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Commissioning in a Healthcare Facility: Code Requirements

In my previous post (LINK), I outlined the many ways a good commissioning team can assist in mitigating the risks associated with construction, remodeling, and ongoing operation of a healthcare facility. In addition to the many benefits commissioning brings to a facility, some building codes require commissioning to be a part of the process, this is especially true in the healthcare industry.

Codes and standards related to healthcare facilities include requirements for mechanical ventilation, ventilation rates (including re-circulation), outdoor air change rates, filtration, relative humidity, and minimum lighting levels. These codes and standards work to establish a standard of care. Failure to operate according to these standards could put a hospital in a position of financial and legal liability, e.g. for hospital acquired infections.

Below is a brief summary of various code requirements:

FGI Guidelines & Joint Commission

The Joint Commission uses the “FGI Guidelines for Design and Construction of Hospitals and Outpatient Facilities” as a reference standard when reviewing healthcare facilities. Included within that standard is the requirement to commission any project that involves changes to the physical environment used for patient care.

Medicare and Medicaid Services (CMS)

The recent adoption by the Centers for Medicare and Medicaid Services (CMS) of NFPA 99: Health Care Facilities Code, 2012 brings with it commissioning requirements for projects which are subject to a CMS survey

NFPA 99 Chapter 9: 9.3.3 Commissioning.

  • Heating, cooling, ventilating, and process systems serving spaces or providing health care functions covered by this code shall be commissioned in accordance with ASHRAE Standard 90.1, Energy Standard for Buildings Except Low-Rise Residential Buildings, 2010

LEED® v4 Building Design and Construction

Any LEED designed building requires an extensive commissioning process during their certification process.

International Energy Conservation Code (IECC)

Many states in the country have adopted some version of the IECC (International Energy Conservation Code) which requires limited commissioning.

  • Commissioning is required if heating and cooling capacity exceeds minimum thresholds.

  • Commissioning of HVAC&R is required per IECC 2012 and later, per IECC 2015 it is required for systems in buildings where the total mechanical equipment capacity is 40 tons cooling capacity OR 600,000 Btu/h (combined space and service water) heating capacity and greater. Systems that serve dwelling units and sleeping units are exempt.

  • The code lists which HVAC equipment must be included.

  • All HVAC equipment listed in IECC C403.2.3 Tables 1-10 are to be included, except small packaged or unitary equipment listed in Tables 1-3 which do not require an economizer. This includes but is not limited to air conditioners and condensing units, heat pumps, PTACs, PTHPs, gas and oil-fired furnaces and unit heaters, boilers, chillers, heat rejection equipment, CRACs, and heat exchangers.

  • Commissioning of Lighting Controls is required per IECC 2012 and later.

  • Commissioning of Service Water heating equipment is required per IECC 2015 and later.

A good commissioning team will be fully aware of these requirements and assist in designing and implementing a plan to ensure all these requirements are met. If you have questions about codes, email me at and I am happy to discuss these requirements further.

In an upcoming post I will be organizing some information to give you an idea of the cost of commissioning a healthcare facility. The short story is that commissioning pays for itself by reducing risk, ensuring functionality of installed systems, and ensuring mechanical systems work together so that your building as a whole is functioning as intended.

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