Search Results for 'wet locations'

Water is wet: How about your ORs?

Howdy folks, as our friends from Chicago return to the field, a couple of items have come to my attention that I felt were worth sharing. There’s also an updated resource that we’ve mentioned in the past (though it seems that there are always many things that we’ve mentioned in the past—go figure).

First up, as we know from our diligent perusal of the intricacies of NFPA 99, Section 6.3.2.2.8.4 indicates that “(o)perating rooms shall be considered to be a wet procedure location, unless a risk assessment conducted by the health care governing body determines otherwise.” Consequently, the Life Safety surveyors are asking to see the risk assessment that determined otherwise or validation that your ORs are appropriately protected in accordance with the requirements for wet locations (isolated power, etc.). In previous discussions, I did note that “health care governing body” would seem to indicate that the assessment needs to include, at least to some degree—it doesn’t specify—hospital leadership. My general thought is that if your ORs aren’t considered wet locations and weren’t designed that way, you should be able to use the initial design/build aspect of the ORs to represent an assessment of those risks and, nominally, as construction activity, would have involved hospital leadership. I guess that then begs the question of how often you would need to revisit the assessment. It might be a(nother) good use of the annual evaluation process; I’m a big fan of using that process to “plant” things where you know they are likely to be viewed during survey. Much as the comments section of the eSOC is a good place to memorialize waivers, equivalencies, and the like, the annual evaluation is a good place to revisit important historical decisions. At any rate, it appears that wet locations are high on the “ask list,” so be prepared.

Another consideration that appears to be on the table is a risk assessment regarding what type(s) of fire extinguishers are in your ORs (could surgical fire management be a theme?). Our friends from the Windy City have something to say about this, and it appears that there was a recent update (though what got updated is not immediately apparent) to the FAQ, so probably worth a visit. I don’t doubt that these elements came into play when extinguishers were first chosen, but (again!) it never hurts to review…

Lastly this week, while this hasn’t necessarily been a survey hot topic, somehow it feels like water management programs are going to start to become more heavily surveyed. I think we can agree that this is a significant risk to be managed and while there is minimal evidence that these risks are not being appropriately managed in U.S. hospitals, any time something “new” comes along, it tends to represent a shift in survey focus. In the past, I’ve recommended checking out Matt Freije’s work at HC Info for really useful information on water management concerns. He does a great job of keeping an eye on water management across the globe, but also keeps an eye on our friends. If you’ve not settled into a water management program yet (and you really do need to get on it), it is definitely worth checking out the HC Info website.

On that note, I will bid you adieu for now; hope you all are doing well and staying safe. See you next week!

No one told you when to run: Closing out one year, embarking on another…

Every once in a while, I like to poke back through recent missives from our friends in Chicago and elsewhere to see if there was anything that I missed on first review or something that didn’t really “pop” out at me at the time. And, somewhat typically, the really pressing hard news stories are in rather shorter supply as we get closer to year’s end. Truth be told, the whole ligature picture has really held sway in recent weeks, almost to the exclusion of everything else.

At any rate, in looking at the most recent (I think) slate of pre-publication standards, I noticed a couple of “new” requirements that gave me a little bit of pause. Due to some editorial constraints, I won’t identify the standards and EP numbers, but I will try to give you a sense of where there “live”: they are identified as “new” on the webpage, so that may be enough for you to find them (you’re a pretty smaht bunch and I have every confidence in your detective-ing abilities). This week we’ll cover the Environment of Care changes and hit the Life Safety changes next week (where did the year go!?!):

 

  • The hospital has a library of information regarding inspection, testing, and maintenance of its equipment and systems. Note: This library includes manuals, procedures provided by manufacturers, technical bulletins, and other information. (Safety Management)
  • Management of smoking materials for patients receiving respiratory therapy. (Smoking Policy)
  • Periodic evaluations of fire hazards during surgical procedures (don’t forget to define that period!) (Fire Safety Management)
  • Process for reducing risks when flammable germicides or antiseptics are using during “hot” surgical procedures (electrosurgery, cautery, lasers) (Fire Safety Management)
  • The hospital meets all other Health Care Facilities Code fire protection requirements, as related to NFPA 99-2012: Chapter 15. (Fire Safety Management)
  • Elevators with firefighters’ emergency operations are tested monthly. The test completion dates and results are documented. (Inspection, Testing & Maintenance of Life Safety Systems equipment)
  • Hyperbaric facility safety, including labeling of equipment used in oxygen-enriched atmospheres (we covered this a couple of weeks ago, with a couple of folks weighing in with questions on how far to go with Chapter 14 of NFPA 99; if the past is any indicator of the future, I would be moving towards adoption of the whole thing and probably start to extend the labeling of equipment out to all oxygen equipment—this is where they start digging into this—we know the targets will move over the next survey years, so better to be ahead of the game than behind). (Medical Equipment Inspection, Testing & Maintenance)
  • Inspection, testing, and maintenance of anesthesia apparatus, including gas flow and oxygen concentration verification; no oil, grease or flammables for oxygen equipment. (Medical Equipment Inspection, Testing & Maintenance)
  • ORs are wet locations unless you have a risk assessment that says otherwise and has been approved by the governing body (it appears that risk assessments done in “isolation” will no longer meet the mark—organizational leadership has to be involved in the process. Written record of the risk assessment is available for survey review. We covered this before.  (Utility Systems Management)
  • Risk level identification of electrical distribution; we did this one before as well.  (Utility Systems Management)
  • Hospital-grade receptacles at patient bed locations and where deep sedation or general anesthesia is administered are tested after initial installation, replacement, or servicing. In pediatric locations, receptacles in patient rooms (other than nurseries), bathrooms, play rooms, and activity rooms are listed tamper-resistant or have a listed cover. Electrical receptacles or cover plates supplied from the life safety and critical branches have a distinctive color or marking.  Keep an eye on those pediatric locations, particularly areas that can “swing” – tamper-resistant receptacles could well become a moderate risk of harm during survey. (Utility Systems Management)
  • Power strips must be appropriately listed for use in patient care vicinity, patient care rooms, etc. Focus on this has already started, so you better start working with your IT folks to make sure everything is going in the right direction. (Utility Systems Management)
  • Extension cords are not used as a substitute for fixed wiring in a building. Extension cords used temporarily are removed immediately upon completion of the purpose for which it was intended. I predict that this is going to keep this standard at the top of the most frequently cited standards list. (Utility Systems Management)
  • Areas designated for administration of general anesthesia using medical gases or vacuum are in accordance with NFPA 101-2012 and NFPA 99-2012 (Utility Systems Management)
  • Electrical system critical branch supplies power for specific needs (task illumination, fixed equipment, select receptacles, and select power circuits) in areas designated for administration of general anesthesia (specifically, inhaled anesthetics) using medical gases or vacuum. The EES equipment system supplies power to the ventilation system. (Utility Systems Management)
  • New buildings equipped with or requiring the use of life support systems (electro-mechanical or inhalation anesthetics) have illumination of means of egress, emergency lighting equipment, exit, and directional signs supplied by the life safety branch of the electrical system described in NFPA 99. (Utility Systems – Emergency Electrical Power Source)
  • Equipment designated to be powered by emergency power supply are energized by the hospital’s design. Staging of equipment startup is permissible. (Utility Systems – Emergency Electrical Power Source)
  • For deemed status hospitals, battery lamps and flashlights are available in areas not serviced by the emergency supply source. (Utility Systems – Emergency Electrical Power Source)
  • Line isolation monitors are tested in accordance with NFPA 99-2012. (Utility Systems Inspection, Testing & Maintenance)
  • Risk level identification of medical gas, medical air, surgical vacuum, waste anesthetic gas disposal (WAGD), and air supply systems. (Inspection, testing & maintenance of medical gas system components)
  • All master, area, and local alarm systems used for medical gas and vacuum systems comply with the category 1–3 warning system requirements. (Inspection, testing & maintenance of medical gas system components)
  • Containers, cylinders, and tanks are designed, fabricated, tested, and marked in accordance with NFPA 99-2012. (Inspection, testing & maintenance of medical gas system components)
  • Locations containing only oxygen or medical air have doors labeled “Medical Gases: NO Smoking or Open Flame.” Locations containing other gases have doors labeled “Positive Pressure Gases: NO Smoking or Open Flame. Room May Have Insufficient Oxygen. Open Door and Allow Room to Ventilate Before Opening.” (Inspection, testing & maintenance of medical gas system components)
  • A precautionary sign readable from 5 feet away is on each door or gate of a cylinder storage room, where the sign, at a minimum, includes the wording “CAUTION: OXIDIZING GAS(ES) STORED WITHIN NO SMOKING.” Storage is planned so cylinders are used in order of which they are received from the supplier. Only gas cylinders and reusable shipping containers and their accessories are permitted to be stored in rooms containing central supply systems or gas cylinders. (Inspection, testing & maintenance of medical gas system components)
  • More cylinder storage stuff (I suspect you know the drill)—NFPA 99-2012 has a great deal of detailed requirements—and I have no reason to think that they won’t be kicking the tires pretty diligently. (Inspection, testing & maintenance of medical gas system components)
  • Also, transfilling of liquid oxygen is a process with very, very specific requirements; if you’re not transfilling liquid oxygen in your facility, you could count yourself fortunate, but be on the lookout for any evidence of liquid oxygen being transferred inside your “house”; NFPA 99-2012 is your guide. (Inspection, testing & maintenance of medical gas system components)
  • Staff responsible for the maintenance, inspection, testing, and use of medical equipment, utility systems and equipment, fire safety systems and equipment, and safe handling of hazardous materials and waste are competent and receive continuing education and training. (Staff Competency & Education)

I know this is a lot of stuff to consider, but I wanted to put it out in front of you folks on the off chance that your bedtime reading hasn’t strayed into the realm of the 2018 standards changes. I have every reason to think that some of this stuff will show up again in this space (and what a space!), but if someone wants to start a particular conversation before we kick off (kick at?) 2018, please feel free.

News to me

Recently, a client sent me a question regarding assessing his surgical procedure rooms as wet locations. This was primarily as a function of the changes to NFPA 99, which brings the concept of wet locations and surgery back into the mix (the 2012 edition of NFPA 99 defines wet procedure locations as the “area in a patient care room where a procedure is performed that is normally subject to wet conditions while a patient is present, including standing fluids on the floor or drenching of the work area, either of which condition is intimate to the patient or staff,” NFPA 99 – 2012: 3.3.184). Previously, operating rooms were not considered wet locations as a rule, but now it appears that the pendulum has swung in the other direction.

To that end, the American Society of Healthcare Engineering (ASHE) issued an advocacy statement last year recommending that organizations form a risk assessment group to develop a process for evaluating surgical procedure rooms to determine which of these areas, if any, might legitimately be considered wet locations. Now based on the definition from NFPA 99, you could probably rule out a lot of procedure areas (rooms designated for eye surgery, neurosurgery, ENT surgery, etc.), but in other areas it may require some observations of the procedures being performed to determine the extent of standing fluids, etc. Once you’ve determined that you have wet locations, then you would need to move to provide appropriate protection (GFCI protection, isolated power, etc.). And there are other considerations as well, based on the activities in the space, the “state” of the equipment used in the space, etc. There can be any number of contributing factors that could increase the risk to staff and patients in wet locations; Appendix B of the 2005 edition of NFPA 99 speaks of such things as line-powered equipment that is within reach; a damaged line cord, attachment plugs, or exposed metal presenting a risk of direct exposure to a conductor; damaged equipment with “live” metal, exposed metal that has become ungrounded, a person making contact with a live metal surface, etc.

As with so many things, the key process is the almighty risk assessment, so if you’ve not yet wrestled with this bear, you might find it useful to start the process (in full disclosure, the ASHE advocacy statement came out last year—and if you don’t think certain three-letter regulatory agencies are not familiar with this bit of news, I would encourage you to think otherwise).  Sometimes codes change for good reasons, sometimes maybe not so much, but we have an obligation to provide the safest possible environments for patients and staff and this looks like something that can be at least determined fairly simply (fixing this if you have issues is likely to be much less simple).

I wanna know: Have you ever seen the rain?

In our intermittently continuing series on the (final!) adoption of the 2012 Life Safety Code®, we turn to the one area about which I have still the most concerns—the magic land of NFPA 99. My primary concern is that while NFPA 99 contains lots and lots of references to risk assessments and the processes therein, I’m still not entirely convinced that the CMS oversight of the regulatory compliance process is going to embrace risk assessments to the extent that would allow us to plot our own compliance courses. I guess I will have to warily keep my fingers crossed and keep an eye on what actually occurs during CMS surveys of the physical environment. So, on to this week’s discussion…

When considering the various and sundry requirements relating to the installation and ongoing inspection, testing and maintenance of electrical system components, one of the key elements is the management of risk associated with electrical shock in wet procedure locations. NFPA 99 defines a wet procedure location as “(t)he area in a patient care room where a procedure is performed that is normally subject to wet conditions while patients are present, including standing fluids on the floor or drenching of the work area, either of which condition is intimate to the patient or staff.”

Typically, based on that description, the number of areas that would “rule in” for consideration as wet procedure locations is pretty limited (and depending on the nature, etc., of the procedures being performed maybe even less limited than that). But in the modern age, the starting point for this discussion (and this is specifically provided for under section 6.3.2.2.8.4 of the 2012 edition of NFPA 99) is that operating rooms are to be considered wet procedure locations—unless a risk assessment conducted by the healthcare governing body (yow!) determines otherwise (all my yammering over the years about risk assessments is finally paying off—woo hoo!). By the way, there is a specific definition of “governing body”: the person or persons who have overall legal responsibility for the operations of a healthcare facility. This means you’re going to have to get your boss (and your boss’ boss and maybe your boss’ boss’ boss) to play in the sandbox on this particular bit of assessmentry.

Fortunately, our good friends at ASHE have developed a lovely risk assessment tool (this is a beta version) to assist in this regard and they will share the tool with you in exchange for just a few morsels of information (and, I guess, a pledge to provide them with some useful feedback as you try out the tool—they do ask nicely, so I hope you would honor their request if you check this out—and I really think you should). Since I’m pretty certain that we can attribute a fair amount of expertise to any work product emanating from ASHE (even free stuff!), I think we can reasonably work with this tool in the knowledge that we would be able to present it to a surveyor and be able to discuss how we made the necessary determinations relative to wet procedure locations. And speaking of surveys and surveyors, I also don’t think it would be unreasonable to think that this might very well be an imminent topic of conversation once November 5 rolls around and we begin our new compliance journey in earnest. Remember, there is what I will call an institutional tendency to focus on what has changed in the regulations as opposed to what remains the same. And I think that NFPA 99 is going to provide a lot of fodder for the survey process over the next little while. I mean think about it, we’re still getting “dinged” for requirements that are almost two decades old—I think it will be a little while before we get our arms (and staff) around the ins and outs of the new stuff. Batten down the hatches: Looks like some rough weather heading our way!

At any rate, here’s the link to the wet procedure location assessment tool.

Hope everyone has a safe and festively spooky (or spookily festive) All Hallows Eve!