Seismic Compliance Frequently Asked Questions

1. Do I need to submit drawings with the Seismic Evaluation Report?#

The submittal requirements for the seismic evaluation can be found in 2022 California Administrative Code, Chapter 6, Section 1.3, Seismic Evaluation and all subsections which follow. These provisions stipulate that certain drawings and plans are an integral part of the Seismic Evaluation Report. The evaluator shall use drawings, diagrams, and details to accurately present the information necessary to communicate evaluated conditions and details of the subject existing building system.

The graphical information can be presented and incorporated in the evaluation report.  

PDF format is preferred, oversized documents that are too large to upload to eSP may be submitted using our Secure File Transfer (SFT) website, click to request an SFT link.

3. Can a different format be used for the “Compliance Plan Schedule” than the one specified in the regulations if we add a space for the governing codes and the year of construction?#

2022 California Administrative Code, Chapter 6, Section 1.4.4.4 specifies the items required for a complete “Compliance Plan Schedule” and Section 1.4.4.5 specifies the information required for the “Existing and Planned Buildings Matrix”. An augmented version of these documents is acceptable only if all the required items are included in the modified document.

5. Can a conforming hospital building (SPC 3, 4, 4D or 5) be supplied with utilities emanating from a SPC 1 hospital building?#

A SPC 1 hospital building will cease operation as a general acute care hospital building at the end of the maximum extension granted to that building. Refer to California Existing Building Code Section 307A.1.1.1 for additions, alternations and remodels of conforming hospital buildings.

7. If a Static Nonlinear (Pushover) design approach is used, can the hospital utilize the same engineering specialist that assists with the analysis to provide the peer review functions? #

No, see 2022 California Building Code Section 1617A.1.41, Part 2, Title 24.

9. How do I remove Acute Care Services from a hospital building?#

Please see eSP User Guide Applying for Removal of Acute Care Services. The 3-step process is summarized below;

Step 1: Submit a construction project using the eServices Portal (eSP)#

If no construction is required for the removal of acute care services, this step may be skipped.

If construction is required to remove acute care services from a building submit one or more application(s) for new project to the Building Safety Section using the eServices Portal (eSP). See eSP User Guide Applying for Removal of Acute Care Services Section 3.1 for more information.

The project should demonstrate that the hospital building is eligible to have acute care services removed and that it can be transferred to either the local jurisdiction or remain in HCAI jurisdiction as a non-hospital building (this may include Acute Psychiatric or Skilled Nursing uses). 

The 2022 California Existing Building Code, Section 309A outlines the requirements for such a project. Also see CAN 1-6-1.4.5.1.4 for examples on this issue, even though it has been superseded by the 2022 California Building Code. For further questions, contact the supervisor of the appropriate region of the Building Safety Section of HCAI/OSHPD where the building is located. 

Step 2: Submit a no-construction project using the eServices Portal (eSP)#

Once the construction project(s) from Step 1 have been completed and closed in compliance, submit a no-construction application for new project to the Building Safety Section using the eServices Portal (eSP). See eSP User Guide Applying for Removal of Acute Care Services Section 3.2 for more information.

Step 3: Submit a Removal of Acute Care Services (RACS) project to the Seismic Compliance Unit (SCU)#

Once the no-construction RACS project from Step 2 has been completed and closed in compliance, submit a Seismic Compliance Project application using the eServices Portal (eSP), and upload the following supporting documents:

1. Where HCAI jurisdiction is requested, provide the RACS project number and approval letter.

2. Where Local jurisdiction is requested, provide the letter written by the supervisor of the appropriate region that hands the jurisdiction of the building to local authorities.

3. Submit an amended or revised site plan showing the location of the buildings that remain in HCAI jurisdiction.

We also recommend including approved drawings for the RACS project (PDF format is preferred, oversized documents that are too large to upload to eSP may be submitted using our Secure File Transfer (SFT) website, click to request an SFT link). This will expedite the review as it takes time to retrieve the drawings from HCAI archives.

The SCU will then reclassify the building as OSHPD 1R and remove it from the list of buildings that need to comply with Senate Bill 1953.  Where the building is being handed to local jurisdictions, the building is removed from the list of hospital buildings all together.

11. What is the Detailed Frame Joint Evaluation procedure for Pre-Northridge Moment Frame Buildings after an earthquake?#

This is a 3-step process:

Step 1: Submit an application to the Seismic Compliance Unit (SCU)#

Submit a Seismic Compliance Project application using the eServices Portal (eSP) for a Complete Joint Penetration (CJP) Joint Inspection Program per the 2022 California Administrative Code, Chapter 6,  Section 4.2.0.3 where buildings have exceeded the ground motion specified in 2022 CAC Chapter 6, Section 4.2.0.1. 

2022 California Administrative Code (CAC), Chapter 6

4.2 Steel moment frames. Welded steel moment frames may be subject to detailed frame joint evaluation requirements, as outlined in this section. The purpose of this joint evaluation is to determine if the building has experienced joint damage in strong ground shaking.

4.2.0.1 Preliminary screening. All welded steel moment frame structures shall undergo a detailed frame joint evaluation if the building is located at a site that has experienced the following:
1. An earthquake of magnitude greater than or equal to 6.5 that produced ground motion in excess of 0.20g; or
2. An earthquake that generated ground motion in excess of 0.30g.
The ground motion estimates shall be based on actual instrumental recordings in the vicinity of the building. When such ground motion records are not available, ground motion estimates may be based on empirical or analytical techniques. All ground motion estimates shall reflect the site-specific soil conditions.

4.2.0.2 Additional indicators. A detailed frame joint evaluation of the building shall be performed if any of the following apply:
1. Significant structural damage is observed in one or more welded steel moment frame structures located within 1 km of the building on sites with similar, or more firm, soil properties;
2. An earthquake having a magnitude of 6.5 or greater, where the structure is located within 5 km of the trace of a surface rupture or within the vertical projection of the rupture area when no surface rupture has occurred;
3. Significant architectural or structural damage has been observed in the building following an earthquake; or
4. Entry to the building has been limited by the building official because of earthquake damage, regardless of the type or nature of the damage.

4.2.0.3 Connection inspections. Detailed frame joint evaluations shall be performed in accordance with the procedures in the Interim Guidelines: Evaluation, Repair, Modification and Design of Welded Steel Moment Frame Structures, FEMA 267, August 1995_.

Accessibility requirements for Detailed Frame Joint Evaluation Procedure for Pre-Northridge Moment Frame Buildings:

The detailed frame joint evaluation procedure for pre-Northridge moment frame buildings involves a visual, ultrasonic or magnetic particle inspection of moment frame joints in an existing building. As the inspections of the joint by itself does not constitute a “building alteration, structural repair or addition”, accessibility requirements of Chapter 11B of 2022 California Building Code do not apply. Spray-on-fireproofing or other fireproofing materials removed from the moment frame joint for the purposes of the inspection also do not constitute a “building alteration, structural repair or addition” where they are replaced in kind soon after the inspection (may be subject to special inspection under Section 1705A.14 Sprayed Fire-resistant materials). Where non-structural framing, finishes and/or ceiling systems are removed or altered temporarily to gain access to the joint, and then replaced in kind, the accessibility requirements apply only when the work performed exceeds an amount that would normally be required to gain access to the moment frame joint – a rule of thumb used in such cases is accessibility requirements apply when more than 25% of the ceiling in a room is temporarily removed/altered. Any repair, removal or alteration and replacement of structural systems such as beams, bearing and/or shear walls, will trigger accessibility requirements of Chapter 11B of the 2022 California Building Code, see examples in CAN 2-11B.

Step 2: Submit a construction project using the eServices Portal (eSP)#

After the CJP Joint Inspection Program is approved, submit an application for new project to the Building Safety Section using the eServices Portal (eSP). Obtain a building permit and perform the joint inspection.

Step 3: Submit an application to the Seismic Compliance Unit (SCU)#

Submit a Seismic Compliance Project application using the eServices Portal (eSP) for CJP Joint Inspection Results. If there is no damage, the SCU will concur with the results of the joint inspection and close the CJP Joint Inspection Program and Results projects.

Perform additional joint inspections depending on a damage index based on the results of field joint inspection where required. If damage is found, the SCU will discuss possible repair projects with the responsible design professionals.

Additional Notes:

• The joint inspections for affected buildings should be completed within six months after the earthquake.
• The joint inspection project should be left open until the SCU concurs with the results.
• Include notes on the process for inspection (2013 processforinspections.doc) with the joint inspection project.
• The joint inspection project will be reviewed by a fire marshal to verify replacement in kind of the fire proofing removed for the joint inspection.

1. Can I submit a letter declaring the seismic performance category of a hospital building instead of a detailed Seismic Evaluation Report?#

Per 2022 California Administrative Code, Sections 2.0.1.2 (SPC) and 11.01.2 (NPC) list the specific conditions where a hospital facility owner can submit a written declaration and be exempt from submitting either a structural or nonstructural evaluation report. However, the matrix of construction information specified in Section 1.3.4.6 shall be submitted pursuant to the requirements of Section 1.3.1. There are no other provisions for exemption from the Seismic Evaluation Report.

3. Is HCAI′s expectation that an SPC 2 upgrade provides a “Life Safety” level of performance?#

The various levels of structural seismic performance established by SB 1953 include potential collapse hazard (SPC 1) to immediate occupancy (SPC 5) after a seismic event. The SPC 2 may not be repairable or functional after the event and, therefore; unable to provide general acute care hospital services. Buildings reclassified to SPC 2 on the basis of their collapse probability assessment (HAZUS) have a calculated probability of collapse which increases with the presence of significant structural deficiencies in the building.

5. How do I apply for an SPC 4D Material Testing and Condition Assessment Program (MTCAP) and Results (MTCAR) project?#

The following steps explain the process for SPC 4D Material Testing and Condition Assessment Program and Results. However, the steps described below apply to any type of material testing projects (i.e. same for material testing required by SPC 2 “Usual Level” or SPC 4D “Comprehensive Level”).

Step 1: Submit an application to the Seismic Compliance Unit (SCU)#

Submit a Seismic Compliance Project application using the eServices Portal (eSP) for SPC 4D Material Testing and Condition Assessment Program (MTCAP), and upload the following supporting documents:

1. Submit complete MTCAP documents, detail drawings and specifications. Material Testing Program (MTP) and Condition Assessment Program (CAP) Programs can be submitted separately.

2. The SCU will then review the structural scope of the MTCAP, the detail drawings and specifications. After the SCU approves the MTCAP the project will be closed. The SCU typically stamps the cover page of the report and sends the approved MTCAP report back to the Applicant.

Step 2: Submit a construction project using the eServices Portal (eSP)#

Submit an application for new project to the Building Safety Section using the eServices Portal (eSP) and include the following:

1. A copy of the SCU approved MTCAP Report and approval letter.

2. Construction documents, which shall include all of the following:
   • An overall building floor plan showing the proposed locations of inspection;
   • Emergency procedures for construction workers;
   • Details and requirements for restoration of finishes and/or fire rated assemblies;
   • When inspection impacts means-of-egress, a temporary exiting plan;
   • Plans and details for temporary construction barriers;
   • Fire watch procedures: When it is not possible to maintain fire-resistive assemblies, fire-resistive construction and/or the means of egress, temporary construction barriers and/or a fire watch shall be provided in accordance with HCAI/OSHPD PIN 14.

3. Specifications

4. TIO form

(These projects may be processed in accordance with the FREER Manual as a Field Review project)

HCAI/OSHPD region review includes architectural, structural, fire/life safety. Electrical or mechanical review are typically not required.

After the HCAI/OSHPD region approves the project and issues a permit for the MTCAP project, the construction phase (i.e. testing) begins.

During the Conditions Assessment, fire-resistive assemblies, fire-resistive construction and the means of egress shall be maintained in accordance with Chapters 7 and 33 of the California Fire Code. These plans and procedures shall be reviewed and approved by the HCAI field staff (Compliance Officer, Fire and Life Safety Officer and District Structural Engineer) and the local fire authority (as applicable) in accordance with Section 3301 of the 2022 California Fire Code. Compliance with the provisions of Chapter 33 of the 2022 California Fire Code are in addition to any additional regulations or requirements pertaining to dust control, noise control and asbestos abatement enforced by agencies other than HCAI/OSHPD.

When demolition, inspection and reconstruction is continuous, no hot work is involved and inspectors and construction workers are in constant attendance, enforcement of temporary construction barrier and / or fire watch requirements may be deferred. Under these conditions, appropriate procedures shall be established in the event of a fire or other emergency.

During sampling stage, if any deviation from the MTCAP report occurs, such as sampling location, number of samples etc., SCU shall be notified immediately via email with a brief description of the change, a photo and any additional supporting documentation. To prevent any construction delays, SCU will respond back via email as soon as possible (Keep track of these responses, as these communications will be required in the MTCAR report).

Where changes are extensive, an amended construction document may be required at the discretion of the District Structural Engineer in consultation with the SCU.

The SCU recommends that the project remain open (within time limitations per 2022 CAC 7-129) until the results are accepted by the SCU in case additional testing or inspection is required.

Step 3: Submit an application to the Seismic Compliance Unit (SCU)#

Submit a Seismic Compliance Project application using the eServices Portal (eSP) for SPC 4D Material Testing and Condition Assessment Results (MTCAR), and upload the following supporting documents:

1. Submit complete MTCAR reports, include all deviations, and corresponding SCU approval emails.

2. The SCU will issue and MTCAR approval letter and close the project.

3. Contact the Building Safety Section and request to close the construction project.

1. The continuous operation issue is to be addressed for hospitals that are to remain in existence beyond the 2030 deadline. Prior to 2030 deadline, why does the Nonstructural Performance Category (NPC) 3 category require components that are part of continuous operation systems to be anchored and braced, when located in critical care areas and other support areas critical to patient care?#

The NPC′s were developed with the intent of establishing various levels of seismic performance for nonstructural equipment, components and systems critical to patient care. The critical distinction between any two NPC′s is not merely the survivability of the facility, but its level of functionality after a seismic event. Nonstructural components and systems have a lower threshold to seismic forces than structural elements and systems.

Buildings in the NPC 3 category are expected to maintain their inpatient population following a moderate earthquake, as well as provide a full array of emergency services to the public. To enable a NPC 3 hospital building to provide these level of services (i.e. beyond mere survivability and be able to provide a minimal amount of medical care in specific areas) it is necessary to provide the bracing and anchorage specified in California Administrative Code, Chapter 6, Table 11.1, Nonstructural Performance Categories.

3. Would a Neurocare Ward (not ICU) with patients hooked up to a ventilator fall under the definition of “critical care”? Also, would a telemetry unit be considered “critical care” area?#

A neurocare ward would be considered a “critical care” area due to the nature of the treatment for the patients placed in them or the type of service provided (e.g. postoperative from brain surgery, etc.). A telemetry unit need only be considered for evaluation purposes if it supports a critical care area. In this context, a “telemetry unit” is defined as a group of patient beds with remote monitoring.

5. One of our hospital buildings does not have fire sprinklers. If this building is seismically retrofitted to SPC 2 level, will this require us to install a fire sprinkler system? What if it is retrofitted to SPC 5 level?#

Sprinkler systems fall under the Nonstructural Performance Categories (NPC′s) and not under the Structural Performance Category (SPC) requirements. Compliance with SB1953 does not require that fire sprinkler systems be installed where none existed before, even for SPC 5 conformance. However, hospital buildings with existing fire sprinkler systems must meet the anchorage and bracing requirements of NPC 3 and NPC 4.

7. Are single line diagrams required for the location of certain hospital areas?#

The Nonstructural Evaluation Report (see 2022 California Administrative Code, Chapter 6, Article 1, Section 1.3.4, Item 2.1) must include single line diagrams for the location of the following:

• Central supply areas
• Clinical laboratory service spaces
• Critical care areas
• Pharmaceutical service spaces
• Radiological service spaces
• Sterile supply areas

There are no provisions requiring single line diagrams for other hospital areas.

9. Often in hospital corridors the ceiling space is filled with pipes and conduits. Is it acceptable to create a secondary frame to “catch” the pipes to protect the exiting corridors instead of bracing all the pipes?#

Though catching the pipes is important, it is not the primary issue. In addition to the potential as a falling hazard that the pipes may represent, it is also important to prevent escape of the pipes′ contents should the pipes break. Proper anchorage and bracing will reduce movement and shearing of pipes, and thus reduce the possibility of the escape of the contents. Therefore, the anchorage and bracing of pipes and conduits must meet the requirements of Chapter 16A, Part 2, 2022 California Building Code. Secondary framing is an option available for pipe bracing, but is dependent on site conditions.

11. If the intent of NPC 3 is to prevent loss of water from pipes in critical care areas, do we have to brace pipes from the central plant to the critical care areas? We infer the intent to prevent water loss from the valving option permitted. Can we only valve the pipes at the boundaries of critical care?#

Pipes from the central plant supplying or passing through the areas specified in the NPC 3 category do not need to be braced outside the boundaries of those areas. However, equipment anywhere in the physical plant that services the NPC 3 specified areas shall be anchored and braced.

NPC 3 Exception 1 permits piping systems not be anchored and braced until 2030 (or 2024 based on Seismic Design Category F)  provided that “an approved method of preventing release of the contents of the piping system in the event of a break is provided.” Valving the piping system is an acceptable method of preventing the escape of the pipe systems contents in the event of pipe breakage or shearing. The configuration of the valving layout depends on the layout of the piping within the NPC 3 specified areas. It should be noted that valving the pipes only at the boundaries may or may not prevent the release of pipe contents in those areas.

13. In CAC Chapter 6 Article 11, the NPC process involves first a complete survey, then determining whether an HCAI permit exists, then making an NPC designation. This infers that in a code compliant structure, we have to do the whole survey even though it was built with full inspection. Can we not rely on an HCAI permit and inspection to designate the structure as compliant?  Is it acceptable to look for permits first, and then survey the non-compliant areas?#

The evaluator is free to perform the nonstructural evaluation in any manner desired. Hospital buildings constructed under a permit issued by HCAI are deemed to comply with the anchorage and bracing requirements of Title 24, with the exception of the fire sprinklers (unless constructed or retrofitted under NFPA 13, 1994 or subsequent edition). For other types of buildings, a review of the available drawings to determine the extent of the nonstructural bracing prior to conducting the site visit is very prudent. Aside from establishing the level of anchorage and bracing required to be expected, it will allow the evaluator to inventory components appearing on the drawings that should be braced. As a rule all major components that require bracing should be shown on the drawings. It is important to note that the NPC 3 evaluation is limited to those systems and components listed in the 1995 CBC, Part 2, Title 24, Table 16A-O.

All compliant buildings are not the same. Between 1973 and 1983, the enforcement of the code requirements for nonstructural elements, components and systems was inconsistent. The level of attention given to nonstructural bracing varied tremendously. This is substantiated by the nonstructural failures that occurred in various post-1973 hospitals as a result of the Northridge Earthquake.

In the late 1970′s and 1980′s some pre-1973 buildings had extensive remodels. The scope of these remodels can vary extensively, from cosmetic alterations to a complete gutting of the space, with reconstruction to current standards. It is not unusual to find braced and unbraced components next to each other in the same space. If the component or system was not modified during the remodel, then it was probably not seismically retrofitted. Only by inventorying the systems can the extent of the seismic bracing be definitively established.

15. Is NPC 5 a campus-wide designation (like NPC 2) or a seismically separate building designation?#

NPC 5 is a campus-wide designation with compliance expected in 2030, but new seismically separate buildings constructed to the 2010 or later California Building Codes are required to be NPC 5 compliant now. HCAI recommends planning to comply on a campus-wide basis with a phased approach to get NPC 5 compliance for a new building before it’s occupancy.

17. Does the NPC 5 requirement of 72 hours of water refer to potable water only? Is industrial water or (process) water to operate hospital utilities included in this storage requirement?#

NPC 5 requirement refers to both potable water as well as industrial/process water to operate hospital utilities to support 72 hours of emergency operations:

For a seismically separate building that has licensed patient beds, a minimum of 150 gallons of potable water per licensed bed shall be provided (Section 615.4, 2022 California Plumbing Code) with additional industrial/process water to support 72 hours of emergency operation of the subject building. Also see exception in California Plumbing Code Section 615.4.1, for a seismic separate building that has no licensed patient beds, potable water and industrial/process water to support 72 hours of emergency operation of the subject building. A new Central Utility Plant must provide water for 72 hours of emergency operation for itself, any other new buildings but not for the existing buildings on the campus (The existing buildings will need to comply by 2030).

The amount of water required is determined from the facility’s emergency operations plan and an associated Water Conservation/Water Rationing Plan to provide for 72 hours of operation. The water conservation/water rationing plan must also be accepted by the California Department of Public Health licensing division. Whereas, there is a minimum volume of potable water per licensed bed, there is no minimum volume for industrial/process water in the California Plumbing Code. This volume is dependent on which utilities and systems the hospital facility intends to operate during an emergency. The Water Conservation/Water Rationing Plan must account for losses in the process water for closed loop heating and cooling systems.

See a planning guide titled “Emergency Water Supply Planning Guide for Hospitals and Health Care Facilities” published by DHHS, CDC and AWWA.

HCAI review of NPC 5 will be based on the volume of water required by the facility’s Water Conservation/Water Rationing Plan (as part of the facility’s emergency operations plan) as required by the California Plumbing Code.

19. Per Section 727 of the 2022 California Plumbing Code, can the facility store the sewage and liquid waste in a 5,000-gallon tank? Does this tank need to be connected to a sewage line?#

Yes, holding tanks are required; however, there is no minimum size for the holding tank provided in Section 727, 2022 California Plumbing Code. The capacity shall be based on the Water Conservation/Water Rationing Plan required in Section 615.4.1.

The purpose of the holding tank is to permit 72 hours of continuing operation if the external sewer connection is severed. Thus, HCAI does not have any requirements for connection of the holding tank to the existing sewer line; however, such connections should be made with sufficient valves to isolate the external sewer lines.

21. For NPC 5 evaluations, is the on-site emergency fuel storage requirement based on 96 hours or 72 hours? Are the fuel storage requirements based on fuel consumption of the generators at rated capacity or the actual load for the facility? Does the fuel storage requirement apply to N configuration only?#

HCAI enforces a minimum of 72 hours of fuel storage for NPC 5 buildings, and not the 96 hours required by NFPA 101.However, NFPA 110 requires the main fuel tank(s) to have on-site fuel storage of at least 133% of the quantity required. Requirements for on-site fuel storage requirements for various healthcare buildings can be found in the 2022 CEC article 700.12.

As stated in NFPA 110 5.1.1.1 “on-site storage of an alternate energy source sufficient to allow full output of the EPSS to be delivered for the class specified shall be required.” For acute care hospitals, the class is 72, therefore the minimum on-site storage tank capacity requirement is 133% of the calculated 72-hour fuel supply to support fully loaded generator(s).

The minimum on-site fuel storage for an existing acute care hospital facility required to meet NPC 5 requirements shall be based on the actual load [“full-demand” on the Essential Electrical System (EES) per the 2022 California Electrical Code Section 700.12 (B)(2)]. The full demand load of the existing EES should be calculated by following the method described in HCAI PIN 38 for level-one panel existing demand loads. The full-demand metered load taken at 125% should be used to determine the minimum number of generators required to meet or exceed the full-demand load at a particular site. Fuel sufficient to operate the minimum required generators at 100% for 72 hours shall be required. Note that for a N+1 configuration, fuel sufficient to operate only N generators is required.

Here is an example calculation to demonstrate these requirements.

Existing site has (3) 1500 kW/1875 kVA emergency generators. Facilities existing max demand load for the essential system is 2.9 MVA. [2.9 MVA x 1.25 = 3.625 MVA]

Therefore, the facility needs (2) 1500 kW/1875 kVA generators to meet site essential loads. Manufacturers listed fuel consumption for 1500 kW generators 100% loaded (full output) is 106.5 gal per hour.

• 106.5 gal/hour * 72 hours * 1.33 = 10,198 gallons
• 10,198 gallons * 2 generators = 20,396 gallons

Minimum on site fuel storage is 20,396 gallons.

23. What are the NPC 4 and NPC 5 evaluation deadlines and requirements for buildings that will be removed from acute care service by the January 1, 2030 deadline?#

Please see General Questions FAQ #9 for detailed instructions on submitting Removal of Acute Care Services (RACS) projects.

2022 California Administrative Code, Chapter 6, Article 1, Section 1.5.2.1

1.1. By January 1, 2024, the hospital owner shall submit to the Office a complete nonstructural evaluation up to NPC 4 or 4D and NPC 5, for each building. 

The NPC 4/NPC 5 evaluation shall consist of a letter from the hospital (on hospital letterhead, signed by the Administrator/CEO) stating that BLD-xxxxx will be removed from acute care usage by January 1, 2030.  Submit a Seismic Compliance Project application using the eServices Portal (eSP), and include this letter as a supporting document.

2022 California Administrative Code, Chapter 6, Article 1, Section 1.5.2.1

1.2. By January 1, 2026, the hospital owner shall submit to the Office construction documents for NPC 4 or 4D and NPC 5 compliance that are deemed ready for review by the Office, for each building that will continue to provide acute care services beyond January 1, 2030. 

The facility will need to submit one or more RACs construction projects to meet the requirements of applying for Removal of Acute Care Services. If no construction is required for the removal of acute care services, then this step may be skipped.

2022 California Administrative Code, Chapter 6, Article 1, Section 1.5.2.1

1.3. By January 1, 2028, the hospital owner shall obtain a building permit to begin construction, for NPC 4 or 4D and NPC 5 compliance of each building that the owner intends to use as a general acute care hospital building after January 1, 2030. Hospitals not meeting the January 1, 2028 deadline set by this section shall not be issued a building permit for any noncompliant building except those required for seismic compliance in accordance with the California Administrative Code (Chapter 6), maintenance, and emergency repairs until the building permit required by this section is issued. 

RACs construction project(s) shall obtain building permit(s) by January 1, 2028.  After closure of these projects in compliance, a no construction RACs project shall be submitted to the Office, as per the eSP User Guide Applying for Removal of Acute Care Services, indicating whose jurisdiction the building will be in (local authority having jurisdiction or HCAI/OSHPD).  Once that project is closed in compliance, submit a Seismic Compliance Project application using the eServices Portal (eSP) by January 1, 2030, to remove the building from the acute care building inventory.

25. Link to 1995 CBC Table 16A-O#

1995 CBC Table 16A-O

27. Limits of Critical Care Areas#

2022 California Administrative Code (CAC), Chapter 6, Article 1, Section 1.2 – CRITICAL CARE AREA means those special care units, intensive care units, coronary care units, angiography laboratories, cardiac catheterization laboratories, delivery rooms, emergency rooms, operating rooms, postoperative recovery rooms and similar areas in which patients are intended to be subjected to invasive procedures and connected to line-operated, electromedical devices.

In the case of a Surgical Services Department, for example, CBC 1224 calls for certain code required spaces such as staff locker rooms, nurse control office, etc. Because these rooms are required by code for a Surgical Services Department to function, must they also be considered Critical Care Areas? Or, do we take a strict definition of Critical Care Areas to include only spaces for patients?

The whole Surgical Services department would be the boundary of the NPC 3 critical care area.

29. Using the 1987, 1989, 1991 NFPA 13 to show compliance with fire sprinkler bracing#

Scope of Work

1987, 1989, 1991 edition NFPA 13 Building Scope:

1. Buildings where fire sprinklers are designed with 1991 edition NFPA 13: Design team required to add missing end-of- line restrains only.
2. Buildings where fire sprinklers are designed with 1987 and 1989 edition NFPA 13: Design team to perform a visit site and verify original branch line bracing and end-of-line restrains exist. Design team required to add missing end of branch line restraints, missing longitudinal sway bracing for feed and cross mains, and missing lateral sway bracing for feed and cross mains.

1985 edition and earlier NFPA 13 Building Scope:

1. Buildings where fire sprinklers are designed with 1985 and earlier NFPA 13: All fire sprinkler piping above ceiling shall be evaluated.

Existing Documentation

1. Photo Documentation: For projects constructed under the 1987, 1989, and 1991 edition NFPA 13 if the design team observes either end of line restrains and/or branch bracing, photo documentation will be sufficient to accept the as-built condition as part of an engineering report signed and stamped by the Structural Engineer of Record. However, the amount of photo documentation will need to be discussed, reviewed, and approved by the SCU.

Design Criteria

1. Anchorage Design: Where new restraints or bracing is placed, the anchorage design shall meet current California Building Code.
2. Location of Bracing and End-of-Line Restraints: The number and location of bracing or end-of-line restraints will be identified per Scope of Work above.

31. Where can I find the California Department of Public Health Licensing and Certification All Facility letter (AFL 23-21)?#

AFL 23-21

33. Can buildings and tunnels with an OSHPD approved NPC 4D Level 1, 2, or 3 rating supply services/systems and utilities to conforming buildings (SPC-3, -4, -4D, or -5) downstream?#

2022 California Existing Building Code, Section 310A.1.1.1.1 does allow the use buildings or tunnels with an OSHPD approved NPC 4D Level 1, 2, or 3 rating to provide services/systems and utilities to conforming (SPC-3, -4, -4D, -5) buildings downstream of the NPC 4D Level 1, 2, or 3 building or tunnel. However, as part of the approval of the NPC 4D Level 1, 2, or 3 upgrade for these buildings or tunnels, the NPC 4D Operational Plan required by 2022 California Administrative Code, Chapter 6, Article 11, Section 11.2.3.f, shall address showing how for all critical care areas in the downstream buildings the facility will repair nonstructural damage and bring systems and services back on line for the downstream critical care areas, or provide downstream critical care areas in an alternative manner to accommodate continuation of critical care operations.

35. If the NPC 5 submittal is part of a package submitted by a licensed design professional, does it need to be sealed and signed by a licensed design professional?#

If the NPC 5 report is submitted by a licensed design professional, it needs to be signed and sealed by a licensed architect or mechanical engineer.

37. What are the testing requirements for tension and shear for existing anchors?#

Demand, capacity, and testing requirements are listed under 2022 CAC Chapter 6 Article 11 §11.3 and clarified below for NPC-3, 4, and 4D:

1. Tension and shear demands shall be calculated per 1998 CBC §1630B as listed under 2022 CAC Chapter 6, Article 11, §11.3.
2. Tension and shear capacity for cast-in-place anchors shall be per Table 19B-E of the 1998 CBC. The tension and shear capacity for post-installed anchor tension and shear capacity is allowed to be per the ICC ER report matching the anchor manufacturer and code cycle at the time of installation.
3. Testing:
   • Tension: Refer to §11.3.1 and §11.3.2 for testing frequency, demand (3*tension), usage type (equipment versus distribution system), and permitted exceptions.
   • Shear: Shear testing or tension testing is not required when analysis indicates only shear demand (no tension).
   • Alternate testing criteria are permitted per §11.3.4.

39. What is the minimum number of elevators required by NPC 4D Level 2 and NPC 4D Level 3 upgrades?#

There shall be a minimum of one elevator selected to provide service to patient, surgical, obstetrical, and ground floors during interruption of normal power. The selected elevator shall be capable of carrying a gurney. The selected elevators do not need to be in the building requesting the NPC 4D Level 2 or Level 3 upgrade, but shall be accessible on the patient, surgical, obstetrical, and ground floors and be reasonably close to the building in question.

41. When is verification of flex joints, or alternate means of handling differential movement of pipes, conduits, ducts at seismic separation joints between two buildings required?#

[For NPC 4, NPC 4D Level 2, NPC 4D Level 3] Please verify if utilities, services, and systems crossing seismic joints can accommodate the relative building displacements or have a flex joint. Where the building does not meet this criteria, the design professional of record shall state the following sentence in the report: “The building might not be functional after an earthquake due to failure in utilities between adjacent buildings”. The following table clarifies where the survey is required.

43. Can a Central Utility Plant (CUP) building, mechanical room, electrical room, cooling tower or equipment yard be upgraded to NPC-4D Level one or two or three?#

No, these buildings can only be upgraded to NPC-4 level of compliance. These buildings serve the entire facility and therefore should be in operation after an earthquake.

44. The requirement for piping suspended by individual hangers 12” or less in length from top of pipe to bottom of support has changed in CBC 2016 and CBC 2019. Is it acceptable to use previous CBC codes for the exception?#

The exception from 1998 code or later codes but not a combination thereof, shall be considered acceptable to satisfy the requirements of NPC reclassification. 

1. Do Skilled Nursing Facility buildings have to meet the requirements of SB 1953?#

Skilled Nursing Facility buildings (SNFs) which are licensed under 1250 (c) of the Health and Safety Code do not have to meet the requirements of SB 1953. Also precluded are hospital buildings that are licensed under Section 1250 (a), General Acute Care, but provide skilled nursing services only. For additional information, refer to the response to Question #3 below.

3. My SNF building is under GAC license but it is a separate building on the campus. Does SB 1953 require this building to be evaluated?#

The Seismic Evaluation Procedures and Compliance Plan Regulations were developed by HCAI specifically for implementation by GAC licensed hospital buildings in furtherance of the Alfred E. Alquist of Hospital Facilities Seismic Safety Act of 1983. These regulations require GAC licensed hospitals to perform seismic evaluations on their respective facilities and for mitigation of substandard structural and nonstructural conditions by the seismic retrofit (compliance) plan.

In the 2022 California Administrative Code, Chapter 6, Section 1.2, Definitions, the term “General Acute Care Hospital” is defined. It states in part the following:

“…a hospital building as defined in Section 129725 of the Health and Safety Code and also licensed pursuant to Section 1250 (a) of the Health and Safety Code…(but) It also precludes hospital buildings that may be licensed under the above mentioned code sections, but provide skilled nursing services only.”
Therefore, a building which contains no GAC licensed beds or services but is used only for SNF beds and services is not subject to the requirements of SB 1953 even though it is under the GAC license. However, the building must be “freestanding and separate” in accordance with the conditions set forth in #HSC-129725, revised August 20, 1996. For additional information, refer to Question #4 below.

5. Are acute psychiatric (or skilled nursing) facilities exempt from seismic retrofit requirements?#

Seismic retrofit requirements apply to General Acute Care Hospital buildings (as defined in the 2022 California Administrative Code Chapter 6), therefore, buildings, including SPC and/or free-standing buildings, providing only skilled nursing or acute psychiatric services are exempt.

Conversion of General Acute Care Hospital buildings for acute psychiatric or skilled nursing uses can be complex especially if the subject building is located in a facility that also provides general acute care services in other buildings at the same site. It is recommended that a meeting with the regional supervisor of the Building Safety Section of HCAI/OSHPD be arranged to discuss all possible issues related to the conversion.

Chapter 6 of the 2022 California Administrative Code
GENERAL ACUTE CARE HOSPITAL as used in Chapter 6, Part 1 means a hospital building as defined in Section 129725 of the Health and Safety Code and that is also licensed pursuant to subdivision (a) of Section 1250 of the Health and Safety Code, but does not include these buildings if the beds licensed pursuant to subdivision (a) of Section 1250 of the Health and Safety Code, as of January 1, 1995, comprise 10 percent or less of the total licensed beds of the total physical plant, and does not include facilities owned or operated, or both, by the Department of Corrections. It also precludes hospital buildings that may be licensed under the above mentioned code sections, but provide skilled nursing or acute psychiatric services only.

1. What is an AB 2190 Attestation statement? #

A hospital owner or operator who has a facility with one or more buildings with a structural performance rating of less than SPC 3 or whose non-structural performance rating is less than NPC 5 must submit a statement to HCAI attesting that its board of directors is aware of that their hospital buildings are required to meet the January 1, 2030 deadline for substantial compliance.  (H&S Code Section 130066)

3. Does the owner or operator of the facility need to disclose its compliance plan in its attestation?#

No.  H&S Code 130066 only requires an attestation of the awareness of the board of directors of its obligation to meet seismic safety deadlines.

5. What will HCAI do with the attestation statement?#

Attestations are public records due to their mandate in law.  Attestation letters will be publicly available on the Facility Detail page of the HCAI Office of Statewide Hospital Planning and Development (OSHPD) web site for each responding facility. 

7. Can an attestation letter be for more than one facility?#

If a healthcare system wants to submit one letter for all the hospitals for which they are the governing authority, they need to specify which hospitals and which building(s) at each hospital that are not in substantial compliance, the letter is intended to cover.  HCAI will duplicate and apply to each campus that is detailed in the letter.

Hospital Signage & Posting Requirements#

1. PIN 75 states the following: “The proposed location and the content of the notice are required to be accepted by the department through a construction project submittal.” Is an Amended Construction Document (ACD) or a new project acceptable to submit for posting?#

Please submit an application with a specific record type (GACSIGN) using the eServices Portal (eSP). Please follow the eSP User Guide Hospital Signage Reporting for the step-by-step application process.

2. What documents are required for the signage application?#

Please follow the eSP User Guide Hospital Signage Reporting. A floor plan showing the signage locations and the signage page selected and filled in from PIN 75 are required to be uploaded as part of the AB 1882 signage application.

3. Is only one notice needed for each non-compliant structure?#

The law requires posting in any lobby or waiting area generally accessible to patients. The department may agree with a fewer number of posting locations depending on the floor(s) layout and use of space. Please submit an application with proposed posting locations for the department’s review and approval.

4. Can this be done as part of another ongoing project on the site?#

No. Please submit a new AB 1882 signage application using eSP.

5. There are general acute care buildings without lobby or waiting areas, would posting still be required?#

If there is no lobby or waiting area, the department will review the location of the posting on a case-by-case basis. AB 1882 posting is not required for equipment yards, tunnels, canopies, cooling towers, or emergency generator enclosures.

6. Are these signs expected to be printed pieces of paper? What about signage to wall connection detail?#

There is no required material type for the signage. The signage should be protected from damage and securely adhered or hung on the wall.

7. Is it sufficient to provide a general location, such as pointing to the approximate area on a floor plan, or does the exact location need to specified?#

Pointing to the approximate area on a floor plan is acceptable. The installed signage is required to be verified and accepted by HCAI field staff.

8. Will the HCAI regions be reviewing these AB 1882 projects, or will they go through the Seismic Compliance Unit (SCU)?#

Review and approval will be done by the corresponding region or field staff.

9. Do we need to complete project kick-offs with the field staff? District Structural Engineer (DSE), Fire Life Safety Officer (FLSO), and Compliance Officer (CO)?#

No.

10. Do we need an Inspector of Record (IOR), Testing Inspection Observation Program (TIO), or Verified Compliance Report (VCR) by the Design Professional of Record (DPOR)?#

No.

11. Can the sign be moved at a later date?#

For revised location, please submit a new AB 1882 signage application using eSP.

12. Is a version of the sign for the visually impaired required?#

Braille signage is not required.

13. If the building SPC or NPC rating changes, would revised signage be required?#

Yes.

14. Can the facility provide supplemental information to the posting?#

No supplemental information on the posting will be allowed. However, additional informational postings around the signage that does not interfere with the AB 1882 signage posting is allowed.

15. The statement says no deviation from the notice format. Assuming that the format remains as is, can the statement be adjusted?#

The statement, the size, or the format cannot be revised.

16. Is the signage requirement in Section 130065 applicable only to the first floor, or does it apply to all floors including the basement in multi-story buildings?#

The signage requirement in Section 130065 applies to all floors in multi-story buildings, including the basement. This is because the section states that signs must be posted in “any lobby or waiting area generally accessible to patients or the public.” Therefore, all floor plans, including the basement, must be submitted with the locations of posted signage clearly marked. In the absence of lobby or waiting room place the signage in front of elevator/stair exit or in corridor. A minimum of one signage per floor is required.

17. Is signage required for a building that is not open to the public or does not see patients or provides no general acute care services?#

Yes, provide at least one signage for OSHPD 1 building at each floor.

18. Is signage required for OSHPD 1R or OSHPD 2 or OSHPD 5 buildings?#

Signage is not required for OSHPD 1R or OSHPD 2 or OSHPD 5 buildings.