Compliance Hot Buttons
Managers face a dizzying array of regulations, standards and codes designed to make institutional and commercial facilities more efficient, more comfortable and safer. And the larger the organization, the greater the challenge facing maintenance and engineering managers who must ensure their departments and facilities are in compliance.
Beyond that, regulations and codes continue to evolve and expand to meet the changing needs of occupants and workers, as well as the advance of technology.
Managers can keep their departments and facilities ahead of the curve by addressing hot-button compliance areas, including facility access, worker safety, indoor air quality (IAQ), and hazardous materials management. While these areas are not the only ones managers need to monitor, they are among the most active.
For a list of web resources on these issues, see the sidebar below.
The 2004 revisions of the Americans with Disabilities Act access guidelines (ADAAG) are among the biggest compliance issues facing managers because they affect so many building areas and components. For greater consistency, the ADAAG revisions incorporate updated guidelines under the Architectural Barriers Act governing facilities designed, built, altered or leased with federal funds.
The revisions provide better harmonization with building codes and industry standards, and they take into account new technology in facilities. The guidelines address access in new construction and alterations, and they contain scoping provisions describing areas of facilities that must comply, in addition to technical specifications that spell out compliance guidelines. Prominent areas of revision include:
- the accessibility of circulation paths within work areas that are sizable, meaning 1,000 square feet or more
- enhanced scoping for public entrances, van parking, passenger loading zones, stairways, and telecommunications devices at pay phones for persons with hearing or speech impediments
- reduced scoping for unisex toilet rooms located at a single location —one-half instead of all — and for wheelchair spaces in large assembly areas.
Regulators, along with developers of standards and codes, have taken a much closer look at all areas of facilities in order to improve their operations. This trend is especially true for fire safety and energy efficiency.
In December 2004, the city of Chicago responded to a fatal fire at a county office building by enacting an ordinance requiring installation of sprinklers in most existing commercial high-rise buildings. New York City and other cities with older, high-rise structures also are revisiting their building codes.
Fire safety in colleges and universities has come under greater scrutiny, also in light of a series of fatal fires in dormitories. In January, Rep. Stephanie Jones (D-Ohio) introduced H.R. 128, which would establish a demonstration incentive program to promote installation of fire-sprinkler systems or other fire-suppression or -prevention technology in qualified student housing and dormitories.
The National Fire Protection Association (NFPA) also has taken several steps that will affect institutional and commercial facilities. In 2004, it proposed a revision of NFPA 90A, Standard for the Installation of Air Conditioning and Ventilating Systems, that would increase the required testing of dampers from every four years to annually.
Also, NFPA in January called for facility managers and owners to incorporate the needs of people with all types of disabilities into emergency planning. The group previously called for all nursing homes to be equipped with fire sprinklers.
In the area of energy efficiency, on July 1, 2004, the deadline passed for compliance with a federal law that mandates states to upgrade energy codes for commercial buildings to meet or exceed ASHRAE/IES 90.1-1999 standards. As of May 2005, only three states — Alaska, Mississippi, and South Dakota — have not met the requirement, according to the U.S. Department of Energy.
Workers and Occupants
Recent changes in codes and standards also sought to enhance worker safety and comfort in key areas.
On the safety front, standard-setting organizations paid a great deal of attention to the issue of dangers posed by electrical systems. NFPA’s 2005 National Electrical Code, for example, contains a number of important revisions, including:
- new and revised rules for ground-fault circuit interrupters
- new requirements for arc-fault circuit interrupters
- reorganized electrical calculation requirements in Article 220: Branch Circuit, Feeder, and Service Calculations
- new requirements for identifying underground branch-circuit and feeder conductors.
NFPA devoted increased attention to dangers posed to workers by arc flash, arc blast, shock and electrocution. The latest revision of NFPA 70E addresses the gamut of electrical safety issues, from maintenance to work practices, special-equipment requirements, and installation. The standard’s revised definitions clarify safety issues such as arc rating, incident energy and restricted-approach boundary. Also, NFPA and the Institute of Electrical and Electronic Engineers said they are working together to support research to increase understanding of arc-flash phenomena, which injures more than 2,000 people per year.
Also on the safety front, the American Society of Heating Refrigeration and Air Conditioning Engineers (ASHRAE) published its 2004 standard on refrigeration safety. ANSI/ASHRAE 15-2004, Safety Standard for Refrigeration Systems, includes clarifications to the application of safety relief valves for pressure vessels. It also covers the addition of flammable refrigerant restrictions in comfort-cooling applications omitted from the 2001 standard.
Finally, in the area of indoor comfort, ASHRAE updated its IAQ standard, ANSI/ ASHRAE Standard 62.1-2004, Ventilation for Acceptable Indoor Air Quality. Among the major changes is the revision of the ventilation rate procedure to reflect recent information on the impact of ventilation on IAQ and to clarify adjustments necessary for space-air distribution and system efficiency of multi-zone recirculating systems.
Growing interest in environmentally friendly products, processes and facilities has shown itself in standards, regulations and guidelines that outline strategies managers can implement in their “green” efforts.
A number of organizations have adopted green mandates designed to minimize the environmental impact of facilities. In June 2004, for example, the 10-campus University of California system adopted a green-building standard that tightens building-design standards, along with a clean-energy policy that sets goals for producing and buying clean energy.
Health care facilities came in for special consideration in November 2004 with the publication of the Green Guide for Health Care from the U.S. Green Buildings Council and the American Society for Healthcare Engineering. The guide integrates environmental and healthy practices into the planning, design, construction, operation and maintenance of facilities.
Finally, water shortages and the resulting rise in the cost of water have prompted states and municipalities to enact ordinances and rules limiting water use in plumbing and cooling systems and on landscapes. For example, as of January, all urinals installed in Arizona state buildings must be waterless, and Oregon recently approved a rule allowing the use of waterless urinals in government facilities.
The U.S. Environmental Protection Agency (EPA) also is entering this arena. Following a series of meetings with interested parties in 2004, the EPA is in the process of developing and implementing a national, voluntary program for promoting water-efficient products.
New compliance issues seem certain to appear as regulatory bodies and code-setting organizations take an even closer look at the impact of facilities on occupants and the environment. Taking action now can help managers and their organizations stay ahead of the compliance curve.
HazMat and the EPA
Red flags have popped up in education and health care facilities across the nation in the last five years. If they haven’t appeared in your facilities, they soon might.
— Dan Hounsell
The web sites listed below offer additional compliance guidance, resources and contacts.
— Dan Hounsell