Well, it does seem like there are a couple of compliance themes asserting themselves in 2018, concerns related to emergency management (relatively simple in terms of execution and sustainability) and concerns relating to the management of behavioral health patients and the management of workplace violence (relatively complicated in terms of execution and sustainability). I think we can say with some degree of certainty that there are some commonalities relative to the latter two (beyond being complicated to work through) as well as some crossover. And while I wish that I had a ready solution for all of this, if I have learned nothing else over the last 39+ years, it is that there are no panaceas when it comes to any of this stuff. And with so many different regulatory perspectives that can come into play, is it enough to do the best you can under the circumstances? As usual, the answer to that question (at least for the moment) is “probably not.”
In last week’s Hospital Safety Insider, there was a news item regarding OSHA citations for a behavioral health facility in Florida for which inadequate provisions had been made relative to protecting staff from workplace violence. As near as I can make out from the story , the violence was being perpetrated mostly in patient encounters and revolved around “failing to institute controls to prevent patients from verbal and physical threats of assault, including punches, kicks, and bites; and from using objects as weapons.” Now, in scanning that quote (from information released by the Department of Labor ), it does seem rather daunting in terms of “preventing” patients from engaging in the listed activities. This is one of those really clear division between federal jurisdictions—OSHA is driving the prevention of patients from engaging in verbal and physical threats while CMS is (more or less) driving a limited approach to what I euphemistically refer to as the “laying on of hands” in the management of patients. That said, I think it’s worth your while to take a look at the specific correction action plan elements included in the DOL release—it may have the makings of a reasonable gap analysis if you have inpatient behavioral health in your facility. It appears that the entity providing some level of management at the cited facility was also cited at another facility back in 2016 for similar issues, so it may be that some of this is recurrent in theme, but I think it probably makes sense to take a look at the details to see if your place has any of the identified vulnerabilities.
Wanting to end this week’s installment on an upbeat note, as well as providing fodder for your summer reading list, I was recently listening to the id10t podcast and happened upon an interview with astronaut Leland Melvin, who navigated a number of personal and profession barriers to become the first person to play in the NFL and go into space as an astronaut. His book, Chasing Space, is a fun and thought-provoking read and really captures the essence of what we, as safety professionals, often face in terms of barrier management. I would encourage you to check out the book as well as the interview . As a side note, I’m not sure if you folks would all be familiar with Chris Hardwick and his Nerdist empire, but I think he’s become a most winning and empathetic interviewer, and since I’ve never been afraid to embrace my inner (and outer) nerd, I will leave you with that recommendation (and please, if you folks have stuff that you’re reading and think would be worth sharing with our little safety community, please do—fiction, non-fiction—a good read is a good read!)