Thoughts about Small Medical Clinics

Back in 2002 Section 24 of the Ontario Electrical Code was amended to reflect the changing nature of health care, and to recognize that procedures once reserved for hospitals are now being performed in medial clinics. The scope of section 24 was changed to include all types of health care facilities and not just hospitals. 

The Ontario Safety Authority issued bulletin 24-2-3 at the time. I expect a similar bulletin was released by the BC Safety Authority as well (but a quick search of the BCSA web site failed to uncover one).

Bulletin 24-2-3 contains this text

A '"Health Care Facility" is defined as a set of physical infrastructure elements that are intended to support the delivery of specific health-related services. Examples of Health Care Facilities include but are not limited to hospitals, rehabilitation facilities or group homes that provide extended, multi-level, psychiatric, or intermediate care, outpatient and surgical clinics, dental offices, doctors’ clinics, dialysis units, ultrasound and electro diagnosis (ECG, EEG, EMG) suites, chiropractic clinics, physiotherapy clinics, and physicians’ offices.

OESC Section 24 applies to electrical wiring and equipment within patient care areas of health care facilities and those portions of the electrical systems of health care facilities designated as essential electrical systems. Patient Care Areas are areas within the health care facility that are intended primarily for the provision of diagnosis, therapy, or care. The Electrical Safety Authority (ESA) is responsible to ensure that all electrical wiring and equipment in the health care facility complies with the electrical code, and that wiring and equipment within the patient care areas also complies with the supplementary rules for electrical safety that are contained in Section 24.

So, this is all well and good. The Safety Authority will take responsibility for ensuring that a building containing patient care areas, regardless of size, will comply with the electrical code, including section 24.

But there is another set of standards that applies to patient care areas. This is "CAN/CSA-Z32 - Electrical Safety and Essential Electrical Systems in Health Care Facilities". This standard was initially designed as a handbook for electrical engineers designing hospitals, but it now applies to all patient care areas where CEC section 24 applies. The standard provides many rules about the layout of electrical wiring and conduit, bonding, and such. There is no need to go into the details, but it is worth mentioning that Z32 not only describes what needs to be done, it also lays out a procedure for testing the implementation, and furthermore mandates that such testing be performed by a licensed third party.

This means that when I work on a health care facility there are two "rulebooks" that I am working under - section 24 and Z32. This isn't a problem - I have the training and experience to see that everything proceeds appropriately. But what about a small clinic or tenant improvement ? In those cases the there is no requirement to hire a CRP or engineer. BSCA will be looking out for CEC section 24 but who is looking out to make sure Z32 is properly implemented?

I decided to dig into this. First I checked with our local BSCA electrical inspector. He explained that while he is fully aware of the standard, it is not in the safety authority mandate to enforce it the portions that do not overlap CEC.

Next, I checked with a BOCP inspector. He had not even heard of this standard!

So, in my opinion we have a problem, which I will try and summarize below

For small clinics, tenant improvement there is no requirement to hire a CRP or engineer. In this case there is no engineer or inspector overseeing that the Z32 standard is implemented. This presents a risk to the public, and it also exposes doctors who build small clinics to liability risks that most likely they are not aware of. (The Z32 standard cites the “administrator” as the responsible party, and in a small clinic this is most likely the lead physician (or dentist, or specialist...) 

The solution in my view is simple. All projects located in British Columbia which include a patient care area should be required to produce a declaration from an licensed member of APEG-BC certifying that the patient care wiring has been implemented to professional standards. 

I believe a dialogue is necessary between APEG-BC, BSCA, and BOCP to move this along, and wrote a letter to the association in this regard. I'll add a blog entry if there is some movement on the issue.