Healthcare Compliance Guide

ICRA & ILSM, made practical for facility managers.

What you need to know about Infection Control Risk Assessment and Interim Life Safety Measures before construction begins in an occupied medical environment.

Why ICRA and ILSM exist

Hospital construction is unlike any other commercial build. The patients on the other side of your containment wall are immunocompromised, post-surgical, or on ventilation. A single airborne Aspergillus spore released during demolition can cause a fatal infection. ICRA and ILSM are the regulatory frameworks — codified by the Joint Commission, CMS, ASHE, and AIA — that protect those patients while construction proceeds.

The four ICRA classes

ICRA classifications combine patient-risk groups (Low through Highest) with construction activity types (A through D) to assign a containment class. Class I requires minimal precautions for routine inspection. Class II adds dust-control mats and HVAC isolation. Class III demands sealed hard-wall barriers, negative air, and HEPA filtration. Class IV — used for major demolition adjacent to high-risk patients — adds anterooms, dedicated personnel paths, and daily Infection Prevention monitoring.

Building an ILSM plan

Every healthcare project needs a written ILSM evaluation when construction impairs fire alarms, sprinklers, smoke barriers, or egress. The plan identifies the deficiency, the duration, the compensating measure (fire watch, additional extinguishers, temporary barriers), the staff training requirement, and the documentation trail. Frans Construction's superintendents prepare ILSM documentation jointly with the facility's Safety Officer before mobilization.

What facility managers should require from their GC

Ask for ICRA-certified site supervision, written containment and ILSM plans submitted before mobilization, daily containment-integrity checks, third-party air monitoring on Class III/IV work, after-hours scheduling protocols for sensitive zones, and a single point of contact who attends your Infection Prevention and Safety Committee meetings. These are the non-negotiables for occupied medical construction.

FAQs

Common questions

What is ICRA in healthcare construction?

ICRA (Infection Control Risk Assessment) is a structured, multi-disciplinary process required before any construction or renovation activity in a healthcare facility. It identifies the patient populations at risk, the type of construction activity, and the appropriate infection-control mitigation class (I–IV) — driving requirements like negative-air containment, HEPA filtration, anteroom protocols, and traffic separation.

What is ILSM and when is it required?

ILSM (Interim Life Safety Measures) are temporary fire- and life-safety protections required by the Joint Commission and CMS whenever construction activity deficiencies impair the building's normal life-safety systems. ILSM plans cover fire watch, alternative egress, smoke compartmentation, fire-protection system impairments, and staff training during the work.

Who is responsible for ICRA and ILSM compliance on a project?

Responsibility is shared. The healthcare facility's Infection Preventionist and Safety Officer set requirements; the general contractor implements containment, monitoring, and documentation; and the design team incorporates infection-control and life-safety considerations into drawings and phasing plans. A qualified GC like Frans Construction coordinates all three.

How do you protect patients during an occupied-facility renovation?

Through hard-wall containment with negative-air machines, HEPA-filtered exhaust, sticky walk-off mats, sealed penetrations, dedicated construction routes, after-hours work in sensitive zones, daily containment monitoring, and continuous communication with the Infection Preventionist. Every step is documented for Joint Commission survey readiness.

What are the ICRA construction activity types?

Type A is inspection and non-invasive activities. Type B is small-scale activities creating minimal dust. Type C is work generating moderate to high dust, demolition, or removal of fixed building components. Type D is major demolition and new construction. Higher activity types combined with higher patient-risk groups drive stricter Class III or IV containment requirements.

Do you need ICRA training to work on hospital projects?

Yes. ICRA Awareness (8-hour) and ICRA Best Practices (24-hour) training certifications are widely required for site supervisors and tradespeople performing work in healthcare environments. Frans Construction maintains a roster of ICRA-certified superintendents and self-perform crews for occupied medical builds.

Build with confidence

Your commercial construction partner —
from concept to completion.

Partner with a multi-state design-build firm trusted by enterprise brands for predictable execution, strategic guidance, and long-term reliability across every market we serve.