I am in the midst of creating a PowerPoint presentation for a speaking engagement at the Annual Meeting of the International Association of Electrical Inspectors (IAEI) Wisconsin Chapter. Ironic (yet exciting) you say? What could an electrical engineer share with electrical inspectors that they don’t already know? Shouldn’t the inspectors be the ones teaching the engineer about interpreting and implementing codes?
I have to admit that it did cross my mind regarding what knowledge I could share with this group. Because of this concern, I did what any good engineer would do — research. I implemented my own informal query to some electrician and inspector friends. The overarching feedback I received was that not all people in the trades have a solid understanding of the differences between health care construction and non-health care construction. Not all jurisdictions have a hospital, clinic, or nursing home, so knowledge of health care-specific requirements is not necessary for some electricians or inspectors to do their jobs. With this feedback, I decided to focus my presentation on how health care electrical design requires adherence to more than just the basic electrical codes and building codes and provide a few examples of what to watch for in the field.
I am also not arriving “unarmed” to this particular event. I will be co-presenting with M. “Sam” Sampson, the senior electrical representative for the Department of Labor and Industry in St. Paul, Minn. We are partnering to exemplify how engineers, electricians, and inspectors can work together to implement a code-compliant and safe health care design. There are a lot of unique health care electrical code requirements that, if installed incorrectly or covered by drywall, may be difficult to find and are costly to change. If we have a better understanding of the requirements for health care facilities, the construction process can be significantly less painful.
Since most of you will not be attending the presentation, I will share with you the highlights of what we will discuss.
When thinking about the best way to start the presentation, the most obvious answer is to define what a health care facility is since it is not as straightforward as it sounds. There are many types of occupancies that are required to adhere to health care standards beyond your basic hospital or clinic. NFPA 99: Health Care Facilities Code defines a health care facility as “Buildings, portions of building, or mobile enclosures in which medical, dental, psychiatric, nursing, obstetrical, or surgical care is provided.” NFPA 70: National Electrical Code adds “Health care facilities include, but are not limited to, hospitals, nursing homes, limited care facilities, clinics, medical and dental offices, and ambulatory care centers, whether permanent or moveable.” The FGI Guidelines for Design and Construction of Hospitals and Outpatient Facilities define a health care facility as “Any facility type listed in the table of contents in this book.” One thing to note is the phrase “buildings or portions of buildings.” With health care services becoming more integrated into the community, smaller pop-up services are much more prevalent in nontraditional locations — and they do require adherence to health care codes regardless of where they are located.
This doesn’t mean that each health care facility is required to be designed the same as a full-blown hospital, but all health care facilities do have additional electrical design requirements beyond the rules in Articles 1-4 of NFPA 70. Article 517 is the primary Article in the NEC that affects health care engineering. It features a lot of additional and more stringent requirements above and beyond the content of the other Articles. Article 517 describes the branches of power, wiring criteria, coordination criteria, device criteria, and some installation parameters. Articles 700 and 701 also have special conditions for health care facilities beyond the basic emergency needs of non-health care occupancies.
In addition to the NEC, health care electrical design must adhere to NFPA 99. Chapter 6 provides additional requirements to the NEC. NFPA 70 and NFPA 99 are not installation manuals, but they do provide guidance for health care design parameters. There are also health care-specific criteria in NFPA 110: Standard for Emergency and Standby Power Systems. This document quantifies the level of emergency systems installation required, the run time of generators, and other design criteria based upon both the acuity of the patients and the seismic category of the structure.
Beyond NFPA and building code requirements, there are other resources that are either made into law or adopted as codes. An example of this is the FGI Guidelines, which is a compilation of design and construction guidelines that provide specific design criteria for many types of occupancies. Another entity that mandates additional requirements is the Centers for Medicare & Medicaid Services (CMS). Adherence to CMS guidelines is required for specific occupancy types to assure facilities receive reimbursement for their services. The adoption of specific editions of code and other ancillary documents is not consistent throughout the United States, and each state (or city) may have different requirements — and their own set of amendments to existing codes. The adopted building code may also dictate which other codes are enforced. This is why it is important that a code research effort is completed with each new health care project to confirm the edition of codes enforced and additional requirements or modifications to adopted codes.
So, on top of the adopted codes, guidelines and laws, health care design throws one more loop into the mix — just to make it more fun. This is what I call the “make a determination and hope the AHJ agrees with you” criteria. Many sections of these documents have a “needed for effective operation” or “as defined by the governing board of the facility” adder to some of the articles and sections. This eliminates the all-inclusive concise directive and allows flexibility in designs, which brings us back full circle to why it is good to have the engineer, electrician and AHJ all on the same page. There are many things that are clear-cut in the codes and guidelines, but there are other items that are truly up for interpretation. By having all parties, including the owner, in alignment before systems are designed and installed, you have fewer conflicts and a more collaborative design process.
With all the additional documents required to be referenced, interpreted, and implemented, mastering the unique differences specific to health care can be challenging. So Sam and I will share code requirements and walk through details regarding what we have seen done correctly and incorrectly to bring better awareness of electrical health care design. We hope to provide information and resources for those who are interested in learning more about this type of construction. Some of the doozies I have seen in the field will be highlighted in future articles. But for now, it’s back to finishing up my PowerPoint.