Healthcare Exceptions
Measure Overview
The proposal seeks to eliminate selected exceptions for healthcare facilities in the building energy code. Specifically, for new construction, it would remove or revise exceptions in Sections 120.2(e), 140.4(d), and 140.4(m) in Title 24, Part 6. For existing buildings, the exceptions would be modified or removed in Sections 141.0(b)2.
For new construction, the removal or modification of exceptions is centered around HVAC system requirements. However, as healthcare facilities must comply with other national standards, state codes and the requirements of California Department of Health Care Access and Information (HCAI), (formerly the Office of Statewide Health Planning and Development (OSHPD)), the changes impacting Sections 140.4(d) and 140.4(m) would modify the exceptions to comply with standards called out in ASHRAE 90.1 (Section 6.5.3.2.4), and the California Mechanical Code (CMC) Table 4A, to maintain the required pressure and air flow for these spaces.
For existing buildings, exceptions for healthcare facilities are centered around building envelope, HVAC, and lighting requirements. However, rather than a wholesale approach to removal of all exceptions, threshold limits would be studied to allow for a cost effective update for alterations and additions for healthcare facilities.
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This measure page will be updated as the 2028 code cycle progresses. For questions or suggestions, email [email protected]. Please include the measure name in the subject line.
Scope of Proposed Code Change
| Building Type(s) | Construction Type(s) | Type of Change | Updates to Compliance Software | Third Party Verification |
| Nonresidential | New construction, additions, alterations | Mandatory, prescriptive, performance | Update existing feature, add new feature | Update existing verification requirements, add new verification requirements |
Justification for Proposed Change
The proposed code changes would have positive impacts in both energy savings and compliance improvement. By removing exceptions or modifying them, healthcare designers and builders have a more consistent building energy code requirement across the non-residential spaces.
Energy savings would come from allowing HVAC systems to turn down to more efficient levels in zones and sections of the healthcare facility where it would be safe to do so. Improving building envelopes, lighting, and HVAC requirements for existing buildings without compromising occupant safety by aligning with relevant CMC requirements.
The proposed measure would have an added benefit of aligning the HCAI requirements with Title 24, Part 6 requirements, which in turn helps to reduce code complexity and potential for conflicting code requirements.
There are exceptions for healthcare facilities throughout the Title 24 Part 6 requirements, and this has been an interest to both California Energy Commission (CEC) and HCAI to bring an alignment for building energy codes in healthcare facilities. By focusing on a few large energy saving exceptions, this would hopefully be the first step in addressing all exceptions to healthcare facilities in subsequent code cycles.
Relevant Documents
Round One Utility-Sponsored Stakeholder Meeting Materials
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