The Beebe File
- Deputy executive director, American Society for Health Care Engineering (ASHE) regulatory affairs.
- Associate director of advocacy for ASHE.
- Former authority having jurisdiction for the State of Washington.
- Architect and certified building official.
- Trustee of the Fire Protection Research Foundation.
- National Fire Protection Association committee positions include executive board member of the Health Care Section, chair of the Health Care Section Codes and Standards Review Committee and a member of more than 20 technical committees.
As deputy executive director of the American Society for Health Care Engineering (ASHE) and lead for ASHE’s regulatory affairs efforts, Chad E. Beebe, AIA, CHFM, CFPS, CBO, FASHE, has many responsibilities. This month, he talks to Health Facilities Management about the advocacy portion of his job portfolio.
What regulatory issues are you currently working on as we move into the new year?
We are always working on updating and maintaining facility codes to try to make sure they are consistent with each other. That keeps our team pretty busy, but to make sure that work has value, we have to get the codes updated by the Centers for Medicare & Medicaid Services (CMS). So that will be a big focus for us in 2024 and possibly for a few years to come. We are advocating that CMS adopt the 2024 editions of the National Fire Protection Association’s NFPA 99, Health Care Facilities Code, and NFPA 101®, Life Safety Code®, and that they do it like other federal agencies that automatically adopt the current codes when they are released.
Who is involved in ASHE Advocacy?
We have a great team at ASHE. Leah Hummel heads up our work with the Facility Guidelines Institute’s FGI Guidelines, Jonathan Flannery heads up the work with the ASHRAE standards and guidelines, Kara Brooks gets involved with any of those standards and more that pertain to sustainability, and I primarily focus on NFPA codes and standards. This helps us manage the work, and constant communication helps us ensure that we are meeting our objective of unifying these codes and standards.
But we don’t do it alone; there are dozens of ASHE volunteers who also represent ASHE for various guidelines, codes and standards. We meet regularly with these individuals and do our best to approach our advocacy work in a manner that reduces regulatory burden while maintaining a high level of safety.
The team speaks at chapter events and receives feedback there. We also pay attention to my.ashe.org and conversations in the field to identify areas of confusion or needs for regulatory relief, then we address those through committee work.
What is the general strategy of the ASHE Advocacy Team?
Our direct advocacy efforts include our work as members of various committees that are publishing these rules. With that work, we not only respond to public input, but we also propose a lot of the changes based on what we hear from our membership. Between NFPA, the International Code Council, ASHRAE and FGI, we submit hundreds of proposed changes. We have a pretty good track record with those changes because we make sure there is a justification and we include research, studies or survey results from our membership, when appropriate, such as when we successfully advocated for changes to the 30-day exit sign inspection requirements in NFPA 101.
Indirect advocacy revolves around education. A lot of misinterpretation or confusion around codes and standards comes from a misunderstanding of the intent or purpose of a section. It’s difficult for committees to fully capture the intent of a section and still have the language be in code language that is defensible, so it’s inevitable that some education needs to accompany the changes. We provide this education in our course materials, but we also provide a lot of this through the HFM Insider e-newsletter, our chapter presentations and the conference sessions that the advocacy team leads.
When I first started with ASHE, we didn’t have a team to rely on, and with so many changes happening, we couldn’t be on top of everything. We often had to resort to another form of advocacy, which is just a form of public protest that happens typically after a change in the hopes of reverting back to a different policy. The time it took to file appeals, delays and adoptions and fight the opposition on issues was rarely successful. We find that, generally, everyone is looking to make changes for the better, and we can often influence those changes so they are better for everyone.
We also like to take a broader look at the proposed changes and offer modifications or sometimes oppose changes that wouldn’t be feasible for all members to comply with. For example, there are often submissions from facilities managers who have had difficulties securing funding for equipment or new technologies. They sometimes submit changes that would require such equipment in the code [so they can get funding]. The difficulty is that the equipment may not be appropriate for every facility and may increase the burden on everyone. We are sensitive to the difficulties in getting funding for new technology, but we need to advocate for minimum standards versus best practices.
However, we do have other indirect advocacy efforts that address methods for designing, building and maintaining facilities above the code minimums.
What have been some of your advocacy success stories over the past few years?
Given our strategy of managing the development processes by being a part of the discussion early and collaborating on results that work, the greatest successes can be seen in the limited number of appeals or floor actions that we have had to take within the different code organizations. With NFPA, for example, it was not uncommon to have to fight for or against more than 50 issues each year. Now we typically only have a few each year.
On the more technical side, I think adding health care microgrids and the changes that are stemming from that will have the most impact in years to come. This opens a lot of room for new technology to be used within health care. It also reduces our reliance on diesel generators.
That effort started with a small group of ASHE members, NFPA technical committee members and a couple of ASHE’s business partners getting together and determining what health care will look like in 10 to 20 years. That highlighted several problems with the codes and standards as they existed, so we knew we needed to start on a path to make changes to allow health care to evolve.
How does sustainability fit into ASHE’s Advocacy Team agenda?
Technology is changing at such a fast pace that the codes and standards are either in the way of utilizing newer technology or they don’t address the technology so that it can be used in a safe and appropriate way.
Advocacy efforts on sustainability are not politically based but technology based. In the building industry, there is always an interest in developing new and better technology. What we want to do at ASHE is to embrace technology that may reduce our spending for construction, maintenance or operations.
While we will continue to fight policymakers to make sure they only adopt energy targets that are appropriate for health care, we are likely not able to thwart the efforts that will require us to think about sustainability. So, it’s important for us to decide how we can capitalize on the situation.
We can reduce our energy costs and perhaps put that money into updating outdated and inefficient equipment, further reducing our operational costs.
What role does advocacy play in cybersecurity for operational technology?
All of this technology is changing, and everything is connected in some way. As a trustee on the Fire Protection Research Foundation (FPRF), I have been advocating for research in this area.
The FPRF is starting this research by looking primarily at fire protection systems and identifying what is and can be connected to the web. In initial discussions, it has been eye-opening for building owners who have been looking into these risks. The owners who initially said they knew everything that was connected found out that they didn’t. And those items that they didn’t know about were major security vulnerabilities!
Michael Hrickiewicz is editor-in-chief of Health Facilities Management magazine.