Our tenure in consensus standards development for education facilities (see ABOUT) may enlighten local, state and federal authorities about the present status of leading practice discovery as reflected in the action of ANSI accredited and open source standards. Since local first-responders are aligned with the building and fire codes we follow the development of the documents that establish the standard of care for their responsibilities. Some of the most recent action within the more familiar standards suites is linked below:
This is a timely, subtle and complicated issue for the education industry to resolve. The overwhelming question — upon which good minds will disagree — is this: How much of this can be resolved by the federal government versus resolution at the state, local and institutional level?
Market incumbents (whom we identify in our ABOUT) want to develop regulations at the national level because they have the financial resources to operate in Washington, D.C where so many education industry trade associations are domiciled and have their influence. In other words, they will seek a politically visible “top-down” solution that they write and administer.
On the other hand, school districts, colleges and universities may prefer local adaptations of regulatory products developed by ANSI accredited standards developers with which their front line subject matter experts in building, fire, electrical and public safety codes are already trained. Standards developed at this level — and, ideally incorporated by reference by federal agencies, offer the greatest degree of transparency and stakeholder involvement. Unfortunately, much of the leadership of the education industry is not involved in the US standards community. (See videoclip below)
Since our business model does not depend upon revenue from membership, publication royalties, conference attendance, continuing education credits for conformity assessment credentials we are relatively free to operate as a watchdog on the standards action of all the incumbents (and newcomers) in this space.
Education facility security standards are a standing item on our weekly Open Door teleconference — every Wednesday 11 AM Eastern time. Click here to log in.
Category: Public Safety, Public Policy
Colleagues: Mike Anthony, Richard Robben
S. Joe Bhatia | CEO American National Standards Institute | University of Michigan Ross School of Business | October 2015
We follow, but do not advocate in, a suite of consensus standards developed by theFinancial Accounting Standards Board (FASB) — among them, documents that discover and recommend best financial management practice for not-for-profit organizations common in almost all of the US education industry.
Today, we simply pass on an announcement posted on the FASB website about a June 15th webcast during which there will be some content that would interest financial professionals in the education industry:
We have seen an acceleration in the growth in website visitors over the past few months. We would like to reach out specifically to the vast constellation of education industry trade associations who visit Standards Michigan as a resource for streaming content relevant to their advocacy goals.
“Pythagoras and the beautiful Theano” (1913) | Artist unknown
We track broad policy trends, but do not advocate our agenda, in the legislative precincts of the US federal government. There is plenty of work to do in technical, management, safety and sustainability standards for the emergent #SmartCampus. Education policy is a space crowded with “market incumbents”, so to say, as some of the related links below should reveal. Sorting through the Orwellian fog, we see the broad contours of emergent legislation that will likely have some affect on the flow of money to the physical characteristics of our cities-within-cities.
On May 7th, Senate bill S 2791 – A bill to amend the Higher Education Act of 1965 to provide grants for institutions of higher education to prevent substance abuse, and for other purposes — was logged into the US Senate’s legislative calendar.
A summary is now in progress and will be posted at this link: Congress.GOV
Promoting Real Opportunity, Success, and Prosperity through Education Reform: Prosper Act
We see how other industries apply technical and business standards to meet their organizational goals so it is natural for us to ask about the degree to which adoption of privately developed consensus standards accredited by the American National Standards Institute would be an effective tool for driving down the cost of higher education in the United States. Education — about 4 percent of gross domestic product — is an industry which, arguably, is built upon a foundation standards and related accreditation enterprise. A baccalaureate degree is, after all, a standard.
Even as the legislative activity on revising/reauthorizing the Higher Education Act of 1965 is already in motion* we see three related developments that might enlighten understanding about how standards support regulation, and how regulation determines cost:
The number of organizations accredited by the American National Standards Institute as accredited standards developers for documents suitable for incorporation by reference by federal, state and local agencies has grown steadily.
December 1, 2017 Update from the House Committee on Education and the Workforce: (Click here)
The parent legislation for the US higher education industry is the Higher Education Act of 1965; available in its entirety at this link:
AN ACT: To extend the authorization of programs under the Higher Education Act of 1965, and for other purposes.
The sections of interest to us are highlighted below:
‘‘SEC. 143. ADMINISTRATIVE SIMPLIFICATION OF STUDENT AID DELIVERY.
‘‘(a) IN GENERAL.—In order to improve the efficiency and effectiveness of the student aid delivery system, the Secretary and the Chief Operating Officer shall encourage and participate in the establishment of voluntary consensus standards and requirements for the electronic transmission of information necessary for the administration of programs under title IV.
‘‘(b) PARTICIPATION IN STANDARD SETTING ORGANIZATIONS.— ‘‘(1) The Chief Operating Officer shall participate in the activities of standard setting organizations in carrying out the provisions of this section. ‘‘(2) The Chief Operating Officer shall encourage higher education groups seeking to develop common forms, standards, and procedures in support of the delivery of Federal student financial assistance to conduct these activities within a standard setting organization. ‘‘(3) The Chief Operating Officer may pay necessary dues and fees associated with participating in standard setting organizations pursuant to this subsection.
‘‘(c) ADOPTION OF VOLUNTARY CONSENSUS STANDARDS.—Except with respect to the common financial reporting form under section 483(a), the Secretary shall consider adopting voluntary consensus standards agreed to by the organization described in subsection (b) for transactions required under title IV, and common data elements for such transactions, to enable information to be exchanged electronically between systems administered by the Department and among participants in the Federal student aid delivery system.
‘‘(d) USE OF CLEARINGHOUSES.—Nothing in this section shall restrict the ability of participating institutions and lenders from using a clearinghouse or servicer to comply with the standards for the exchange of information established under this section.
‘‘(e) DATA SECURITY.—Any entity that maintains or transmits information under a transaction covered by this section shall maintain reasonable and appropriate administrative, technical, and physical safeguards— ‘‘(1) to ensure the integrity and confidentiality of the information; and ‘‘(2) to protect against any reasonably anticipated security threats, or unauthorized uses or disclosures of the information.
‘‘(f ) DEFINITIONS.—
‘‘(1) CLEARINGHOUSE.—The term ‘clearinghouse’ means a public or private entity that processes or facilitates the processing of nonstandard data elements into data elements conforming to standards adopted under this section.
‘‘(2) STANDARD SETTING ORGANIZATION.—The term ‘standard setting organization’ means an organization that— ‘‘(A) is accredited by the American National Standards Institute; ‘‘(B) develops standards for information transactions, data elements, or any other standard that is necessary to, or will facilitate, the implementation of this section; and ‘‘(C) is open to the participation of the various entities engaged in the delivery of Federal student financial assistance.
‘‘(3) VOLUNTARY CONSENSUS STANDARD.—The term ‘voluntary consensus standard’ means a standard developed or used by a standard setting organization described in paragraph (2).’’. (b) REPEAL OF OLD GENERAL PROVISIONS.—Title XII (20 U.S.C. 1141 et seq.) is repealed. PUBLIC LAW 105–244—OCT. 7, 1998 112 STAT. 1617 (c) REPEAL OF TITLE IV DEFINITION.—Section 481 (20 U.S.C. 1088) is amended— (1) by striking subsections (a), (b), and (c); and (2) by redesignating subsections (d) through (f ) as subsections (a) through (c), respectively.
We provide a link to an overview of the American National Standards Institute in the link below.
The IAPMO Group has launched the 2021 revision cycle for the Uniform Mechanical Code; widely incorporated by referent into public safety law in many states.
BSR/IAPMO UMC 1-20xx, Uniform Mechanical Code (UMC). This code provides minimum standards to safeguard life or limb, health, property, and public welfare by regulating and controlling the design, construction, installation, quality of materials, location, operation and maintenance, or use of heating, ventilating, cooling, refrigeration systems, incinerators and other miscellaneous heat-producing appliances. The provisions of this code apply to the erection, installation, alteration, repair, relocation, replacement, addition to, use, or maintenance of mechanical systems.
This document is developed so that its technical concepts correlate with the Uniform Plumbing Code (UPC). The UPC provides standards and requirements to safeguard life or limb, health, property and public welfare by regulating and controlling the design, construction, installation, quality of materials, location, operation and maintenance or use of plumbing systems. The provisions of this code apply to the erection, installation, alteration, repair, relocation, addition to, use, or maintenance of plumbing systems.
Project Need: Designation of the UMC as an American National Standard has provided the built industry with uniform mechanical standards resulting in a reduction in training costs and product development costs, and in price reduction for consumers. This American National Standard provides consumers with safe mechanical systems while allowing latitude for innovation and new technologies. This project is intended to keep the code current.
Stakeholders: Manufacturers, users, installers and maintainers, labor research/standards/testing laboratories, enforcing authorities, consumers, and special experts. *
The Complete Monograph of proposed revisions for the 2021 Uniform Mechanical Code has been released and available for public review.
Comments are due Jauary 3, 2019. We encourage subject matter experts at the workpoint in the education facilities industry — i.e. tradespersons, foremen, supervisors that have a user-interest point of view (the stakeholder who is the final fiduciary)– to participate in the development of the next revision of the Uniform Mechanical Code. As we explain in our ABOUT we find that standards developers routinely attempt to cultivate the user-interest.
More detailed information about how all stakeholders may participate is available this link: Public Comment Page. You may communicate directly with IAPMO’s standards staff here:IAPMO (International Association of Plumbing & Mechanical Officials) 4755 E. Philadelphia Street Ontario, CA 91761 Office: (909) 472-4241 Gabriella Davis email@example.com
University of Richmond
Since 2012 we have been tracking several IAPMO documents which govern the safety and sustainability concepts in education facilities; among them:
It is noteworthy that the US education industry is not a participant in this global standard which will likely have implications for standards setting for all aspects of educational organizations including the management of Massive Open Online Courses which we have covered in previous posts.
The ISO/TC 288 has reached a milestone with its May 1st of the First Edition (Click on image):
All ISO consensus documents are on the standing agenda of our weekly Open Door teleconferences every Wednesday, 11 AM Eastern time. Anyone is welcomed to Click Here to login and help prepare user-interest comments on documents open to public review:
The Roy G. Cullen Building at the University of Houston is believed to be the first university facility to install an air-conditioning system. (Click image for more information)
The American Society of Heating and Refrigeration Engineers (ASHRAE International) has released an addendum to its Standard 170 Ventilation of Health Care Facilities. The purpose of this standard is to define ventilation system design requirements that provide environmental control for comfort, asepsis, and odor in health care facilities. Click here for the ASHRAE Standing Standard Project Committee 170 landing page.
The proposed addendum revises requirements for filters in the body of the standard, removes Table 6.4, and adds filter efficiencies on a space-by-space basis. The redline can be found on ASHRAE’s Online Standards Action & Public Review Draft page. (Click here)
Comments are due June 10th.
Standards Michigan limits its interest in environmental air systems in healthcare facilities to university-affiliated medical research and clinical delivery enterprises. We acknowledge the American Society for Healthcare Engineering as an identifiable user-interest in this space.* For the most part environmental air system design, construction, operation and maintenance of the ventilation systems of university affiliated healthcare facilities is identical to healthcare facilities elsewhere; though the risk aggregations may be different for university-affiliated healthcare systems since those enterprises tend to have more research square-footage and receive high-risk patients seeking cutting-edge treatment.
We encourage front-line and middle level subject matter experts in a supervisory role in a university-affiliated healthcare system to participate in ASHRAE’s leading practice discovery processes; possibly at ASHRAE’s Annual Conference in Houston, June 23-27th.
All ASHRAE consensus documents — many of them evolving in 30 to 90 day intervals under ANSI’s continuous maintenance process — are on the standing agenda of our regular Wednesday, 11 AM Eastern Time, Open Door teleconference. We have one today. Anyone is welcomed to join it with the login information below:
You can also dial in using your phone. United States : +1 (408) 650-3123 Access Code: 718-914-669
Issue: [13-56], [15-83] and [16-144]
Category: Healthcare Facilities, Mechanical
Colleagues: Larry Spielvogel, Richard Robben
* By listing its corporate sponsors ASHE acknowledges financial sponsorship of user-interest competitor stakeholders identified in ANSI Essential Requirements: Due process requirements for American National Standards (Section 2.3 Balance). The dominance of stakeholders such as manufacturers, insurers, labor, conformity and trade associations that can build their participation cost into the price of the product or service they sell to the user-interest is condition is seen nearly everywhere in the global standards system As we explain in our ABOUT this condition is a wicked problem — a problem not unlike the problem of participatory democracy generally. While lack of participation may never go away entirely — despite clear, due diligence by accredited standards developers — Standards Michigan seeks to at least manage the weakness of the voice of technical and management experts in the ~$300 billion education facilities industry. To some degree, and in some cases, user-interest price signals are conveyed through trade associations.
The education industry – particularly large research universities — are likely stakeholders in this discussion – which NIST will expand outside the policy-making precincts of Washington DC. Standards Michigan collaborates with the American National Standards Institute on issues of this nature.
It is not too soon to begin preparing public input for the 2021 edition of NFPA 101: Life Safety Code. The Life Safety Code is the most widely used source for strategies to protect people based on building construction, protection, and occupancy features that minimize the effects of fire and related hazards. Unique in the field, it is the only document that covers life safety in both new and existing structures.
We have been advocating in this document since the 2003 edition in which we submitted candidate code changes such as the following:
• Student residence facility life safety crosswalk between NFPA 101 and IBC
• Refinements to Chapters 14 and 15 covering education facilities
• Identification of an ingress path for rescue and recovery personnel toward electric service equipment installations.
• Risk-informed requirement for installation of grab bars in bathing areas
• Modification of the 90 minute emergency lighting requirements rule for small buildings and for fixed interval testing
• Modification of emergency illumination fixed interval testing
• Table 7.3.1 Occupant Load revisions
• Harmonization of egress path width with European building codes
There are others. It is typically difficult to make changes to any consensus standard though some of the concepts were integrated by the committee into other parts of the NFPA 101 in unexpected, though productive, ways.
Public input is due June 27, 2018. We reach out to facility managers, subject matter experts and trade associations — collaborating where possible – but at least reporting on the progress made on behalf of the user/owner/final fiduciary in this industry. This document is a standing item on our weekly (Wednesday 11 AM Eastern) Open Door teleconference to which everyone is welcomed. Click here to log in.
Category: Fire Safety, Public Safety
Colleagues: Mike Anthony, Josh Elvove, Joe DeRosier
We follow state adaptations of the NFPA and IEEE family of consensus documents that set the standard of care for electrical safety in education facility design, construction, operation and maintenance; starting with the State of Michigan (a state with a $490 billion gross domestic product; and ranked the 13th largest state in the United States from an economic point of view). The education facility construction industry is a significant part of that $490 billion of economic activity.
We have been advocating for changes to the State of Michigan Electrical Administrative Act that currently requires all electrical work valued above $100 to be installed by a licensed journeyman electrician and inspected by an accredited electrical inspector. The $100 threshold was set decades ago and has never been challenged by another other advocacy enterprise representing the user interest. Almost all of the stakeholders on the present Electrical Administrative Board are stakeholders who benefit economically from the $100 threshold. Much of the reason for the apparent imbalance of interests lies in tradition; but also because no user interest has been present to advocate for a change. As we explain in our ABOUT; the user-interest is the only interest advocating for cost-savings. All the other stakeholders in the US standards system are generating revenue from their participation in the US standards system. Making money is easier to understand than saving money.
This advocacy priority was on the Do-List of the original University of Michigan codes and standards advocacy enterprise which was focused on strengthening the voice of the user/owner/final fiduciary in the promulgation of regulations affecting Michigan educational facilities. Of all the trades covered in the parent legislation — Stille-Derossett-Hale Single State Construction Code Act (Act 230 of 1972)— the electrical power discipline is the only discipline in Michigan building technology regulations that sets a dollar criteria for electrical work to be performed and inspected. While we recognize the need for safe installation of the electrical power chain within a building; we propose another criteria for establishing the requirement for a licensed electrician and a licensed inspector should be determined (as it is in all other construction disciplines administered by the Bureau of Construction Codes, a division of the Department of Licensing and Regulatory Affairs).
As a consequence of the Governor’s Office of Regulatory Reinvention significant changes to both the Bureau of Construction Codes, a division of the Department of Licensing and Regulatory Affairs) have taken place within the past twelve months; which make us optimistic about political support for our proposals. We will be collaborating with our colleagues at Michigan State University to make necessary legislative changes we believe will lower the #TotalCostofOwnership of education facilities in the State of Michigan.
We will refer the Michigan Electric Code, and other state electrical codes the IEEE Education and Healthcare Facilities Committee will host breakout teleconferences with electrical professionals in the education facilities industry as required by the demand for them.
The next meeting of the Michigan Electrical Board is August 16th. We have been attending the meetings in Lansing and have made our proposal to revisit the dollar criteria known to the entire board. Our approach is informal now — during the public hearing section of the meeting. We hope the Electrical Administrative Board will develop another criteria on its own.
Contact: Mike Anthony, Jack Janveja, Richard Robben, Kane Howard
The education industry provides one of the largest markets for biosafety cabinetry manufacturers — particularly large research universities, university-affiliated healthcare enterprises and K-12 science laboratories. When new research square-footage is budgeted the effective cost of this equipment is often difficult to determine; not just in per-unit terms but the degree to which environmental air management systems are affected.
NSF Internationaldevelops a consensus standard for this technology — NSF 49 Biosafety Cabinetry. This Standard applies to Class II (laminar flow) biosafety cabinetry designed to minimize hazards inherent in work with agents assigned to biosafety levels 1, 2, 3, or 4. It also defines the tests that shall be passed by such cabinetry to meet this standard. NSF 49 includes basic requirements for the design, construction, and performance of biosafety cabinets that are intended to provide personnel, product, and environmental protection; reliable operation; durability and structural stability; cleanability; limitations on noise level; illumination; vibration; and motor/blower performance.
Comments are due May 27th. The public may comment directly on the NSF Online Workspace and/or communicate directly with Allan Rose, (734) 827-3817, firstname.lastname@example.org (with copy of comments to email@example.com
Action in the NSF International suite of standards generally track on this page: (Click here). The NSF International suite of standards are a standing item of our weekly Open Door teleconferences every Wednesday, 11 AM Eastern Time, which are open to anyone. Click here to log in.
Category: Risk Management, Occupational Health and Safety
Laboratory at University Leipzig (Institute of Chemistry) 1906
NSF 49 Biosafety Cabinetry applies to Class II (laminar flow) biosafety cabinetry designed to minimize hazards inherent in work with agents assigned to biosafety levels 1, 2, 3, or 4. It also defines the tests that shall be passed by such cabinetry to meet this standard. NSF 49 includes basic requirements for the design, construction, and performance of biosafety cabinets that are intended to provide personnel, product, and environmental protection; reliable operation; durability and structural stability; cleanability; limitations on noise level; illumination; vibration; and motor/blower performance.
NSF 49 is undergoing revisions that are relevant to the teaching and research enterprises in the education industry:
RE: Average inflow velocity. The redline (strike and bold) public review document is available at this link: ANSI Standards Action Page 42. Comments are due March 25, 2018.
RE: Inflow canopy velocity alarms. The redline (strike and bold) public review document is available at this link: ANSI Standards Action Page 98. Comments are due March 11, 2018.
RE: Interlocking with building environmental air systems. The redline (strike and bold) public review document is available at this link: ANSI Standards Action Page 22. Comments are due February 11, 2018.
RE: Hood visibility criteria. The strike and bold document for these revisions are accessible at this link: ANSI Standards Action Pages 35-36.Comments are due January 14, 2018.
The public may comment directly on the NSF Online Workspace. and/or communicate directly with Allan Rose, (734) 827-3817, firstname.lastname@example.org (with copy of comments to email@example.com
Action in the NSF International suite of standards generally track on this page: (Click here). The NSF International suite of standards are a standing item of our weekly Open Door teleconferences every Wednesday, 11 AM Eastern Time, which are open to anyone. Login information is available in the link below: