the Food and Drug Administration (FDA), this draft guidance is intended to help clarify whether activities performed on devices are likely "remanufacturing." Such clarification intends to provide consistency and better understanding of applicable statutory and regulatory requirements.
ASHE reports on successes at International Code Council hearings
If you’re like most health care facility professionals you know that conflicts in building codes can be a real headache. Unnecessary and conflicting codes and regulations can be costly, and the resources spent to comply with contradicting requirements could be better put to use addressing other issues.
How to decrease fire risk in oxygen-enriched atmospheres
The European Commission Joint Research Centre (JRC) issued a special lessons learned bulletin in January regarding the risk of oxygen-related fires in hospitals treating COVID-19 patients, and incidents such as the hospital fire in Baghdad on April 24 where more than 80 people lost their lives in what appeared to be an oxygen-related fire clearly indicates the increased risk in these types of fires.
Hospital works with theater venue to set up vaccine distribution
As the nation begins to expand COVID-19 vaccine availability to more and more individuals, the need for additional space to perform these services can become a challenge. First and foremost, dedicating space at the hospital may not be the best-case scenario. Many hospital campuses are quite large and have limited parking. Providing ample wayfinding from where the available parking may be to the available clinic space can be its own challenge.
Johns Hopkins addresses COVID-19-related oxygen shortages
On Jan. 26, Johns Hopkins Center for Health Security issued a white paper on potential solutions to the COVID-19 oxygen crisis. While there have definitely been shortages of oxygen reported by news outlets, there are a few things that can be done to help avoid this issue from occurring. Of course, to be able to truly understand the importance of the solutions it helps to understand what is driving this issue in the first place.
Thoughtful responses to COVID-19 pandemic
One of the intriguing issues that developed due to the COVID-19 pandemic is the overwhelming amount of information and guidance. This brought to mind two proverbs: “Haste makes waste” and “Patience is a virtue.” While these proverbs are propagated throughout our lives because they are self-evident, it bodes well to reflect on what their meanings truly are. “Haste makes waste” is about doing things in a careful and precise manner.
Understanding RPT use and code requirements
Relocatable power taps (RPTs) are a common cause for citations related to inappropriate electrical issues. In 2014, the Centers for Medicare & Medicaid Services (CMS) began offering categorical waivers to allow hospitals to use RPTs, also known as multi-plug adapters or power strips, in patient care areas under certain circumstances.
FDA permits emergency use of alternative respirators
The Food and Drug Administration (FDA) recently issued two letters that allow for greater flexibility in the use of filtering facepiece respirators (FFRs). The recommendations were made based on the evolving COVID-19 public health emergency and FFR shortages.
ASHE issues recommendations on COVID-19 for facilities managers
As the American Hospital Association continues to report on the novel coronavirus (COVID-19) and monitor updates from the Centers for Disease Control and Prevention (CDC) and World Health Organization (WHO), the American Society for Health Care Engineering (ASHE) has also compiled COVID-19 resources for health facilities managers to help battle the virus. First identified in Wuhan, China, in December 2019, the virus has spread to thousands in China, with more than 2,000 associated deaths.
Adding safety to upcoming hospital holiday cheer
For those responsible for their hospital’s compliance with The Joint Commission’s Environment of Care Chapter, the most dreaded season may be the winter holidays. It is the season when the desire of well-meaning staff to celebrate and decorate often clashes with the rules and regulations facilities and safety professionals are responsible to uphold. Often, the safety officer must be “the Grinch” while walking the halls and units within the health care facility.
Comprehensive utility failure plans
A “hiccup” in the essential electrical system could be a sign of a much larger issue within the overall system that could impact patient care if it is not properly communicated. Image from Getty Images It often seems there are more questions than answers when it comes to developing comprehensive utility failure plans. In fact, many facility professionals are in the process of developing their own plans and curious about how their peers are approaching the issue.
Public resources for utility failure planning
Utility failure risks in the physical environment can include electricity, lighting, domestic water, medical gases, vacuum, HVAC, air pressure, domestic water, fire sprinkler and alarm, nurse call, security and access control, computer networks, refrigeration, steam, natural gas, sewer and wastewater, vertical transportation, medical equipment and myriad other specialty systems all needed to properly care for patients and to perform daily operations.
Make yourself heard at the NFPA meeting
Next year’s National Fire Protection Association (NFPA) Conference & Expo is an especially important event for those interested in health care codes and standards. At the June 2020 meeting, NFPA members will cast important votes during the technical meeting portion of the program on proposed changes to both NFPA 99, Health Care Facilities Code, and NFPA 101®, Life Safety Code®.
Task force helps members to overcome blind spots
In 1999, social psychologists David Dunning and Justin Kruger published a study titled “Unskilled and Unaware of It: How Difficulties in Recognizing One’s Own Incompetence Lead to Inflated Self-Assessments.” The study centered on a psychological phenomenon of illusory superiority that they identified as a form of cognitive bias, which essentially means being ignorant of one’s own ignorance. They coined it the Dunning-Kruger Effect.
ASHE victories at ICC meeting help to unify building codes
The International Code Council (ICC) Committee on Healthcare (CHC) was established by the ICC Board to evaluate and assess contemporary code issues relating to health care facilities. This is a joint effort between ICC and the American Society for Health Care Engineering (ASHE), a professional membership group of the American Hospital Association, to eliminate duplication and conflicts in health care regulation.
New initiatives address conflicts for power taps
The American Society for Health Care Engineering (ASHE) recently became aware of survey citations for the failure to use Underwriters Laboratories Inc.’s (UL’s) Outline of Investigation 2930-listed movable power supplies within the patient care vicinity. In our efforts to decipher this issue, we discovered that UL 2930 was commissioned through UL to fill a gap for movable power supply connections. UL Outline of Investigation 1363a covers special purpose relocatable power taps (SPRPTs).
Five tips on submitting regulatory comments
Recently, health facility professionals saw two key opportunities to participate in the advocacy process: The National Fire Protection Association (NFPA) requested input into a proposed tentative interim amendment (TIA) on NFPA 110, Standard for Emergency and Standby Power Systems; and the Centers for Medicare & Medicaid Services (CMS) issued its proposed rule regarding regulatory provisions to promote program efficiency, transparency and burden reduction.
Examining the federal rule-making process
The public rule-making process is the method through which federal rules and procedures are established. Typically, when Congress passes a law to create an agency, it grants that agency general authority to regulate certain activities. Congress also may pass a law that more specifically directs an agency to accomplish certain goals. An agency must not take action that goes beyond its authority or violates the Constitution.
Taking part in the ICC code-development cycle
As noted in last month’s Advocacy Adviser column, reducing code conflicts allows health care facilities to optimize their physical environment and focus more of their resources on patient care. Over the next few months, we will share how you can become part of the team to help with the future unification of health care codes and standards. This month I will discuss the International Code Council (ICC) code-development cycle.
Working to unify overlapping codes
The American Society for Healthcare Engineering (ASHE) advocacy team works to monitor and unify the many overlapping codes and standards that affect health care facilities. It strives to maintain a proactive advocacy position in support of regulations that are backed by data and make sense for health care. Some of the key accomplishments over the last several years have been: While a lot of good work has been accomplished, there is still more to do.
ASHE issues update on CMS ligature-risk policy
The American Society for Healthcare Engineering (ASHE) previously alerted members to a Centers for Medicare & Medicaid Services (CMS) memo that clarified ligature-risk issues. It is now providing additional information specific to emergency departments (EDs) and other areas where at-risk patients may be treated.
Minimizing facility water system risks
The ASHRAE Standard 188-2015, Legionellosis: Risk Management for Building Water Systems, establishes minimum legionellosis risk-management requirements for building water systems in all types of buildings. However, the standard also recognizes the unique nature of health care facilities that have infection preventionists on staff, and allows qualified health care facilities to use a more risk-based approach instead of the prescriptive approach of the general ASHRAE 188 requirements.
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