Comments on Revisions to the Built Environment (EC8)
Note: ASHE comments are highlighted in yellow.
General Comment
The chapter numbering should stay the same as it is now to provide continuity with existing plans. This should remain EC 8
Current Standard: EC.8.10
The organization establishes and maintains an appropriate environment.
Revised Standard EC.7.01.0:
The [organization] establishes and maintains an appropriate environment.
Note: One or more persons can be assigned to manage risks associated with the management plans described in this standard.
Define “appropriate”. This is not language that should be used in a standard (not code language). There needs to be specific requirements not general feelings.
Current Standard: EC.7.10 Current EP 1:
Interior spaces should be the following:
- Appropriate to the care, treatment, and services provided and the needs of the patients
- related to age and other characteristics
- Include closet and drawer space provided for storing personal property and other items provided for use by patients
- Lockers, drawers, or closet space is provided for patients who are in charge of their own personal grooming and who wear street clothes (for example, behavioral health care patients who wear street clothes and are expected to meet their personal grooming needs)
- For hospital settings that provide longer term care (more than thirty days), allow for good recreational interchange, consider personal preferences when feasible, and accommodate equipment, such as wheelchairs, that are necessary to activities of daily living
- For hospital settings that provide longer term care (more than thirty days), have equipment for rehabilitation and activities adequate to accomplish goals without compromising the environment’s safety
Revised Standard: EC.7.01.0: Revised EP 1:
Interior spaces meet the needs of the [patient] population and are suitable to the care, treatment, and services provided.
Define “meet the needs of the patient population” – what does this mean? This is non specific and not adequate code language. JC needs to list these needs or enforcement will be subject to the whim and personal experience of each surveyor.
Revised Standard: EC.7.01.0: Revised EP 4:
The [organization] provides sufficient storage space to meet [patient] needs.
Define “sufficient”. This needs to be referenced to a specific standard. This is non specific and not adequate code language whose enforcement will be subject to the whim and personal experience of each surveyor.
Revised Standard: EC.7.01.0: Revised EP 17:
Interior spaces accommodate the use of equipment, such as wheelchairs, necessary to activities of daily living.
Define “accommodate”. Does this mean free clearance to allow wheelchairs to pass (see ADA and AIA specific clearance requirements). If not this is non-specific and not adequate code language.
Current Standard: EC.8.10 Current EP 2:
Furnishings and equipment should:
- Be maintained to be safe and in good repair
- Reflect the patient's level of ability and needs
- For hospital settings that provide longer term care (more than thirty days), help to normalize the patient's living environment
Revised Standard: EC.7.01.0: Revised EP 24:
Furnishings and equipment are safe and in good repair.
What is the definition of safe? Risk assessment and subsequent maintenance efforts are implemented to reduce risk. Consider revising to read:
“The condition of furnishings and equipment minimize the risk of injury”
Current Standard: EC.8.10 Current EP 3:
For hospital settings that provide longer term care (more than 30 days) outside areas are:
Provided when required by the care, treatment, and services (for example, when certain patient groups, such as pediatric, experience long lengths of stay)
Appropriate and safe considering the care, treatment, and services provided and the needs of the patients related to age and other characteristics
Revised Standard: EC.7.01.0: Revised EP 5:
Outside areas are suitable to the [patient]s' ages, physical or mental conditions, or other factors.
With the >30 days criteria removed, will we now need to create outside areas for all patients? This is not simpler, it is a much greater requirements. Other factors is a broad statement without a basis for interpretation. This is a perfect example of making it worse not better.
Keep the current EP 3 as is.
Current Standard: EC.8.10 Current EP 4:
Areas used by the }patients are safe, clean, functional, and comfortable.
Revised Standard: EC.7.01.0: Revised EP 19:
Areas used by [patients] are clean and odor-free.
This is huge amplification of standards. We went from “ventilation to eliminate odors” in EC.8.10 – EP7 – to “odor-free”. This is a new requirement. I don’t know how we can create an odor-free environment
Current Standard: EC.8.10 Current EP 5:
Lighting is suitable for care, treatment, and services and the specific activities being conducted.
Revised Standard: EC.7.01.0: Revised EP 10:
Lighting is suitable for care, treatment, services.
What is the interpretation of “suitable”. This should be reference to a standard or eliminated.
Current Standard: EC.8.10 Current EP 7:
Ventilation provides for acceptable levels of temperature and humidity and eliminates odors.
Revised Standard: EC.7.01.0: Revised EP 13:
The [organization] maintains ventilation, temperature, and humidity levels specific to the environment.
How is “specific to the environment interpreted? These requirements need to be tied to a standard such as AIA or ASHRAE.
Current Standard: EC.8.30 Current EP 1:
When planning for the size, configuration, and equipping of the space of renovated, altered, or new construction, the organization uses one of the following: applicable state rules and regulations; Guidelines for Design and Construction of Hospitals and Health Care Facilities, 2001 edition, published by the American Institute of Architects; or standards or guidelines that provide equivalent design criteria.
Revised Standard: EC.7.03.0: Revised EP 1:
The [organization] uses one of the following design criteria when planning for new, altered, or renovated space: state and local rules and regulations; or Guidelines for Design and Construction of Hospitals and Health Care Facilities, 2001 edition, published by the American Institute of Architects; or when the above rules, regulations, and guidelines do not meet specific design needs, other reputable standards and guidelines that provide equivalent design criteria.
Why is the 2001 Edition referenced instead of the 2006 Edition?
Current Standard: EC.8.30 Current EP 2:
When planning demolition, construction, or renovation, the organization conducts a proactive risk assessment using risk criteria to identify hazards that could potentially compromise care, treatment, and services in occupied areas of the organization's buildings. The scope and nature of the activities should determine the extent of risk assessment.
AND
Current Standard: EC.8.30 Current EP 3:
When planning demolition, construction, or renovation, the organization uses risk criteria that address the impact of demolition, renovation, or new construction on air quality requirements, infection control, utility requirements, noise, vibration, and emergency procedures.
TO
Revised Standard: EC.7.03.0: Revised EP 2:
When planning demolition, construction, or renovation, the [organization] conducts a pre-construction risk assessment for air quality requirements, infection control, utility requirements, noise, vibration, and other hazards that affect care, treatment, and services.
Footnote: For information on fire safety procedures to implement during construction or renovation, see EC.4.04.0.
This contains a new requirement. Currently the standard calls for a proactive risk assessment. This new requirement is for a pre-construction risk assessment.
Risk assessment should be an ongoing process throughout a construction or renovation process. Changes take place during the course of a project that could introduce new risks.
Consider revising as follows:
“When planning and implementing demolition, construction, or renovation, the [organization] conducts proactive risk assessment that includes assessment of the potential affect on air quality, infection control, utilities, noise, vibration, and other hazards that affect care, treatment, and services.”
Current Standard: EC.8.30 Current EP 4:
When planning demolition, construction, or renovation, the organization selects and implements proper controls, as required, to reduce risk and minimize impact of these activities.
Revised Standard: EC.7.03.0: Revised EP 3:
The [organization] takes action based on its risk assessment to minimize risk and the effects of demolition, construction or renovation.
How do you define effects? Consider revising as follows:
“The organization takes action based on its risk assessment to minimize risk during demolition, construction or renovation.”