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Ready, Set, ICRA!

One of the more frequently recurring questions/concerns/vulnerabilities in my travels relates to when it is appropriate to do a (and I will use this term collectively) pre-construction risk assessment, inclusive of all the usual suspects: Noise, vibration, system shutdowns, etc. Clearly (and I know you know, because I see you knowing), the pieces of this puzzle that can get you into the most trouble in most rapid fashion are those relating to infection control and interim life safety measures.

My (moderately) tongue-in-cheek response to any questions about “when” you would employ has typically been “always” (I remember the first time the question came up at a conference and my response was the same—and I’m sticking to my guns on this). My general philosophy as it relates to risk assessments is that we always assess for risk and we implement only what is necessary to manage those risks.

At any rate, as your “homework” for this week (and I would very much like to hear how you folks are parsing this), please look over the list below and figure out where you’ve placed the dividing line for your risk assessment process (basically, where you’d do an assessment and where you wouldn’t), particularly as a function of the Chicago requirement to “when planning for demolition, construction, renovation, or general maintenance [my bolding], the hospital conducts a preconstruction risk assessment for air quality requirements, infection control, utility requirements, noise, vibration, and other hazards that affect care, treatment, and services.” I firmly believe that this balancing act is going to be become a key component of survey oversight. (I would be more than happy to be wrong about this, but somehow I think things are moving in this direction.)

So please look over these perky little definitions and let me know your thoughts: Categories of Rehabilitation Work. The nature and extent of rehabilitation work undertaken in an existing building. Repair. The patching, restoration, or painting of materials, elements, equipment, or fixtures for the purpose of maintaining such materials, elements, equipment, or fixtures in good or sound condition. Renovation. The replacement in kind, strengthening, or upgrading of building elements, materials, equipment, or fixtures, that does not result in a reconfiguration of the building spaces within. Modification. The reconfiguration of any space; the addition, relocation, or elimination of any door or window; the addition or elimination of load-bearing elements; the reconfiguration or extension of any system; or the installation of any additional equipment.* Reconstruction. The reconfiguration of a space that affects an exit or a corridor shared by more than one occupant space; or the reconfiguration of a space such that the rehabilitation work area is not permitted to be occupied because existing means of egress and fire protection systems, or their equivalent, are not in place or continuously maintained. Change of Use. A change in the purpose or level of activity within a structure that involves a change in application of the requirements of the Code. Change of Occupancy Classification. The change in the occupancy classification of a structure or portion of a structure. Addition. An increase in the building area, aggregate floor area, building height, or number of stories of a structure.

I got those travelin’ code compliance blues…

One occupational hazard (or probably more correctly an occupational preoccupation) I find is a constant awareness of code violations wherever I go. It seems that there are an awful lot of airports, concert venues, and the like that are engaged in upgrading facilities, and often, there are plenty of opportunities to look up into the areas above the ceiling envelope. Now I absolutely understand why healthcare gets a lot of scrutiny relative to concerns of life (and general) safety—far too many folks incapable of self-preservation to put them at risk. But as I wander around looking at stuff, I’m thinking we’re dealing with a whole mess of folks (euphemistically called passengers) in almost a collective daze, mesmerized by their cell phones, etc., who would be difficult to manage in the event of an emergency (I also have no doubt that the folks in charge in these various venues have already considered this and have plans in place).

At any rate, just this morning, I was privy to a number of open junction boxes, cabling attached to sprinkler piping, the odd penetration (don’t have the life safety drawings to hand, so I can’t say), in areas just outside of the main construction zone(s)—and no, I didn’t see a posted infection control risk assessment, but it does make one wonder whether it might not be such a bad thing. Presumably things are well-isolated from an HVAC standpoint, though certainly less so from a noise standpoint, but the whole thing does periodically give one (or at least gives me) pause. It is generally acknowledged that healthcare is a heavily regulated industry, and while I think we could certainly engage in extensive debate about the prioritization of risk when it comes to some of the minor imperfections that have become so much a part of the typical survey report, I don’t know that I would alter the accreditation process (which is kind of self-serving as helping folks manage the process is how I make a living).

In the end, this probably a little ado about nothing, but sometimes one is charged with channeling one’s inner curmudgeon…

One item as we close out this week, Health Facilities Management is soliciting input on the operational challenges relating to various monthly inspection and testing items (exit signs, elevator recall) as a function of (more or less) “if you already have a reduced resource pool with which to work, how are you going to manage these.” Check out an article discussing this in general, which includes links to the surveys for each area of consideration. ASHE has been a very effective advocate over time when it comes to compliance activities, so I think it would be good to make your voice heard.