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Plans . . ao SCA oo 00 o© f o o o co L) JC �,C\s no 0 0 0 0 0 oo o 00 0 0 0 0 0 00 00 OD ARCHITECTS O ok.�P = l, �� C O 0 O O C O 0 00 0 �o 0 O 00 0 0 July 25, 2017 - 0° 0 0 C Mr. Mark Van Domelen Building Official 0 City of Tigard Re: Elimination of Door Closers on Resident Units Madrona Recovery Center(Building A and B) Permit#: BUP2017-00084 and BUP2017-00092 Mr. Van Domelen Thank you for taking the time to meet with us on site two weeks ago and walk the building to help evaluate the existing conditions and applications. As you are aware one of the items that came up during discussion was the removal of the required door closers on the resident sleeping rooms. Below are the paths we took to establish the rating criteria and necessity for the closers: • 310.6.2 Residential Group R-4, Condition 2,Alcohol & Drug Centers. • 420.2 Separation walls. Walls separating sleeping units in the same building, and walls separating dwelling units or sleeping units from other occupancies contiguous to them in the same building shall be constructed as fire partitions in accordance with section 708. • 708.3, Exception 1. Corridor walls permitted to have % hour fire-resistance rating by table 1018.1 • 708.6 Openings. Openings in a fire partition shall be protected in accordance with Section 716. • Table 716.5: Minimum fire door rating in a 30-minute fire partition to be 20-minutes. • 7.16.5.9 Door Closing. Fire doors shall be self-closing or automatic closing in accordance with this section. Both of the buildings are providing the code required NFPA 13 Fire Sprinkler system, and Fire/Smoke Alarm Systems. After discussion with our client they have decided that they would like to ask for the removal of the closers on the resident sleeping rooms. They have prepared a letter explaining the additional operational measures they will take and the safety risks that this population serves. We appreciate your time and consideration in reviewing this request. If you have any additional questions, please feel free to reach out to me. han u. City of figard Approved Plans Kirk Sund,AIA — 1=.= 7 Principal CB Two Architects SITE COPY CB I Two Architects LLC I 500 Liberty St SE Suite 100 Salem,Oregon 97301 P:503 480-8700 cbtwoarchitects.com 0 00 00 00 0 0 0 00 r3 0 0 0 0 0 0 0 0 0 0 0 7 0 00 00 0 0 O 0 0 CV 0 0 0 c o O 0 0 0 0 0 00 madrona recovery 0 0 0 O 0 0 0 0 7000 SW Varns Street• fcgard, 9P 97223 0 City of Tigard Permit Center 13125 SW Hall Blvd. Tigard, OR 97223 July 20, 2017 Dear Building Inspector: As the President of Madrona Recovery, I take safety very seriously. In a highly structured and intensively staffed, 24-hour care environment, Madrona Recovery will provide treatment services to troubled teens struggling with psychiatric and addiction problems.Almost all the individuals whom we will serve will present with some degree of danger to themselves(i.e.,suicide).Our"Job#1" is to keep them safe. In accord with the Oregon Structural Specialty Code,the purpose of this letter is to request a modification to help us succeed at Job#1. 104.10 Modifications.Wherever there are practical difficulties involved in carrying out the provisions of this code,the building official shall have the authority to grant modifications for individual cases,upon application of the owner or owner's representative,provided the building official shall first find that special individual reason makes the strict letter of this code impractical and the modification is in compliance with the intent and purpose of this code and that such modification does not lessen health, accessibility,life and fire safety,or structural requirements.The details of action granting modifications shall be recorded and entered in the files of the department of building safety. Your role is critically important. With great respect,we understand that you are charged with the administration and enforcement of building regulations,and with that authority comes considerable responsibility.We also understand that no matter how detailed the building code may be,you must,to some extent,exercise your own judgment in determining code compliance.You have the responsibility to establish that the structures in which the citizens of the community reside and the buildings in which they work are designed and constructed to be structurally stable,with adequate means of egress, light,and ventilation,and to provide a minimum acceptable level of protection to life and property from fire. Fire safety codes are important.They minimize the risk of harm to occupants. You well know that when trying to assure people will live in a safe-built environment, it is imperative to understand how a building is intended to be used. Permit us to elaborate on that subject. To begin,the code classification system for buildings is based upon how the building is intended to be used.We are classified as R-4. Because of the relatively high fire risk and potential for loss of life in buildings classified in Groups R,the most stringent provisions for the protection of life are in these occupancies.Most of the nation's fire problems occur in Group R buildings. More specifically, one and two- family dwellings account for more than 80 percent of all deaths from fire in residential occupancies and about two-thirds of all fire fatalities in all occupancies. One-and two-family dwellings also account for more than 80 percent of residential property losses and more than one-half of all property losses from fire.There are several factors contributing to this. 00 00 00 0 0 0 0 0 0 ) 0 0 0 O 0 u 0 O O 0 0 0 0 ) 0 c0 00 o Ou 0 0 Structures in the residential occupancy usually houseAhe widest rarge of occupant tripes(i.e., infants to the aged)and for the longest periods of time.As such, residential occupancies are more susceptible to the frequency of careless acts by the occupants. In contrast,our clients will be age 12 to 17,and our staff will n n n o 0 - on on all be competent adults. Our clients are expected to 3tay'Vwo t�tiroe vreel's.They are continuously monitored/supervised by our 24-7 staff(facility-wide ratio exceeding t )staff to ane client)who stay eight to ten hours per shift. In addition, more than 23 security cameras will be strategically placed throughout the facility and grounds to augment/enhance our surveiljagce abilities. Of comae,for privacy's sake there are no cameras in bedrooms or bathrooms. Most residential occupants are asleep approximately oile-third oicevery 24-hour period.When sleeping, they are not likely to become immediately aware of a developing fire.Also, if awakened from sleep by the presence of fire,the residents often may not immediately react in a rational manner and delay their evacuation.In contrast, Madrona Recovery will have at least two staff members in each building on duty throughout the night,awake and properly trained in emergency procedures.All our occupants will be physically and mentally able to actively participate in a complete building evacuation during an emergency and are capable of self-preservation. Moreover,every client will be trained in emergency evacuation procedures,and drills will be conducted (and documented)at least once per shift per quarter(monthly). Our facility will have fire detection and suppression (i.e.,sprinklers)systems throughout. The fuel load in residential occupancies is often quite high, both in quantity and variety.Also, in the construction of residential buildings, it is common to use extensive amounts of combustible materials. In contrast, Madrona Recovery's choices in design and materials are mindful of minimizing combustibles. Our clients'short stays will further reduce the number of belongings in the buildings. Moreover,all clients' belongings are searched upon admission,and contraband (including any means of fire ignition and items that are highly flammable)are sent back home with their parents. Another portion of the fire problem in residential occupancies relates to the occupants' lack of vigilance in the prevention of fire hazards. In their own domicile or residence, people tend to relax and are often prone to allow fire hazards to go unabated.Thus, in residential occupancies,fire hazards tend to accrue over an extended period of time and go unnoticed or are ignored. In contrast, Madrona Recovery staff will be thoroughly trained in identifying potential fire and safety hazards. Formal hazard surveillance will be conducted and documented daily. Suicide prevention strategies are important.They minimize the risk of harm to clients. The risk of suicide in our kind of setting is estimated to be 675%higher than the risk of fire(The Joint Commission, 2017). Inpatient suicide was the most common sentinel event reported to the Joint Commission on the SENTINEL EVENTS 2005 - 2016 Accreditation of Healthcare Organizations over a 10-year period (1995 to 2005)and the fourth leading sentinel event between 2005 and 2016. In addition to the human tragedy,about 1 of 2 1,013 TatTSSSitltSatt inpatient suicides will result in a suit/claim srr«;de (James L. Knoll IV, 2012). Understandably, courts and juries generally perceive inpatient 1 50 Td units as having a greater degree of control over Fire the patient,and thus,a greater responsibility to prevent suicides. The Joint Commission,the organization that provides Madrona Recovery's accreditation, explicitly mandates that we "conduct a risk assessment that identifies... environmental features that may increase 19 33 9 3 9 3 33 D. 0 3 9 9 9 0 3 9 '33 J' J 3 3 :) J '3 or decrease the risk for suicide"and act to address tht)sti risk3points 1National PatiertSafety Goal 15.01.01) (The Joint Commission, 2017). Beginning in March 2017,the Joint Commission is emObasixing assessment crl,ligait4e,suicide,and self- harm observations in psychiatric hospitals and inpati n1p y�hiat?icpat,;ent areas i general hospitals.A March 1, 2017,Joint Commission Online article details specific steps se veya1' Wil take during on-site surveys to document all observations of ligature or self-harm risks in the environment. Each observation of a ligature or self-harm risk will be considered a requircroz.nZ ifoqrqvgmpt(RFS). Survey findings at the highest level of risk may trigger consideration of whether an imr 'diet'Threat to Life(ITL)exists while the surveyors are on-site and result in denial of accreditatich (The,Joint Cor n isiicr,2017). Setf-closing or automatic closing bedroom doors will compromise our ability to effectively implement protective precautions for suicidal clients.Thus, we are requesting a modification to the last item (as it pertains to bedroom doors) in this list of interrelated codes that apply to our buildings. • 310.6.2 Residential Group R-4, Condition 2 • 7.08.6 Openings. Openings in a fire partition shall be protected on accordance with Section 716. • Table 716.5: Minimum fire door rating in a 30-minute fire partition should be 20 minutes. • 7.16.5.9 Door Closing. Fire doors shall be self-closing or automatic closing in accordance with this section. "How will self-closing bedroom doors compromise your ability to effectively implement protective precautions for suicidal clients?"You might ask. For more than 10 hours of the day, closed bedroom doors will not be a problem. For safety,the doors will be closed and locked when clients are not in their bedrooms. Clients will be actively engaged in therapeutic activities elsewhere. However,during bedtime and occasional breaks during the day, observing/monitoring clients who are behind closed doors is problematic. Installing viewing windows into the doors was considered, but blind spots seemed inevitable, and the utility of viewing windows can be quickly and easily nullified by a resourceful,desperate client with something as simple as notebook paper or a towel. The most common method for individuals in the community to commit suicide is with firearms.Since clients in treatment settings like ours do not have access to firearms,the most frequent methods of attempting suicide are by hanging or by cutting themselves with a sharp object.Seventy-five percent of inpatient suicides occur in the patient's bathroom, bedroom,or closet(Joint Commission Resources, 2007). "How will automatic closing bedroom doors compromise your ability to effectively implement protective precautions for suicidal clients?"You might ask. "The doors could be completely closed or completely open until they are triggered to close by the smoke/fire detection system." Critical areas for concern in treatment settings like ours are ligature attachment points (places from which a person could hang themselves)—particularly any ligature attachment points in areas where clients are provided privacy or are otherwise unobservable by staff(such as in their bedrooms with the doors closed). Doors and door hardware(including the mechanisms used for automatic closing) are the most common ligature points patients use to hang themselves, by far the most common method of suicide in healthcare facilities (Joint Commission Resources, 2007). 3 31 03 31 3 3 3 '3 3 3 '3 3 3 3 3 3 3 3 3 .3 3 3 1 ,3 3 3 33 33 3 0 3 3 3 '3 3 3 3 3 3 33 3 3 3 3 Typical Automatic Door Closer Haro vo e o 3 3 0.3 3 3' 3 3 3 333 `3 3 3 3 3 3 1 3 03 3 3 3 73 7 3 3 3 3 3 3 30 ` 3 O 3 ) 7 'l 3 :7 3 ) 3 3 3 3,3 3 3 ) 3 3 3 3 3 3 3 3 3 3 3 3 "Why not just ask your clients if they are suicidal and check on them very frequently—at least every fifteen minutes or so?" "It only takes 4 or 5 minutes of adequate pressure on the carotid arteries in a person's neck to produce death by oxygen deprivation to the brain.Thus... 15-minute suicide watches tend to allow a patient sufficient time to commit suicide...Almost any article of clothing and any protruding object can be utilized for self-asphyxiation."(Maris RW, 1992). A problem that is cited over and over again in sentinel event reports, peer reviews,and malpractice litigation cases involve"inadequate monitoring and protection of new patients with moderate or high suicide risk,or with unknown risk" (Reid, 2010). Experts caution that just asking and watching are inadequate. "It is important to keep in mind that even clients who respond honestly may misunderstand their own symptoms,condition,and level of risk(Reid,2010).They may not be capable of predicting their future condition, impulses,and behaviors, particularly in the midst of(1)a psychiatric illness severe enough to warrant inpatient admission,and (2)a life crisis that typically precedes some admissions." Inpatient suicide rates correlate strongly with the admission rate(Bowers L,2010).The first week of a client's admission to the facility is considered a clear, high-risk period (Qin P,2005).With an average length of stay of only three weeks, up to one third of all our clients at any given time will meet this risk criterion. Clients can and do commit suicide while on 15-minute checks. In a study of 76 patients who committed suicide while in the hospital or immediately after discharge, 78%denied suicidal ideation when last asked, and 51%were on 15-minute checks or 1:1 observation (Busch KA, 2003). The physical environment itself must also be made as safe as possible. With these considerations in mind,we respectfully request a modification such that our bedroom doors have the ability to be open,closed,or only partially closed when clients are physically present.This allows us to individualize the safety precautions and care of each client as we hold in tension their privacy needs, their psychiatric needs,and their fire protection needs. During the day time, having the door partially open while the client is in their bedroom • allows us to fully view the entire room compared to having a completely closed door • allows us to quickly poke our head in occasionally to make our presence known • deters the client from hurting themselves compared to having a completely closed door • limits noise compared to having a fully open door • provides some degree of privacy compared to a fully open door 3 33 33 33 3 3 3 3 3) 3 3 3 3 3 3 3 3 3 3 3 19 3 3 33 33 3 3 3 3 3 333 3 3 33 3 -3 3 3 Similarly, at night having the door partially open while the client is3in3their badroon 3 3 3 • allows us to view their person and the entire room compared to having a completely closed door • allows us to frequently check on their welfare without distuxbing,tihir sl 'e.p with the, ois nd light 3 3associated with opening the door 3 3 3 3, 3 3 3 93 3 3 3 n • deters the client from hurting themselves compared to having aComplehly krsed dUOr • allows less noise and light from the corridor, making for more restful sleep compared to having a fully open door • provides the perception of some privacy compared to a fully open ioo".) 3 Thus,we are proposing that when clients are in their bedrooms,their doors may be open, closed, or partially closed, depending on their individual safety needs.When clients are not physically in their bedrooms,their doors will always be closed and locked.This also includes when there is an emergency evacuation.All clients will be accounted for and evacuated;their bedroom doors will be closed and locked behind them. Since staff are always present in the corridor when clients are in their bedrooms, it is natural for these actions to occur simultaneously. Our policies, procedures,and drills will reinforce this practice. In summary, not having closers on the bedroom doors compromises the integrity of the fire partitions in the sleeping room corridors and thus, increases the risk of harm during a fire. Our procedures and practice will mitigate this risk.At the same time, not having closers on the bedroom doors would dramatically improve our ability to effectively observe/monitor/protect at-risk youth and also eliminate ligature attachment points,thus reducing the risk of a client harming themselves or committing suicide.The risk of suicide in our setting is much greater than the risk of fire.We would very much appreciate your support in our succeeding at Job#1 - keeping vulnerable people safe. Thanks for your careful consideration of our individual case.We would welcome any questions and an opportunity to explain this matter more fully,face-to-face. Sincerely, John Thornton, CEO O OC CO 00 O 0 0 0 00 O 0 0 0 0 O 0 0 O 0 0 O 0 O C^ 7 O 0 f 0 0 ,O O 3 0 O 0 References Joint Commission Resources. (2007).Suicide Prevention:Toolkit for Implementing National Patient Safety Goal O O O O 00 G^ O 15A.64. c, 0 Bowers L, B.T. (2010).Suicide inside:a systematic review of inpatient suicides.J Nery Ment Dis,198:315-328. Busch KA, F.J. (2003). Clinical correlates of inpatient suicide.J Clin Psychiatrr,-64:44-19, James L. Knoll IV,M. (2012,May 22).Inpatient Suicide:Identifying Vulne abiltty ih the 4csp'ta'S?tt+ng. Retrieved from Psychiatric Times: http://www.psychiatrictimes.com/suicide/inpatient-suicide- identifying-vulnerability-hospital-setting Jayaram G,S. H. (2010).The utility and effectiveness of 15-minute checks in inpatient settings. Psychiatry (Edgmont).,7:46-49. Maris RW, B.A.(1992).Summary and conclusions:what have we learned about suicide assessment and prediction? In B.A. Maris RW,Assessment and Prediction of Suicide. (p. 663). New York:Guilford Press. Qin P, N. M. (2005).Suicide risk in relation to psychiatric hospitalization:evidence based on longitudinal registers.Arch Gen Psychiatry.,62:427-432. Reid,W.(2010). Preventing suicide.2010;.J Psychiatr Practice, 16:120-124. The Joint Commission. (2017,July 18).Behavioral Health Care National Patient Safety Goals. Retrieved from Joint Commission: https://www.jointcommission.org/assets/1/6/NPSG_Chapter_BHC Jan2017.pdf The Joint Commission. (2017, March 1).Now effective:Surveying,scoring of ligature,suicide,self-harm in inpatient psychiatric setting. Retrieved from Joint Commission: https://www.jointcommission.org/issues/article.aspx?Article=gyekSlHbR9Hi6%2fCHXVKFw2XUfze5Q3 AXIdxy7eEkhZM%3d The Joint Commission. (2017,July 18).Summary Data of Sentinel Events Reviewed by The Joint Commission. Retrieved from Joint Commission: https://www.jointcommission.org/assets/1/18/Summary_4Q_2016.pdf