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Comment <strong>and</strong> Process Review<br />

The decision <strong>of</strong> OSHPD plan review <strong>and</strong> field staff as it relates to interpretation <strong>of</strong> the CBSC may<br />

be appealed by a hospital or its design team or contractors if it is felt that the interpretation is in<br />

error. There are both in<strong>for</strong>mal <strong>and</strong> <strong>for</strong>mal processes <strong>for</strong> appeals, each with its own timing <strong>and</strong><br />

mechanisms.<br />

The Comment <strong>and</strong> Process Review (CPR) mechanism is established by OSHPD as a method <strong>for</strong><br />

a hospital owner or its consultants to have persons <strong>of</strong> increasing authority review code<br />

interpretations made by first-line plan reviewers <strong>and</strong> field personnel. This in<strong>for</strong>mal process is as<br />

follows:<br />

Step 1: Review with the Comment Originator<br />

The plan review staff <strong>and</strong> field staff are responsible <strong>for</strong> rendering judgments regarding<br />

applicability <strong>of</strong> the building code. If the hospital or design team object to an interpretation <strong>of</strong> the<br />

code as expressed through the comments made by OSHPD staff, the first step <strong>of</strong> the process is to<br />

discuss the difference <strong>of</strong> opinion with the staff person who originated the interpretation. This<br />

allows <strong>for</strong> disputes to be resolved at the lowest level.<br />

Step 2: Appeal to the Supervisor<br />

If the matter is not resolved satisfactorily with the staff member, the issue may be appealed to the<br />

Regional Supervisor or the Regional Compliance Officer who supervises the originator <strong>of</strong> the<br />

code interpretation. The Supervisor may uphold, overturn, or modify the interpretation as is<br />

determined to be appropriate. The Supervisor’s ruling then becomes effective.<br />

Step 3: Appeal to the Division Chief<br />

If the matter is not resolved satisfactorily with the supervisor, the issue may be appealed to the<br />

Division Chief over the region involved in the dispute. The Division Chief may uphold, overturn, or<br />

modify the interpretation <strong>and</strong> may seek guidance from other supervisory personnel who serve as<br />

subject-matter experts over the disciplines in question or from other OSHPD staff as appropriate.<br />

The decision <strong>of</strong> the Division Chief marks the end <strong>of</strong> the in<strong>for</strong>mal appeal process.<br />

Hospital Building Safety Board<br />

Once the in<strong>for</strong>mal process has been exhausted, the issue may enter the <strong>for</strong>mal appeal process by<br />

being submitted <strong>for</strong> judgment to the Hospital Building Safety Board (HBSB). The HBSB, a<br />

statutory body appointed by the governor, serves two purposes:<br />

• To advise the Director <strong>of</strong> OSHPD on the administration <strong>of</strong> the Hospital Facilities Seismic<br />

Safety Act, <strong>and</strong><br />

(OSHPD <strong>Best</strong> <strong>Practices</strong>) Page 103 DRAFT FINAL, Sept. 2011

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