Engineers and designers often work on projects in locations and jurisdictions that may have unique requirements specific to that region. To better provide engineering solutions, it is of utmost importance that we understand the background of why additional requirements are being implemented.

As plumbing engineers or designers, we may at times question why other disciplines implement systems that don’t make sense to our discipline. One example is when the structural engineer designs a mat slab, making it difficult for the routing and future modification of plumbing piping. 

Once we understand the rationale behind the requirements, however, it becomes much easier for us to move forward with the plumbing systems design with an open mind and a focused purpose. Take OSHPD, for example.

What is OSHPD?

The 1971 Sylmar earthquake, also known as the San Fernando Earthquake, had a magnitude of 6.6 on the Richter scale. Four hospitals were severely damaged, two of which had collapsed, killing 47 people. In response to this event, the Alfred E. Alquist Hospital Seismic Safety Act was enacted, and the Office of the Statewide Health Planning and Development (OSHPD) was then created to be the statewide office overseeing the construction of healthcare facilities in California. 

According to the California Geological Survey, at least 15,000 seismic faults can be found in the populous state. California accounts for two-thirds of the nation’s earthquake risk. The next big earthquake is not a matter of if, but when. 

In 2021, OSHPD was changed from a state office to a department and renamed the Department of Health Care Access and Information (HCAI). The California building code regulations, such as the California Plumbing Code, continue to use OSHPD to define the types of facilities. 

In a catastrophic earthquake, buildings and the surrounding infrastructure in the community can be damaged. And it is not only infrastructure, but first responders can be victims, too. The goal is for healthcare buildings to be self-reliant and able to maintain their operations and services during and after the disaster. This is why it is vital that systems and infrastructure in these buildings be designed in strict accordance with the HCAI, both for their function and for the protection of those inside.

During the COVID-19 pandemic, OSHPD (now HCAI) enlisted experts to create an Emergency Design Task Force, including but not limited to design professionals, clinicians, facility personnel, and others. These experts were then tasked with identifying the varying needs for multiple emergencies, such as pandemics, wildfires and others. 

There are a few terminologies worth mentioning. It is not our intent to dive into the details at this time, but simply to highlight the vast amount of information associated with OSHPD. 

One such term is the Structural Performance Category (SPC), a value that is assigned to all general acute care hospitals within the state of California and is based on the building’s risk of collapse during a strong earthquake. The SPC ratings range from 1 to 5, with 1 being very likely to collapse and 5 being the most likely to withstand a strong earthquake and be in a position to continue serving the community. 

The Non-Structural Performance Category (NPC) assesses the continued operation of building systems and equipment critical to patient care after an emergency. The HCAI uses the term Code Application Notices (CANs) to interpret various sections of the California building codes. Currently, only one CAN relates specifically to the California Plumbing Code (CPC), which is CAN 5-310.9, relative to requirements for overhead piping. 

Other terms include Policy Intent Notices (PINs), relating to OSHPD’s policy on specific subjects. One example is PIN 62, which explains the processes and procedures for the Preapproval of Manufacturer’s Certification program. Another example is PIN 55, which similarly explains the processes and procedures for the Special Seismic Preapproval Program and other related issues to obtaining special seismic certifications.

OSHPD vs. NFPA 99 categories

Engineers and designers outside of California who are not familiar with OSHPD might have a misconception that the OSHPD levels are the same as or interchangeable with NFPA 99, Health Care Facilities Code categories. These two programs are not intended to be interchangeable. 

Requirements in NFPA 99 are based on systems risk categories, while OSHPD levels are for building classification based on the type and level of care being provided. These classifications and categories are as follows:

• OSHPD 1: General acute hospitals (I-2 occupancy);

• OSHPD 2: Skilled nursing facilities (I-2.1 occupancy);

• OSHPD 3: Outpatient clinics (B occupancy);

• OSHPD 4: Healthcare environments within correctional facilities (I-3 occupancy);

• OSHPD 5: Behavioral health centers (I-2 occupancy);

• NFPA 99 Category 1: Risk that equipment or system failure likely results in major injury or death;

• NFPA 99 Category 2: Risk that equipment or system failure is likely to cause a minor injury;

• NFPA 99 Category 3: Equipment or system failure is not likely to cause an injury but may result in some temporary discomfort.

OSHPD requirements impact on plumbing systems

Understanding the classifications and risk categories gives designers and engineers a better sense of the associated impacts on the plumbing system’s design. The following are some examples of OSHPD classification requirements and associated risk factors specific to plumbing systems in OSHPD buildings. 

To support the mission of being self-sustaining during and after an earthquake, an emergency water supply and drainage storage are required in acute care hospitals (OSHPD 1). As a result, the CPC requires acute care hospitals to have on-site water storage tank(s) to supply water and holding tank(s) to collect the sewer waste in the event of an emergency. Both tanks are required to be sized for 72 hours of continued operation during emergencies. 

The requirement for sizing the tanks to accommodate 72 hours of continuous operation often intimidates plumbing engineers and designers, as the tank size(s) can become astronomically large. However, OSHPD has been on top of this and identified some instances where there is not enough space to accommodate, such as large tanks. 

There is an exception provided in the CPC, using a transportable water hookup if first approved by the office and the licensing agency. In lieu of 72 hours, the water tank can be sized to support 24 hours of operation without replenishment based on an approved water rationing plan. The minimum size of the water tank and the sanitary holding tank is 5,000 gallons.

Other examples of variations between OSHPD and other codes are as follows:

• OSHPD does not permit change Polyvinyl Chloride (PVC) or Acrylonitrile Butadiene Styrene (ABS) piping installation for waste, vent and storm piping. As the building’s foundation design considers earthquakes, it is not uncommon to see a robust structural design, such as a mat slab. Without understanding the need for a robust design, plumbing engineers or designers often find this design exaggerated and a nuisance when routing the piping. 

• While the CPC requires a 10-foot minimum vent distance from any outside air intake, the OSHPD requirement is more stringent with a 25-foot minimum distance. This is also not unique to OSHPD, with the Facilities Guideline Institute requiring the same 25-foot minimum distance. 

• OSHPD calls for each domestic water riser or branch to have an accessible sectionalizing valve in the hot and cold water system. Additionally, new or renovation projects also need water disinfection. Chlorinated Polyvinyl Chloride (CPVC) is not permitted for applications under the authority of OSHPD. Cross-linked Polyethylene (PEX) is allowed with 30-day UV protection.

The code requires that the plumbing schedules, as shown in Figure 1, shall clearly indicate the equipment to be on essential power. In the event of a power outage, the following equipment will have essential power.

• Domestic water booster pumps;

• Domestic hot water circulating pumps;

• Sewage ejector pumps;

• Sump pumps and drain pumps;

• Domestic water heating equipment and controls;

• Fuel pumps;

• Grease removal devices requiring electrical power;

• Domestic hot water high-temperature alarm. 

From the outside, HCAI requirements for healthcare might be excessive compared to traditional projects. However, these regulations are necessary to safeguard critical infrastructure. HCAI has done a tremendous job providing the data and information required on its website. In addition to this, HCAI also hosts and continues to host a series of webinars to inform design professionals. 

We all play an essential role in the design of building systems. This becomes more amplified in critical care buildings that provide services to our community. We all need to be supportive of each discipline in meeting the intent of these codes and standards. 

When a significant disaster strikes, one unifying symbol is the building that still stands, along with the continued operation of the first responders and healthcare professionals providing services, even though the external infrastructure around the facility may have been damaged.

Lowell Manalo is the plumbing discipline leader for the western region at SmithGroup. He is a member of the American Society of Plumbing Engineers and has more than 20 years of experience designing plumbing systems for a variety of building types.