Hospitals' non-structural quake mandate: A primer
A 1994 California law required that hospital buildings meet strict standards so that their buildings can withstand major earthquakes.
The law consists of two parts. First, hospitals must fix or replace buildings with structural problems that could cause them to collapse in a quake.
Second, plumbing, electricity and other non-structural features must be sturdy enough that hospitals can keep operating after the quake.
Many hospitals in the state missed deadlines for making non-structural fixes, according to records from the state Office of Statewide Health Planning and Development. Some hospital administrators say that they cannot afford to make those fixes, and some have asked for and received deadline extensions.
The Center for Health Reporting asked state regulators why the delays occurred and what’s ahead.
Q: What is the history of the state’s non-structural rating system for hospitals, and why is it separate from the system for judging the structural strength of hospital buildings?
A: Structural Ratings or Structural Performance Category (SPC) are ratings for the actual building frame. Non-structural ratings or Non-Structural Performance Category (NPC) pertain to the seismic compliance of electrical, mechanical, plumbing and fire protection systems.
The combination of the two categories (structural and non-structural) determines the overall building performance level. Buildings are placed in the appropriate performance level based on their attributes or their vulnerabilities based on a seismic evaluation.
Both the SPC and NPC ratings were created under Senate Bill 1953, which was enacted in 1994, and was established to provide that by 2030 California hospitals must be capable of remaining operational after seismic event.
Q: How do you judge the non-structural sturdiness of a hospital?
A: The non-structural or NPC ratings are based on the expected performance of non-structural systems and equipment critical to patient care.
The first four ratings, NPC-1 through NPC-4, require that nonstructural components and systems in critical care areas must be anchored and braced so they don’t become falling hazards and threat to life in the event of an earthquake or other natural disaster.
NPC-5 compliance requires the building must maintain sufficient water, power, and fire and life safety independence for at least 72 hours thereby allowing the facility to remain operational after an earthquake.
The definitions of the five NPC ratings:
- NPC-1: In these buildings, the basic systems essential to life safety and patient care are inadequately anchored to resist earthquake forces. Hospitals were required to brace the communications, emergency power, bulk medical gas and fire alarm systems in these buildings by January 1, 2002.
- NPC-2: In these buildings, essential systems vital to the safe evacuation of the building are adequately braced. The building is expected to suffer significant nonstructural damage in a strong earthquake.
- NPC-3: In these buildings, nonstructural systems are adequately braced in critical areas of the hospital. If the building structure is not badly damaged, the hospital should be able to provide basic emergency medical care following the earthquake.
- NPC-4: In these buildings, the contents are braced in accordance with current code. If the building structure is not badly damaged, the hospital building should be able to function, although interruption of the municipal water supply or sewer system may impede operations.
- NPC-5: These buildings meet all the above criteria and have water and wastewater holding tanks—sufficient for 72 hours of emergency operations—integrated into the plumbing systems. They also contain an on-site emergency system and are able to provide radiological service and an onsite fuel supply for 72 hours of acute care operation.
Q: When are hospitals required to meet these deadlines?
A: The 1994 law requires the Office of Statewide Health Planning and Development to consult with the Hospital Building Safety Board to identify the most critical non-structural systems and establish timeframes for upgrading these systems.
As a result, hospitals were to comply with NPC-2 requirements by 2002 and NPC-3 requirements by 2008. However, subsequent legislation revised interim deadlines for NPC compliance dependent upon the seismic risk of the area surrounding the hospital.
Q: So the original deadlines required hospitals to meet NPC-2 standards by Jan. 1, 2002; NPC-3 standards by Jan. 1, 2008; and NPC 4 and 5 standards by Jan. 1, 2030?
A: Correct. Hospitals in high seismicity regions are allowed to request an NPC-3 extension up to 2020, where hospitals in lower seismicity regions are allowed to request an exemption to NPC-3 up to 2030.
Q: Does the state have current records on the compliance of hospitals statewide? The latest report we could find is dated December 2009.
A: The law does not require hospitals to report their NPC compliance. A large number of hospitals are in the midst of completing their NPC compliance, but have not requested an upgrade or review by OSHPD in their NPC levels.
Q: Has there been any discussion in Sacramento of stiffening NPC rules or moving up deadlines?
A: State law prioritized structural safety for the purpose of reducing injuries and loss of lives resulting from buildings which pose a risk of collapse during an earthquake.
Q: How does the cost of non-structural work compare with making structural fixes such as replacing or retrofitting buildings?
A: NPC-3 work is very costly because of the disruption to services in the critical care area of hospitals, such as operating rooms, emergency departments, intensive care units, neonatal intensive care units, etc. NPC work also triggers upgrading the affected areas to comply with accessibility standards for persons with disabilities. In many cases, the NPC work can be more costly that the structural work.