The Office of State Wide Health Planning and Development, notoriously known as OSHPD, has become the five-letter acronym that will make any California developer, contractor, or engineer cringe. OSHPD, which regulates construction of healthcare facilities, was created by legislation passed following the 1971 Sylmar Earthquakes that collapsed several hospitals in California.
Although the reasoning for OSHPD’s influence in healthcare construction is clear — protecting the safety of patients, staff, and the community — few contractors and engineers come equipped with the experience and knowledge to navigate its murky regulatory waters. Whether it’s the stringent inspection process, highly engineered construction documents, or the strict construction requirements, a lack of comprehensive OSHPD understanding is a recipe for disaster, and is sure to lead to schedule delays and budget busts.
But there is a light at the end of the tunnel: OSHPD has clearly defined the expectations for construction and engineering and provides road maps to successfully guide contractors and engineers through the construction inspection process. Here’s a look at the key factors to keep in mind before you undertake your next healthcare construction project.
To start, the road map for the inspection process is called the TIO, which stands for ‘Testing, Inspections, & Observations.’ This document provides the construction team with a clear understanding of what OSHPD will require, from the notice to proceed with inspection through the contractor’s request for occupancy. Simply put, it’s the project checklist.
A savvy construction team will take advantage of the OSHPD required preconstruction meeting to present the TIO to the Inspector of Record (IOR) for review and approval. At this time, any inspections that the contractor believes to be unnecessary or unrelated to the project scope can be removed from the TIO at the contractor’s request. And, vice versa, the IOR can add missing inspections that will be required, negating the possibility of catching a contractor by surprise.
Once the TIO has been approved, the project team must carry it through to completion. The Area Compliance Officer (ACO) and the Fire Life Safety Officer (FLSO) will require a fully signed-off TIO prior to final inspection. Any incomplete inspections, even if they’re unrelated to the project scope, can delay construction if listed on the TIO.
Although the Architect of Record (AOR) is responsible for the TIO, the contractor and the owner must ultimately answer for any negative consequences caused by a poorly managed TIO and inspection program. Therefore, a well-planned TIO should be seen as a vital tool to guide the project team, instead of becoming a cumbersome document that leads to delays and cost impacts.
So let’s say the contractor installs their respective scope of work per plans and specifications, calls for an inspection, and fails. How is that possible, you might ask? It’s an all too common occurrence within OSHPD construction, as many engineers and architects have difficulty keeping up with copious OSHPD codes, which are continually evolving.
To compound the complexity of changing codes, the IOR may not have time to review all the details of your project until the day of the scheduled inspection when construction is already complete. So, to avoid ripping out that completed work, delaying the schedule and wasting money, make sure your design team is aware of current OSHPD details and standards, and incorporates them into the contract documents.
OSHPD also offers two highly beneficial, voluntary approval programs, the OSHPD Pre-Approval of Manufacturers Certification (OPM) for seismic design of non-structural components, and the OSHPD Special Seismic Certification Pre-Approval Program (OSP) to provide pre-approval of seismic certifications. OSHPD will pre-approve your project plans and specifications, and also provide pre-approved OSHPD details to incorporate in the plans; all you have to do is ask. Voluntarily submitting your project plans through OSHPD’s review programs is well worth your time, as it can help you avoid unwanted schedule delays and cost overages.
A common cause of failed inspections in OSHPD construction is poor scheduling. OSHPD code requires a 48-hour inspection notification from the contractor to the IOR. Most would think that a contractor should be able to plan two days ahead, but with every drywall screw, anchor bolt, and shot pin requiring inspection, inspections can slip through the cracks if a highly detailed construction activity schedule is not in place.
When one inspection slips, it can cause the whole inspection program to stumble, creating a snowball effect of issues. So, plan inspections 48 hours out, monitor construction over the next two days, and constantly communicate with the project IOR to avoid failed inspections.
Improper scheduling in the final weeks of OSHPD construction presents even graver consequences. A final occupancy inspection by the ACO and FLSO must be requested two weeks out. If you fail inspection, leading to a correction notice being issued by the ACO or FLSO, then you must wait an additional two weeks for the ACO and FLSO’s next scheduled site visit to provide final inspections.
Worst case: The contractor fails the final ACO and FLSO inspection. Still, it’s not the end of the world. There is a secret to avoiding the two-week delay: If the ACO or FLSO issues an inspection correction notice, the contractor can request for the power to be put in the IOR’s hands to provide a follow-up inspection once the contractor has taken corrective actions. Simply put, the contractor fixes the issues noted by the ACO and FLSO, and the IOR has the power to issue final sign-off for occupancy on the ACO or FLSO’s behalf.
Instead of requesting courtesy inspections and running around at the last minute, avoid failed inspections and correction notices altogether by maintaining detailed and accurate construction schedules and proactively communicating them to subcontractors.
OSHPD construction is no laughing matter. It’s important to have a thorough understanding of the processes and requirements before jumping into the OSHPD world. To avoid losing big, make sure your design and construction team is comprised of professionals with a wealth of OSHPD expertise.
Hughes Marino’s industry leading Construction Management team has unmatched expertise in every type of commercial building project from tenant improvements to ground-up build-to-suits. With decades of experience in California and beyond, our project managers, engineers and LEED APs offer practical insights for the construction management professional.