1010 SE EVERETT MALL WAY NORTHWEST KIDNEY CENTER - EVERETT 2022-03-07

0 1 0 BUILDING PERMIT I CYCLE 01 CORRECTION RESPONSES NORTHWEST KIDNEY CENTERS I EVERETT KIDNEY CENTER 1010 SE EVERETT MALL WAY, SUITE 104, EVERETT, WA 98208 PERMIT NO. 131912-020 Regarding the question of ambulatory care classification, dialysis facilities are = considered ambulatory care facilities. The 2015 IBC defines an Ambulatory Care Facility as "Buildings or portions thereof used to provide medical, surgical, psychiatric, nursing or similar care on a less than 24-hour basis to individuals who are rendered incapable of self-preservation by the services provided. Under this definition, a dialysis facility is not an Ambulatory Care Facility. Dialysis patients are DDI rendered incapable of self-preservation. No dialysis patients are anesthetized during treatment and per the Federal requirements for End -Stage Renal Disease Facilities (ESRD] 494.60(d)(2) each dialysis patient is trained and capable of emergency disconnect from their dialysis treatment and evacuation from the building. The 2015 IBC Code Commentary for the definition of an Ambulatory Care Facility further clarifies: Ambulatory care facilities, while still classified as a Group B occupancy, have additional standards above those of an outpatient clinic because its patients are temporarily unable to respond to emergencies due to treatment processes. Ambulatory care facilities include day surgery centers and similar facilities where patients may receive fairly intensive treatment, but do not stay at the facility more than a. few hours. The care practices of a dialysis facility do not meet the definitional requirements for an Ambulatory Care Facility per the IBC. This position is corroborated by the Centers for Medicare and Medicaid Services'; GMS) analysis of the Life Safety Risks posed to dialysis patients. In its ruling, RIN 0938- AQ96 [CMS-9070-F] with an effective date of 16 July 2012, CMS determined that the Ambulatory Surgical provisions of the NFPA Life Safety Code should NOT be applied to End -Stage Renal Disease (ESRD) Facilities. Their rationale is fully laid out in the attached PDF. (For your convenience, we have highlighted the relevant detail within the document.) In summary CMS's analysis of the Life Safety Risks finds: 1. Smoke Compartmentalization is UNNECESSARY because dialysis patients are trained in how to rapidly disconnect themselves in on emergency and safely exit the building. (See pages 4 & 7 of Federal Register Vol. 77 No. 95) 2. ESRD Facilities have a low life -safety risk and as a use type ranked lowest at 0.1 % in fire incidents amongst all healthcare facilities. (See page 4 of Federal Register Vol. 77 No. 95) 3. Dialysis Patients are NOT anesthetized and are trained in emergency disconnect. (See page 4 of Federal Register Vol. 77 No. 95) 4. Staff are required to be present on the patient floor at all times and are therefore able to assist in emergency evacuation. (See page 4 of Federal Register Vol. 77 No. 95) CMS does limit their interpretation that Ambulatory Care requirements 11Qt apply to ESRD facilities meeting the following characteristics: 1. At grade level with direct egress to the exterior (Northwest Kidney Center's Bellevue Kidney Center has the dialysis treatment area located on the first floor and complies with this requirement) 2. NOT adjacent to a "High Hazardous Occupancy' as defined by the NFPA 101 (Bellevue Kidney Center complies with this requirement) CMS's analysis of the real -world Life Safety risks posed by dialysis clinics aligns with an interpretation of the 2015 IBC that would not classify a dialysis clinic as an Ambulatory Care Facility. The occupancy classification B Occupancy, outpatient clinic has thus been used for the project with fire partitions provided per IBC Table 509 200115 B1912-020 (Building Permit Corrections 1 - Response) �Page2 W,, 71 COLUMBIA. FLOOR 4. SEATTLE, WA 98104 1 1380 SE 9TH AVENUE. PORTLAND. OR 97214 1 MAHLUM.COM