Compliance News: Evolution of Utility System Technology
Hospitals are dealing with the issues of utility system equipment technology failures and managing the need for ongoing technology upgrades as equipment designs evolve.
Many hospitals have varying generations of utility system digital control technology built into major electrical, mechanical, vertical transportation, etc. operating components that were installed over the past few decades.
Examples include digital technology equipment such as programmable logic controllers (PLCs)1 or other digital control components embedded within major operating components such as:
- Main normal power automatic switchgear controls
- Emergency power paralleling switchgear controls
- Building automation systems and air temperature control systems
- Other complex heating, ventilating, and air conditioning equipment
- Vertical transportation systems such as master controls serving large banks of elevators
- Control equipment serving other types of utility infrastructure components
This technology can fail just as any other electrical or mechanical component can fail. Since the technology components are likely to have been 3rd-layer or 4th-layer components that were part of a much larger operating system, the hospital may have difficulty reaching a reliable current source of service or repair when the failure occurs.
We also need to understand the utility equipment infrastructure risks related to cybersecurity and potential hacking from outsiders. The cyber security risks to medical equipment and patient safety were highlighted by ECRI in its 2015 list of Tip 10 heath technology hazards. We know that there have been ongoing hacking attempts to utility infrastructure equipment as identified by the US Department of Homeland Security. Due diligence would indicate the need to at least investigate the potential for hardening of existing critical digital control equipment.
The original equipment manufacturer is likely to have been acquired by one or more other organizations since the original equipment was provided years earlier. Additionally, as some hospitals are discovering to their dismay, ongoing technological evolution since the equipment was first installed has resulted in the original supplier no longer being willing to support the older generation technology. And those decisions may not have been communicated to the necessary people within the hospital because of personnel and organizational changes within organizations.
Consider the historical means by which technology was installed within a hospital. If it was part of a construction or major renovation project, it was probably purchased and installed by a contractor years earlier. If it was installed directly by the hospital as part of an infrastructure renewal program, it may have been purchased by Materials Management or previous facilities management personnel. The corporate records can be adversely affected by ongoing changes within healthcare facilities themselves or between healthcare facilities as corporate-level and system-level changes occur.
A potential adverse effect of change is that the ability to maintain communications with 3rd-tier or 4th-tier equipment manufacturers can fall by the wayside.
The purpose of this article is to begin a discussion of this and related issues.
- Have you thought about this issue before?
- We have heard that hospitals are surprised to hear that critically important PLCs controlling their main utility equipment have failed and are no longer supported. Has this type of issue adversely affected your organization yet?
- Do you have a proactive process for maintaining communication with 3rd-tier and 4th-tier critical equipment manufacturers?
- If so, is it effective?
- How do you know?
- How does your process reflect the realities of marketplace transformation?
- If you have not yet started this process, how would you intend to commence it?
Please reply to the writer at DStymiest@ssr-inc.com. I will share the results in a future newsletter article.
1 “A programmable logic controller, PLC, or programmable controller is a digital computer used for automation of typically industrial electromechanical processes…” “…PLCs are used in many machines, in many industries.” (from Wikipedia)