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The Case for Consistency in Health Care Building Codes

Jeff O’Neill, AIA, ACHA

Health care facilities are a unique and complex building type. No other type of facility has as many different purposes and users, or houses as many different types of equipment and technology. No other facility type is regulated as much as a health care facility, with local, state, and federal mandates affecting its operations as well as its physical environment. From building construction to patient transfers to purchasing paper towels, there are regulations that affect nearly everything a health care organization does. And patients are not the only occupants of a health care facility who benefit from this attention to safety; otherwise healthy staff, physicians, nurses, administrators, and visitors also use these buildings. Truly, representatives from all walks of life come into a hospital every day.

The International Code Council (ICC) has created an Ad-Hoc Committee for Healthcare (AHHC) charged with addressing one aspect of all this regulation—the building codes that relate to health care facilities. As is well-known, the local, state and federal authorities that regulate building construction and maintenance do not all follow the same building codes. The purpose of the AHHC is to move toward application of one building code to health care facilities by bridging the gap between the I-Codes family and the National Fire Protection Association (NFPA) codes.

The goal is not to oversimplify, deregulate, or otherwise make the building codes any less concerned with the safety of building occupants. The ad-hoc committee is made up of building officials and representatives of health care organizations from across the country. Each of these seemingly disparate groups shares one common goal: to maintain a safe environment in which to deliver health care to our most vulnerable populations. The task is so great that only hospitals and associated ambulatory care facilities can be considered in this current effort.

The facts reflect that hospitals are one of the safest building types in the country, with only one fire-related death per year reported by NFPA for the years 2003–06.* This stellar record would cause some to wonder why we need to move toward one code, when things seem to be working well. The reason is that this success is not without its problems. Currently, health care facilities in the United States waste approximately $5 billion per year in construction costs, and most of this waste is caused by the difficulty of meeting the sometimes conflicting requirements of separate building codes. These differences arise not only from the actual language in the codes, but also from the two schools of thought from which they are developed. Interpretations of authorities having jurisdiction (AHJs) at all levels of government not only differ because of the book they are reading, but also in how they interpret the language in the books. Health care organizations are left to absorb the risks, financial and otherwise, that arise from these conflicts, sometimes tearing out completed work approved by one AHJ to satisfy the requirements of another. This case-by-case approach to dealing with conflicts in the codes leads to much wasted capital.

The capital budgets of health care organizations are often seen as never-ending sources of cash, largely because (1) they are kept separate from organizational operating funds and (2) user groups do not fund capital expenditures. However, when large sums of money must be spent for “code-required building elements” that do not support a building’s function or safety but are required for it to receive regulatory approval to open its doors, the money is very real. Such costs could mean funds are not available to purchase the latest piece of diagnostic equipment to replace one that is 20 years old or to hire a key physician, nurse, or counselor to help patients in need. These are real choices that need to be made as an organization tries to complete a costly capital project and open it to provide the beneficial uses for which it was intended.

Although most health care organizations have staff who only handle construction projects, the organizations are not in the business of building buildings. Their mission is to care for patients, and facility construction is a means to an end and not the organization’s primary activity. By establishing one code for health care facility projects, we recognize that the building is a continuing tool for the delivery of quality health care rather than an end in itself.

The goal of the ICC Ad-Hoc Committee is not to deregulate, but to create a single document enforceable by local, state, and other AHJs that is the best it can be in terms of regulating facilities to achieve safety for all occupants for a reasonable cost.

*Jennifer D. Flynn, Structure Fires in Medical, Mental Health, and Substance Abuse Facilities, NFPA, February 2009.