What about Day 2? Transitioning from Construction to Operations

By David L. Stymiest, P.E., CHFM, FASHE (at ASHE 46th Annual Conference, August 2009)
  

Introduction
Construction projects have standard approaches and processes. Facility operations, management and compliance also have standard approaches and processes. Many hospitals lack a solid process of transitioning from a construction project to operations and compliance. This affects the staff’s ability to manage systems and puts the hospital at risk of noncompliance with codes, standards, rules and regulations. This paper is intended to bridge the gap between construction and operations, providing an overview of the facility operations, management, and environment of care (EC) compliance issues and needs for Day 2 – the day after a facility opens.
  
Changing activation and turnover approaches
Early approaches to facility activation and turnover focused on the logistics of acquiring and installing new equipment and furniture, along with the facility to house it. When the facility neared completion, teams would start scheduling the building turnover sequences - department moves and patient moves.
  
Current thinking about new facilities involves much more than what must fit into it and how the facility will work. Now healthcare administrators might decide that the new facility must resolve concerns about existing service delivery shortcomings. Furthermore, they want the new facility to incorporate best practice operational models.
  
Read entire article here: What about Day 2? 

Opening Day - Transitioning from construction to survey-ready operation

Opening Day

Transitioning from construction to survey-ready operation

This article first appeared in the May 2010 issue of HFM Magazine.

By David l. Stymiest, P.E., FASHE, CHFM

Construction project turnover time is hectic. Facility activation and move-in are usually foremost and it is often difficult to get all of the compliance work done on time. Lacking a solid process for transitioning from construction to operations and survey-ready compliance at occupancy can put a hospital at risk during an early survey.

Click here to go to article at the HFM Magazine website.

Compliance News: Transitioning from Construction to Survey-Ready Compliance - Part 3

By David Stymiest, PE, FASHE, CHFM

Part 1 appeared in the September/October 2009 issue of Compliance News.

Part 2 appeared in the November/December 2009 issue of Compliance News.

Schedules (policies and procedures, forms, lists, etc.) would have to be established for the following types of items (listing is not all-inclusive):

• Fire drills, safety rounds, safety monitoring and security monitoring of EC

• Ongoing testing, inspections and maintenance

• Inspections of all ‘previous’ Building Maintenance Plan (BMP) components – (smoke and corridor walls; fire, smoke and corridor doors; exit signs and egress lights, trash and linen chutes, grease producing devices, and means of egress free of blockage such as ice and snow)

• Inspections of fire walls

• Inspections of fire and smoke dampers, including the special one-year inspection

• Fire alarm systems, devices and equipment; fire protection systems, devices and equipment; fire extinguishers

• Eyewash stations

• Emergency power, medical gas and vacuum, and other systems

Labeling would be expected for hazardous materials and waste, utility system controls to facilitate partial or complete emergency shutdowns, medical gas and vacuum system valves, both permanent and temporary signage, and maps if they are used. Standard labels may not meet all of the AHJ requirements.

Project record documentation that meets the AHJ requirements for mapping of utility systems would be acceptable if it is available during survey. The utility systems include normal and emergency power, steam, chilled water, domestic water, sanitary piping, fire protection, medical gas and vacuum, fire alarm and emergency communications, telecom, and any other systems included in the Utility Systems Management Plan scope.

Utility maintenance documentation is required to be accessible during survey. This includes documentation generated both internally and by outside services. The organization needs to have processes (and contract provisions) to obtain, store and access all such documentation during both equipment failures and unannounced surveys. The decision process for the types of maintenance (preventive, predictive, reliability-centered, corrective, or metered) to be performed on all new equipment should also be documented and available during survey.

Similar requirements apply to maintenance documentation for other types of equipment, including equipment serviced by both internal biomedical engineering departments and external service organizations.

Compliance News: Transitioning from Construction to Survey-Ready Compliance - Part 2

By David Stymiest, PE, FASHE, CHFM

Part 1 appeared in the September/October 2009 issue of Compliance News.

The management plans, policies and procedures for renovations or expansions on an existing campus should reflect the impacts of the project on the existing facility. These impacts can include changes to facilities and areas, changes to infrastructure equipment and systems, new operational and infrastructure-related processes, and department locations or relocations.

Risk assessments may be required for safety, security, fire, and where the facility intends to permit patient smoking. Additional risk assessments may be done for input to the Emergency Operations Plan (EOP) and hazard vulnerability analysis (HVA), as well as hazardous chemicals, hazardous energy sources (including radiation, lasers, batteries), hazardous medications, hazardous gases and vapors, and radioactive materials. Other types of risk assessments apply to Life Safety Code™ deficiencies and Interim Life Safety Measure (ILSM) documentation, preconstruction risk assessments (PRA), and infection control risk assessments (ICRA).

Some of these risk assessments might be used to establish written inventories in the following areas as subsets based upon risk:

• Hazardous materials and waste

• Medical equipment (evaluation prior to initial use)

• Operating components of utility systems (evaluation of new component types prior to initial use)

Many of the systems and equipment, including life safety building features or components, must be commissioned and/or tested prior to initial use. It is not practical to list all of these item types here. Presumably project record documentation that includes all of the information required by the AHJ would be acceptable as long as it is available during survey.

The Project Record Documentation can be helpful in providing the complete list of components for ongoing testing provided that it is available early enough to be useful. The following systems and components require ongoing testing, and there would have to be policies, procedures, schedules, requirements, and forms that detail this testing:

• Fire safety equipment, fire safety building features, fire alarm, fire protection and sprinklers, fire extinguishers and extinguishing systems

• Smoke and fire dampers, air handling unit shutdown, elevator recall, etc.

• Door operation, exit door and corridor door resistance

• Medical equipment on the inventory

• Operating components of utility systems on the inventory

• Emergency power, medical gas, and vacuum systems and equipment

• Pathogenic biological agents in cooling towers, hot water and cold water systems

• Temporary systems required for ILSM

Project testing and certification reports would have to be on file and easily accessible during unannounced surveys. Types of project-related testing and certification reports could include, but are not limited to, the following:

• Contractor documentation and commissioning (Cx) agent documentation

• Documentation of typical AHJ inspections and approvals: Local, State, NRC, DOT, FAA, etc.

• Helipads and separator tank, elevators, fuel tanks, pressure vessels, fire protection water systems, lightning protection systems

• Building automation or building management system

• Low voltage systems, both medical and otherwise

Compliance News: Transitioning from Construction to Survey-Ready Compliance - Part 1

By David Stymiest, PE, FASHE, CHFM

Transitioning from a construction project to survey-ready compliance at occupancy is challenging at best. Facility activation and move-in are usually foremost and it is often difficult to get all of the compliance work done on time. This can put the hospital at risk during an early survey. This series of articles will discuss the major environment of care (EC) compliance issues and needs for Day 2 – the day after a facility opens.

Proactive compliance recognizes that “continuous compliance” could include an unannounced accreditation survey shortly after occupancy – and some hospitals will tell you that this has occurred. Rather than finding what is wrong and fixing it, proactive compliance involves determining what is needed and when it is needed for compliance, identifying what is missing in time to obtain it, and then thoroughly managing this process.

Unfortunately, many construction projects reflect one or more of the following conditions about some of the compliance-related project record documentation:

• The work never gets done.

• The work gets done but is not accurately documented.

• The work gets done and gets accurately documented, but that documentation does not meet

the AHJ’s rules.

• The work gets done, gets accurately documented, the documentation would be acceptable to

the AHJ, but it does not arrive on time for an early AHJ survey.

It is necessary to identify all of the required documentation, and who on the project team is responsible for each item. If documentation is not contractually required in a format that will be survey-ready, chances are that it will not be survey-ready without more work by the Owner. And that extra work is not always completed before occupancy because of the conflicting priorities associated with opening and occupying the project area. The best situation occurs when the AHJ’s compliance requirements related to the initial inspections, testing, documentation and training are factored into project construction documents – with the intent to ensure that project record documents are survey-ready when received on time to support an early survey. This approach leverages already scarce resources by assuring that facility personnel do not need to spend time or funds redoing, to make survey-ready, what the Contractor has already prepared.

The following types of EC compliance documentation should be ready and easily retrievable during a survey on Day 2:

• Project record documentation: test and inspection reports, permits, licenses, certifications, documentation of all required “testing prior to initial use,” AHJ approvals, etc.

• Documentation for the new facility/expansion: inventories, management plans, policies and procedures (P&Ps), risk assessments, training records, maintenance decision processes, inputs into P&Ps and maintenance management systems from O&M manuals, evaluations, lists, spreadsheets, databases, schedules and forms for ongoing required drills, exercises, tests, inspections and maintenance, and all required Emergency Operations Plan (EOP) documentation.

• Life Safety Assessment™ and accurate updated life safety plans, eSOC™, any Plan for Improvement items, and performance-based options for new construction or equivalencies for existing construction.

• Personnel protective equipment (PPE), spill kits, monitoring equipment and other supplies.

• Mapping of utility systems and labeling for critical utility disconnects.