I recently heard a comment from a plumbing designer concerning the California Plumbing Code (CPC), particularly in relation to the California Department of Health Care Access and Information (HCAI) formerly known as the Office of Statewide Health Planning and Development (OSHPD) standards.

The designer remarked, “I have implemented similar systems for many years, and I am confident that what I provide is effective. These OSHPD requirements are not necessary.” This is indeed an interesting comment. It raises the question: Are these additional documents, standards and requirements truly beneficial or are they not?

Let's begin with the fundamentals: what exactly is a code? Codes represent the minimum standards we must adhere to. They exist to ensure that systems meet specific benchmarks and maintain safety. However, it's crucial to understand the code relevant to our specific project and avoid a one-size-fits-all approach, blanket statements or generalizations. It may be beneficial to understand why OSHPD was established initially. Earthquakes are frequent in California, and the catastrophic San Fernando earthquake in 1971 caused significant damage to infrastructure, including hospitals. Consequently, lessons have been learned and considered to ensure that hospitals remain operational and continue to provide services to the public after an earthquake.

Looking at the CPC code requirements as it pertains to OSHPD, it is important to know if the clinic is a licensed clinic that follows the Health and Safety Code. For this example, let’s say it is. The clinic then needs to adhere to the HCAI’s OSHPD 3 Clinics requirements. It can be intimidating with all the abbreviations, etc., but it exists to aid the engineers and designers in understanding what systems and features to provide. It is important that we recognize all the supporting documents such as Code Application Notices (CANs) and Policy Intent Notice (PIN), as this helps with design decision-making. OSHPD’s CANs and PINs are not exclusively plumbing and covers the entire code in general, including the California Building Code (CBC), California Electrical Code (CEC) and California Mechanical Code (CMC) to name a few.

Code Application Notices (CANs) are supplemental information that provides an interpretation of the California Building Standards Code. One example is CAN 5-310.9 which refers to CPC section 310.9. The CPC section 310.9 calls to provide special precautions for drainage piping over operating rooms, nurseries, food serving facilities and other sensitive areas. However, CPC does not define what these special precautions consist of. CAN 5-310.9, however, provides some explanations of acceptable “special precautions.” Special precautions such as the use of Heavy-duty four-band type couplings that are properly supported or restrained to limit joint separation and the use of drain troughs under the piping.

With the CPC clearly noting ABS and PVC pipe materials as not allowed in OSHPD buildings, plumbing engineers and designers can more easily defend why the contractor cannot substitute ABS or PVC in lieu of cast-iron drainage pipe. It’s now become a simple answer — it is against code.

Policy Intent Notice (PIN) includes a list of issued HCAI’s policies on specific topics. One example is PIN: 62 which is about OSHPD Preapproval or Manufacturer’s Certification (OPM). Although following the OPM is a voluntary program, it shortens the process for receiving deferred approvals such as non-structural components support and attachments.

For engineers and designers not used to designing buildings under HCAI, this may seem too much and intimidating but, in my experience, it would be better if other local jurisdictions outside of California had a similar program that informs our understanding of the authority Having jurisdiction’s (AHJ) stance or interpretation on topics. Now, let us look at a few examples of the California Plumbing Code requirements specific to OSHPD 3 Clinics.

The CPC prohibits the use of Acrylonitrile Butadiene Styrene (ABS) and Polyvinyl Chloride (PVC) for drainage piping. These pipe materials are normally the first to be looked at by a contractor when it comes to cost-cutting. With the CPC clearly noting ABS and PVC pipe materials as not allowed in OSHPD buildings, plumbing engineers and designers can more easily defend why the contractor cannot substitute ABS or PVC in lieu of cast-iron drainage pipe. It’s now become a simple answer — it is against code. This is something that I mentioned in last year’s August column, “Defending your hospital system design from VE and Cost-Cutting.”

It is very common to see water heater redundancy in hospitals across the nation, whether using IPC or UPC. When it comes to clinics, however, a single water heater is the norm outside of California. According to the CPC, two water heaters are required for OSHPD buildings. Another requirement associated with water heaters is the high-water temperature alarm, which, per CPC, is set at 125° F. An audible and visual device for the temperature alarm must be in a continuously occupied area. This requirement can have a significant impact on the project if overlooked. If the water heater room is tight and designed to only accommodate one water heater, this can pose a substantial challenge for the design team to address without significantly affecting the program of the spaces. Additionally, adding another water heater can also affect the electrical load.

Other requirements include the fact that the space above the ceiling may not be utilized as return air plenum and that vent pipe terminations are a 25’ minimum away from any air intake or vent shaft.

There are more examples not mentioned above. As engineers and designers, we have a responsibility to review all the codes and standards applicable to the project. "Beneficial or not?" Clearly, HCAI's CANs and PINs are beneficial. It makes our lives a little easier knowing there are codes and standards that clearly delineate the intent and simplify the process of defending our design against aggressive cost-cutting measures.