NPC Revisited

by Paul Coleman, Deputy Director, Office of Statewide Health Planning and Development (OSHPD)


From a hospital building operational standpoint, the terms “fully operational” or “business-as-usual operations” are not in the law, in building standards, or in regulations.  The Hospital Facilities Seismic Safety Act (HFSSA) § 129680 requires that hospitals “shall be designed and constructed to resist, insofar as practical, the forces generated by earthquakes, gravity, and winds.”  HFSSA § 130005 (f) states, “The office, in consultation with the Hospital Building Safety Board (HBSB), shall develop regulations to identify the most critical nonstructural systems and to prioritize timeframes for upgrading those systems that represent the greatest risk of failure during an earthquake.”  

For the 2019 California Building Standards Code (CBSC) cycle, OSHPD and the Hospital Building Safety Board (HBSB) revisited the Nonstructural Performance Categories (NPC) and timelines to determine if changes needed to be made to the regulations based on what is “practical,” what are the “most critical systems,” and what should the “timeframes be for upgrading those systems that represent the greatest risk of failure during an earthquake.”  As a result of this joint effort, a new category was created – NPC-4D.  This new category prioritizes critical care areas and allows other areas of the hospital to be upgraded over time as renovation and remodel work occurs.  NPC-4D will be included in the 2019 CBSC, which becomes effective January 1, 2020.  However, this new category may be utilized before its effective date in accordance with Policy Intent Notice No. 54, “Application of Enforceable Codes.”  

NPC-4D prioritizes critical care areas and allows other areas of the hospital to be upgraded over time as renovation and remodel work occurs.  NPC-4D is basically NPC-3, with significant modifications and reductions, and an Operational Plan.  Also, NPC-4D has three levels from which the hospital may select to comply with, these are:

Level 1:

  • Anchorage and bracing of equipment and systems in the hospitals’ critical care areas in accordance with the revised NPC-3 requirements
  • Anchorage and bracing of the equipment in the physical plant serving the critical care areas
  • Fire sprinkler systems comply with the bracing and anchorage requirements of NFPA 13, 1994 edition, or subsequent applicable standards

Level 2: 
(Recommended lowest level that a designated Trauma Hospital should be)

  • Includes Level 1
  • All services and utilities from the source to Level 1 areas necessary to accommodate continuation of services are anchored and braced
  • Elevator(s) selected to provide service to patient, surgical, obstetrical, and ground floors during interruption of normal power 

Level 3:

  • Includes Level 2
  • All systems and equipment are anchored and braced so that additional services, as determined by the hospital in its Operational Plan (OP), are functional and available to the public after a seismic event

Hospitals will increase nonstructural performance beginning January 1, 2028 for buildings with less than NPC-4 rating as they perform remodels, renovation, or other construction work, with the following exceptions:

Exception 1: Remodels/renovations, or other construction work, that remove a room or space from service use or occupancy for less than 24 hours.

Exception 2: Where 20% or less of the affected existing construction, such as ceilings, walls, ducts, but independent of finishes, is removed to access equipment and services for anchorage/bracing may be reinstalled as it pre-existed prior to the NPC work, if it followed the code at the time it was installed/constructed.

Exception 3: Buildings that have been removed from general acute care service or have projects to remove the building from acute care services by 2030. 

The OP specifies how the facility will repair nonstructural damage and bring systems and services back on line, or provide them in an alternative manner, to accommodate continuation of critical care operations.  The OP does not cover clinical aspects of emergency operations.  It is intended to cover only building functions and operations that are needed to meet the appropriate NPC-4D level.  The OP may refer to an Emergency Operations Plan (EOP) on file with CDPH or any other public agency if the appropriate building functions and operations are covered in the referenced document.  The OP is filed with the Office and posted on its website.  It is not reviewed or approved by the Office

1. Level 1 Areas (Critical Care)

  • Does the facility have as-built plans or schematics showing the routing between the source and the critical care area?  If not, does the facility have a plan to develop as-builts or schematics, and if so, by what date?
  • Based on the routing, configuration, and materials used for the services and systems from the source to the critical care areas, does the facility maintain materials on hand to make repairs in a reasonable amount of time?  If not, has the facility made provisions for ready access to supplies from a reliable source?
  • Facility should have a plan to prioritize repairs to the essential electrical system in event of failure.  If not, has the facility made provisions for ready access to supplies from a reliable source?
  • Facility has a plan to maintain the areas in operation.  An arrangement is in place to transfer the services if critical areas cannot be restored to operations quickly

2. Central and Sterile Supplies 

3. Dietary 

4. Pharmaceutical Services 

Items 2 through 4 above that serve Critical Care Areas may:

  • Refer to the facility’s (EOP) 
  • Have a plan of action as part of this OP
  • Indicate the applicable services are in a conforming building (SPC-3 or higher and NPC-4 or 4D) and services/systems and utilities feeding these areas are in a conforming building and are free of adverse seismic interactions that could be caused by potential failure of overhead or adjacent components. 

5. Emergency Power 

  • Does the facility have adequate on-site fuel supply or ready access to fuel?
  • Does the facility have a means of readily connecting a portable/mobile generator into the essential electrical system prior to an event?
  • May refer to the facility’s EOP or may indicate the essential electrical system is supplied from a conforming source, such as in a SPC-3 or higher and NPC-4 or NPC-4D building

6. Water Supply 

  • Facilities will be required to have on-site access to water supply or by means of an alternative method.  Prior to 2030, facilities should consider an adequate water supply for continuation of operations.  This may already be covered in the Facility’s EOP

7. Medical Gases 

  • The facility may have on-site bottled medical gases, the medical gas systems may be fed from and/or pass through conforming buildings or may be adequately covered by the facility’s EOP

8. Ventilation 

  • Facility can isolate and shut down Heating, Ventilation, and Air Conditioning (HVAC) system zones in an emergency 
  • Guidelines are in place for emergency shutdown               
  • Sections of the facility can be isolated, if needed
  • Individuals are identified who have authority for ordering HVAC shutdown 24/7                                                                                                             
  • Air intakes are protected from tampering                                                 
  • Facilities and Engineering staff have knowledge of HVAC zones and shutdown procedures       
  • Facility maintains adequate emergency supplies of filters for HVAC systems
    • It may not be practical to have every filter type and size on hand, in this event, the facility has made provisions for ready supplies from a reliable source
    • Having carbon filters for air intakes on hand may be a best practice

9. Waste Disposal

  • Procedures for management and disposal of an increased volume of contaminated solid and liquid wastes from the critical care areas for 72 hours are in place.  This could include “red bags” and identify a location or means of storage until disposal
  • This may already be covered in the facility’s EOP

Operational Plan update/change notification. The hospital shall document any changes and file the revised plan with the Office.