Managers Discuss Priorities for Codes, Standards, Regulations
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*Kevin Folsom, director of facilities and plant operations, Dallas Theological Seminary
*Skip Milton, assistant director, facilities operations, Texas Children’s Hospital, Houston
*Mike Gardner, vice president for operations, Butler University, Indianapolis
While regulations, standards, and guidelines have evolved in response to the operations and technology in facilities, one thing has not changed: complying with these guidelines is top of mind for maintenance and engineering managers. Three managers discuss their compliance priorities and offer strategies for professionals new to the industry.
Question: What are your responsibilities related to compliance activities?
FOLSOM: All of them fall under my responsibility — ADA (Americans with Disabilities Act), NFPA (National Fire Protection Association), and environmental, for example. We try to proactively deal with those through facility renewal and through planned efforts. Occasionally, the compliance issue comes to us before we have renewal. There’s a balance there that we have to work through. Pressing non-compliance issues are definitely motivators for planning renewal.
MILTON: I initially was in charge of operating the energy-management business unit. We had a change in our management team, and for about a year, I was in charge of the operations business unit, as well as the energy-management business unit. Now, I’m back to having the energy-management business unit. I still have to ensure that I comply with ASHRAE (American Society of Heating, Refrigerating and Air-Conditioning Engineers) 90 and ASHRAE 62, the Joint Commission, Texas Department of Health Services, and NFPA. Anything I do with respect to change in the environment of the hospital — airflows, air balance, and fluid flows (has to comply).
GARDNER: As vice president for operations, I have not only the facilities piece, but I also have public safety. In terms of how (responsibilities have) changed, I think the Clery Act (a U.S. Department of Education requirement related to campus security and safety) has significantly ramped up in terms of breadth and scope. With respect specifically to the facilities side of things, we, as an independent college of Indiana, entered into an agreement with the EPA (U.S. Environmental Protection Agency). We are, this fall, going to be going through an EPA peer review toward EPA compliance. Evidently, the EPA is ramping up their audits of higher education, and a legal firm and an environmental-engineering firm out East have done this (agreement) with a number of other groups of schools.
Question: What are your top regulatory priorities?
MILTON: Always Joint Commission, to maintain certification. Texas Children’s Hospital practices continuous service readiness, which means we are in constant readiness for a (Joint Commission) survey. All of the utility systems in the hospital that we maintain are maintained hourly to meet the Joint Commission requirements. We have our inspection reports. We have everything ready. Texas Department of Health Services (is also a high priority). That’s my department’s compliance requirement for infection control, air changes, and pressure relationships between spaces.
GARDNER: I don’t know enough about the new ASHRAE indoor-air-quality codes, but I know that we’re going to be moving into a new science building in our existing science-building renovation. That will be an issue. We have a fairly comprehensive asbestos survey that we continuously update as we renovate. That’s always a priority with any renovation that we have or any time we get into a major building systems repair, whether it be boilers, heating-distribution lines, etc.
FOLSOM: They’re all important. We don’t necessarily question the importance of regulatory priorities. The challenge comes with timing and feathering them into facility renewal so we can get full life-cycle value of a revised component.
Question: What types of regulations and guidelines demand more time and resources to comply?
GARDNER: I think with respect to ADA — this isn’t the right way of saying it — we’ve been a victim of our own success. We’ve paid a lot of attention to ADA compliance, and I think as we get new students interested in Butler University, we have a greater number of individuals with challenges. That has forced us to ramp up our efforts for individuals (such as) blind students. Developing a snow-removal policy, for example, to ensure that blind students have access from their residence halls to the food-service space and then on to classroom buildings from there. We’ve had to change our way of doing business.
FOLSOM: ADA would be the most comprehensive facility-related (activity) on campus because it involves so many other planners and leaders. But a really close second would be environmental as it relates to energy use and recycling because it affects the behaviors of every single person on campus.
MILTON: Everything that Joint Commission requires is absolutely focused on patient care and safety. We do devote a lot of time to compliance, but compliance should be something that we are doing (as part of doing business).
Question: What resources or strategies do you use to keep up on the latest standards and guidelines?
MILTON: I’m a member of ASHE, which is the American Society of Healthcare Engineering. I’m a member of ASHRAE. ASHE is a great source of information. ASHE stays in touch with the Joint Commission. They provide us with information on upcoming changes to the standards. They do a great job of ensuring the information is disseminated accurately to all of their members.
FOLSOM: Well, first you need to understand how the system works. The government relies on private industry — manufacturers, buyers, etc. — and non-profit organizations — NFPA, ASHRAE, etc. — predominantly for codes and standards development. While the government sets the course for big-picture (goals), they’re tapping into manufacturers and buyers to sit on committees to develop and refine these codes and standards. Sitting on a committee is the most effective way to stay on the cutting edge. However, the committee members are required to pay for all their own travel and time to participate, which can be very costly and time-consuming.
GARDNER: On the maintenance and operations side of things, our safety committee does a really good job of keeping in touch with things. We also have an environmental health and safety office within public safety that monitors and manages (new developments).
Question: What is the role of maintenance and engineering staff in complying with regulations and standards?
FOLSOM: They’re typically on the whip’s end. By the time a new or updated code comes to them, all the momentum cannot be stopped. They simply have to deal with it and try to help their leadership understand why they need to spend time and money to comply.
MILTON: They perform the inspections, and they perform the maintenance. The documentation is developed by them. That documentation is codified and maintained on record for anyone to see. We have all maintenance records on all pieces of equipment going years back, particularly generators. We have a 96-hour requirement to have emergency power for the hospital in case of an event. So we diligently test generators, fire pumps and all the safety systems.
GARDNER: In our maintenance shops, we have to maintain OSHA (Occupational Health and Safety Administration) compliance, and they do a good job of worker safety within the safety-committee programs that we have. We have confined spaces that we have annual training on. We have blood-borne pathogens that we have annual training on.
Question: For managers new to the industry or to a position, what first steps should they take related to compliance?
GARDNER: A good conversation with the human resources office to know what’s out there (is important). From a building construction and maintenance standpoint, I think a good meeting with an architecture and/or engineering firm to know what the issues are (is important). Architects and engineers by definition have to stay on top of ADA, building codes, NFPA, National Electric Code, etc. For a person who’s new in facilities management, they don’t necessarily have to know everything (related to compliance), but they need to have a good understanding of what those compliance issues are and how they impact day-to-day operations of a large facility.
MILTON: You always have to comply with your authority having jurisdiction, whether it’s the building-inspection department, the fire marshal or whoever that (authority) may be. That’s the ultimate authority that you have to maintain compliance with. Wherever you are located — and it depends on the business you’re in — you have to find out who you need to comply with.
FOLSOM: Spend time reading all those free publications, and align with an association that most closely aligns with your type of industry.