RSSAuthor Archive for Steve MacArthur

Steve MacArthur

Steve MacArthur is a safety consultant based in Bridgewater, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Briefings on Hospital Safety. Contact Steve at stevemacsafetyspace@gmail.com.

Don’t be a Haz-been (or perhaps Haz-not would be more appropriate…)

I would like to take this opportunity to draw your attention to the two most recent issues of Perspectives, for a couple of reasons. First, as the articles (part 1 and part 2) deal with EC.02.02.01, which is on the top 10 list for most-cited standards during 2015, and Joint Commission interpretation relative to the wonderful world of hazardous materials (and it is, indeed, a wonderful world). Second, these articles introduce a new “voice” into the mix, Kathy Tolomeo, CHEM, CHSP, who is one of the engineers at The Joint Commission’s Standards Interpretation Group and is one of the folks in Chicago who reviews clarifications, ESC submittals, perhaps (presumably) PFIs, etc. In that context, I think it’s important to have a sense of how individual reviewers “see” the regulatory compliance landscape, and these articles provide some sense (I will stop short of saying insight) of compliance strategies.

As a starting point, those are good reasons to check out the articles. But I also found these articles particularly helpful in that compliance strategies are discussed in some detail (I mean the articles are only a couple of pages long, so there are limits to how much detail), including an example (in the December Perspectives) of a hazardous materials inventory form, which I think paints a very nice (and perhaps most importantly, clear) picture of what you need to have in place (I’ve encountered a lot of folks struggling with what is expected for the HazMat inventory). There are discussions of eyewash stations and lead PPE, ventilation, and risk assessments (imagine that!) in the December Perspectives; the January issue covers hazardous gases and vapors, permits, licenses, manifests, and other documentation, labeling, monitoring for radiation exposure, proper routine storage, and prompt disposal of trash.

I guess you could say it’s a bit of hodgepodge in terms of ground covered, but that is the wonderful world of hazardous materials and waste. Check out these articles and maybe, just maybe, you can keep yourself off this year’s (or next year’s, depending on when you’re going to be surveyed) Top 10 list.

Fear is not sustainable

A Welshman of some repute once noted that “fear is a man’s best friend” and while that may have been the case in a Darwinian sense, I don’t know that the safety community can rely as much on it as a means of sustainable improvement. I’ve worked in healthcare for a long time and I have definitely encountered organizational leaders that traded in the threat of reprisal, etc., if imperfections were encountered in the workplace (and trust me when I say that “back in the day” something as simple as a match behind a door—left by a prickly VP to see how long it stayed there—could result in all sorts of holy heck), it typically resulted in various recriminations, fingerpointing, etc., none of which ended up meaning much in the way of sustained improvement. What happened was (to quote another popular bard—one from this side of the pond), folks tended to “end up like a dog that’s been beat too much,” so when the wicked witch goes away, the fear goes too, and with it the driving force to stay one step ahead of the sheriff (mixing a ton of metaphors here—hopefully I haven’t tipped the obfuscation scales).

At any rate, this all ties back to the manner in which the accreditation surveys are being performed, which is based on a couple of “truisms”:

 

  1. There is no such thing as a perfect building/environment/process, etc.
  2. Buildings are never more perfect than the moment before you put people in them.
  3. You know that.
  4. The regulators know that.
  5. The regulators can no longer visit your facility and return a verdict of no findings, because there are always things to find.
  6. See #1.

Again, looking at the survey process, the clinical surveyors may look at, I don’t know, maybe a couple of dozen patients at the most, during a survey. But when it comes to the physical environment, there are hundreds of thousands of square feet (and if you want to talk cubic feet, the numbers get quite large, quite quickly) that are surveyed—and not just the Life Safety (LS) surveyor. Every member of the survey team is looking at the physical environment (with varying degrees of competency—that’s an editorial aside), so scrutiny of the physical environment has basically evolved (mutated?) since 2007 from a couple hours of poking around by an administrative surveyor to upwards of 30 hours (based on a three-day survey; the LS surveyor accounts for 16 hours, and then you will have the other team members doing tracers that accounts for at least another 16 hours or so) of looking around your building. So the question really becomes how long and how hard will they have to look to find something that doesn’t “smell” right to them. And I think we all know the answer to that…

It all comes back (at least in my mind’s eye) to how effectively we can manage the imperfections that we know are out there. People bump stuff, people break stuff, people do all kinds of things that result in “wear and tear” and while I do recognize that the infamous “non-intact surface” makes is more difficult to clean and/or maintain, is there a hospital anywhere that has absolutely pristine horizontal and vertical surfaces, etc.? I tend to think not, but the follow-up question is: to what extent do these imperfections contribute to a physical environment that does not safely support patient care? This is certainly a question for which we need to have some sense of where we stand—I’m guessing there’s nobody out there with a 0% rate for healthcare-acquired infections, so to what degree can we say that all these little dings and scrapes do not put patients at risk to the extent that we cannot manage that level of risk? My gut says that the environment (or at least the environmental conditions that I’m seeing cited during surveys) is not the culprit, but I don’t know. As you all know by now (if you’ve been keeping tabs on me for any length of time), I am a big proponent of the risk assessment process, but has it come to the point where we have to conduct a risk assessment for, say, a damaged head wall in a patient room? Yes, I know we want to try and fix these types of conditions, but there are certain things that you can’t do while a patient is in the room and I really don’t think that it enhances patient care to be moving patients hither and yon to get in and fix surfaces, etc. But if we don’t do that, we run the risk of getting socked during a survey.

The appropriate management of the physical environment is a critical component of the safe delivery of healthcare and the key dynamic in that effort is a robust process for reporting imperfections as soon as possible (the “if you see something, say something” mantra—maybe we could push on “if you do something, say something”) so resources can be allocated for corrective actions. And somehow, I don’t think fear is going to get us to that point. We have to establish a truly collaborative, non-knee-jerk punitive relationship with the folks at the point of care, point of service. We have to find out when and where there are imperfections to be perfected as soon as humanly possible, otherwise, the prevalence of EC/LS survey findings will continue in perpetuity (or something really close to that). And while there may be some employment security pour moi in that perpetual scrutiny, I would much rather have a survey process that focuses on how well we manage the environment and not so much on the slings and arrows of day-to-day wear and tear. What say you?

IFU? No, you IFU!

As this little screed represents the closing of the 2015 blogging season (I figure there’s gotta be a lumberjack tie-in—blogging and logging are just too close for words), I’m going to try and keep it relatively brief. If brevity is indeed the soul of wit, then I tend to be rather more witless than not…

Another recent trend in survey findings relates to the management of some of your more “peripheral” patient care equipment, particularly the stuff that gets used by the good folks in the rehabilitation/physical therapy world: hydrocollators, paraffin baths, etc. While I do believe that we have things well in hand from a medical equipment standpoint (most of the equipment being cited falls very clearly into the low-risk/no-risk category), where this is skidding a bit sideways is when the devices in question are not being maintained by the end users in accordance with the manufacturer Instructions For Use (IFU). Now, I will freely indicate that some of the equipment we’re talking about is almost Biblically ancient and the IFUs might not be easily obtainable, but in the absence of a risk assessment to indicate that maintaining this stuff in a manner that is not in strict accordance with the IFUs results in an acceptable level of operational performance/reliability/cleanliness, etc. then you’re at risk for yet another of the (seems like) gazillion little imperfections that are gracing survey reports across the continuum. Interestingly enough, these findings do seem to be “clumping” under the Infection Control standards (pretty much IC.02.02.01, EP 4, which deals with the storage of supplies and equipment), so this may not be on everyone’s radar at the moment. That said, it might be a good idea to poke around a little bit—including any offsite rehab/PT locations—to see if you have any survey risk exposure. Once again, I’m not convinced that this represents a significant risk to patients, but my being convinced (or not) doesn’t necessarily keep you out of trouble during survey. We need to be very sure about where we “stand” in relation to what manufacturers are recommending and what practices and conditions provide appropriate levels of safety, cleanliness, etc. The Joint Commission doesn’t tell us how to do these things, but we need to be able to respond definitively when the questions are (and there is a certain inevitability here) raised during survey.

And on that note, I wish each and every one of you a most prosperous, safe, and successful 2016. See you next year!

Portal chortling: Who wants to be surveyed at Christmas?

I know that this is typically characterized as a season of giving, but I have somewhat of a huge favor to ask of you folks out there in the depths of the blogosphere, so I hope you will bear with me.

With an almost astonishing regularity, the first of each month continues to bring with it a new module being posted in the Environment of Care portal. For the month of December 2015, the featured topic is the Built Environment, inclusive of elements covered under EC.02.06.01, which (as you may recall) was the #1 most frequently cited standard during the first six months (Freudian typo: When I first typed this passage, I came up with “first sux months”—make of that what you will…).

Since I know a lot of folks have been tapped on this one (both as a function of the published data and my own experiences), I was keen to look over the new material—including the latest fireside chat from our partners in compliance George Mills, director of engineering at TJC and Dale Woodin, executive director at ASHE, which covers EP 1 and EP 13 (in separate episodes). One of the interesting things I noticed was, in describing the many and varied findings that are generated under EP 1, a direct comparison was made to OSHA’s General Duty Clause as a function of how this particular EP is being used. Now, the GDC concept as a part of TJC’s survey efforts is certainly not unknown to us (in the “old” days, EC.02.01.01 used to be the catch-all for general safety findings) and basically it comes down to pretty much anything that isn’t quite as it should be (what I have taken to euphemistically describing as imperfections). Could be stained ceiling tiles, could be non-intact flooring, wall, or horizontal surfaces. Could be nurse call cords that are not properly configured (too long, too short, too wrapped around restroom grab bars), could be improperly segregated compressed gas cylinders. The list of possibilities is pretty much infinite.

The second video episode talks about maintaining temperature, humidity, and air-pressure relationships in the “other” locations (pretty much everywhere that isn’t an invasive procedure area or an area that supports invasive procedure areas). I know that there’s been some consternation from findings relating to issues such as pressure relationships in clean utility and soiled utility rooms (clean rooms have to blow and soiled rooms have to suck, so to speak), pressure relationships in pharmacies (positive), laboratories (negative) and so on. There’s some discussion about how these types of conditions might manifest themselves in the environment and the importance of staying on top of these things, particularly during surveys (personal note: my consultative advice is to have an action plan for checking all these various areas that have pressure relationship requirements the moment you learn that “Elvis,” my code name for TJC, is in the building). It is very, very clear that the Life Safety surveyor is going to be checking pressure relationships early on in the survey process—you want to have a very, very good idea of where you stand in the applicable areas.

At any rate, the favor I have to ask (and I’m sure I’ve gone on long enough that the favor is blissfully in the past) is for those of you who’ve viewed the contents of the portal (according to TJC figures, there were 48,000 views of the first two modules; I know I account for a couple of those, but clearly others have checked things out, though it might be interesting to see how many of that number are TJC surveyors…), particularly those of you who have been surveyed in the last few months: Has the material actually been helpful? Part of me feels that the materials are presented in such a general fashion that it makes them less useful from a practical standpoint (perhaps the better part of me), but since I don’t have to worry so much about day-to-day stuff anymore, I will freely admit that I’m too far away from it to be able to say. That said, I am really keen to hear if you think they’ve done a good job, not-so-good job, or somewhere in between. Pretty much any sense of whether the material has been helpful (of course, I could ask the same question about this space, as well, so feel free to weigh in—I always like feedback).

As a final note for this week’s epistle, you may be curious to read about what TJC’s leadership thinks about the portal. You may recall a bit of hand-wringing at the beginning of the year, by Mark Pelletier, the COO of accreditation and certification operations at TJC, regarding the recent “spike” in EC/LS findings (you can find my comments, including a link to Mr. Pelletier’s comments from January, here). As we all know very well, the torture in the EC/LS world has continued (presumably until morale is restored), but the EC Portal is being looked upon as “a light at the end” (at the end of what, I’m not sure, as it isn’t specifically indicated). The thing I keep coming back to in my mind’s eye, is that the typical list of findings is what (again, my “imperfections”) are the types of conditions and practices that, while not perfect (yes, we are imperfect) are not conditions that significantly increase the risks to patients, staff, visitors, etc. If these imperfections are not managed correctly, they could indeed become something unmanageable, but I’m just not convinced that the environment is the big boogie man when it comes to healthcare-acquired infections, which is pretty much the raison d’etre for this whole focus. I keep telling myself that it’s job security, but it frustrates the bejeezus out of me…

Mr. Pelletier’s latest can be found here.

And on that note, I wish you a most joyous holiday season and a safe and inspiring New Year! I may find the urge to put fingers to keys twixt now and the end of the year, but if I do not, please know that it’s taking every ounce of my self-control not to pontificate about something. Consider the silence my gift to you!

Be well and stay in touch as you can!

Only a few shopping days left before the next phase of TJC’s clinical alarm management wishes…

Just in time for the holidays, our good friends at the Association for the Advancement of Medical Instrumentation (more acronymically known as AAMI) have released an Alarm Compendium (isn’t that a fancy title!) to assist healthcare organizations meet the challenges of (our other friends—isn’t it good to have so many friends!) The Joint Commission’s National Patient Safety Goal on Clinical Alarms for which Phase 2 (is it really Phase 2? I’ve kind of lost track since this the second iteration of the Patient Safety Goal, so why don’t we call this v.2.2?) kicks in next month. I haven’t had the chance to look through the whole thing, but I have a sneaking suspicion that we might be observing some of the practices and activities outlined in the Compendium as a benchmark for performance during the 2016 survey year (those of you who have been following this topic closely will recognize some of the 10 Ideas for Safe Alarm Management).

At any rate, the Compendium offers a lot of information about current available knowledge, a list of alarm management challenges, some ideas (10, if you’re counting) for safe alarm management, some sample default parameter settings (for both adult and pediatric patients) and some (what I suspect you’ll find to be) useful appendices. Strictly speaking, the whole thing boils to the simple concept of using alarms safely (simple, but not so easy to pull off). Basically, what we’re looking at (particularly as a function of the next phase of operations) is a classic process improvement activity. I suppose if you (and your organization) have been fortunate enough never to have experienced a failure relative to clinical alarm management you might even be able to use this as a Failure Mode and Effects Analysis (FMEA) to meet TJC’s requirements for a proactive risk reduction activity. That said, I think we can anticipate some interest on the part of the Joint Commission surveyors as they hit the accreditation beaches in 2016 (and, no doubt, beyond). Minimally, it would be more than advisable to dissect the information contained in the Compendium and determine how it may (or may not) relate to clinical operations in your facility. One of the things I like about the Compendium is that it stays away from a “one size fits all” trap (frequently this results in a one-size-fits-none scenario) by providing a fairly broad framework for moving forward. Of course, there is always the possibility (I won’t go so far as to call it a likelihood, but if you’re feeling it, I say “go or it!”) that surveyors will form their own sense of what compliance looks like. I think the best defense is to be prepared to demonstrate, within the framework of the Compendium, to demonstrate what compliance means within your four walls. My mantra when it comes to this stuff is this—you know what “works” in your house better than any surveyor dropping by for a quick visit can—at the end of the day, the responsibility is to ensure an appropriately safe environment for patients, staff, and visitors. Your efforts in this regard should fit quite neatly into your risk management strategy(s): make sure you have all the appropriate folks sign off on the strategy(s) and you should be able to successfully navigate the survey process (this is true of pretty much everything, now that I think about it…)

While the more cynical part of me thinks that perhaps they could have provided a little more lead time for hospitals to absorb the materials, I guess that might be a little too much like looking a gift (insert animal name here) in the mouth. The Compendium is available online. I think this is one gift I’d unwrap now and start playing with—January 1, 2016 will be here before you know it!

And in the spirit of giving…

I couldn’t find any indication that I’d covered this before (mea culpa, mea maxima culpa), so it’s probably past time—but it’s a pretty quick one. One thing to put on the pre-survey to-do list is to inspect the environments in which your emergency generator (or generators, if you are fortunate to have multiples) are located and check to see if you have battery-powered emergency lights in those locations. Now, you can correctly indicate that there is no TJC requirement to have battery-powered emergency lights in emergency generator locations—and you’ll get no disagreement from me. However, as an Authority Having Jurisdiction, The Joint Commission can indeed cite you for not having them, based on the introduction of this requirement (I will use the 2010 edition of NFPA 110 for the source on this; other editions of 110 include this requirement, but for this discussion, we’ll say NFPA 110-2010: 7.3.1).

Also, you probably want to be sure that you have battery-powered emergency lighting in any other spots that might benefit from some illumination if your generator fails and you need to do some work (I’m thinking transfer switch locations would be good). At any rate, I think it makes perfect sense (even if it weren’t required somewhere) to have provisions in place for providing illumination to certain areas if your generator poops out. (I’m almost certainly over-simplifying this, but I think the key piece of this is to look and see what you have and make sure that you can effectively deal with an equipment failure that results in very little in the way of illumination).

You know, I really find you quite attractive (human vs. technological magnetism)

Sometimes, particularly around the solstice, I struggle to come up with something (relatively) fresh upon which to pontificate—something that goes a little beyond the typical closing out of the safety year. Fortunately (at least for me; hopefully for you, the readers, as well), there have been enough funky things coming out of Joint Commission surveys this year to provide plenty of material. And today’s topic is the result of what appears to be an uptick in findings relating to MRI safety.

Now, the unfortunate aspect of all this is when the human and technological elements meet in combat, it would seem that it is the TJC surveyors that “win,” which is a very much less than desirable outcome.

At any rate, there’s certainly been a lot of information regarding safety in the MRI environment, first (and probably foremost) being the guidance provided by the American College of Radiologists (ACR). You can find lots of very good information on the topic on the ACR’s MR Safety page. And then, of course, our friends from Chicago felt this was important enough to warrant a Sentinel Event Alert (back in 2008…imagine that!).

Then, effective July 2015, we have the addition of two Elements of Performance (EC.02.01.01, EPs 14 and 16) dealing with some rather specific elements of MRI safety, particularly processes to ensure that folks who access the MRI restricted areas are educated/trained in MRI safety or screened by the folks controlling access to the restricted areas. I think we can reasonably point out that any time TJC adds EPs that indicate specific risks, etc., they are not convinced that hospitals well and truly have their collective acts together. And I guess, to a certain degree, they may have a point, but I think it may be more a question of managing behaviors than anything else (which I’m sure comes as a surprise to everyone in the studio audience).

Based on some TJC reports, the common theme that I’ve noted in recent survey seems to revolve around the management of surveyors when they trace patients into the MRI (and with the pervasive use of MRI in diagnostic medicine, I think I can safely say that if you have an MRI in your “house”, then there will be a patient tracer in to that environment), particularly as a function of screening the surveyors before they enter restricted areas. Now, part of me would like to craft a policy that requires a full screening (and yes, I am talking about a “full” full screening…hah!) of any and all regulatory surveyors—that might get them to shy away from being so obstreperous with these types of findings! That said, I think there is something to say about screening policies/protocols—make sure your MRI staff understand whatever screening process you’ve implemented, and (perhaps more importantly) prepare them for interactions with surveyors as a function of the screening process. Too many findings have come at the hands of surveyors that cited organizations for not having access that is “well controlled” or “adequately secured” based on MRI staff not putting the surveyors through the full screening process.

All that said, I would strongly encourage you to look at the process (and the policy, if you should happen to have a MRI screening/access control policy) for controlling access to the MRI restricted areas, including the mechanism for screening individuals (keeping in mind that “screening” can take different forms). EP 16, among other things, requires hospitals to restrict the access of everyone not trained in MRI safety or screened by staff trained in MRI safety from the scanner room (Zone IV, for those of you keeping score) and the area that immediately precedes the entrance to the MRI scanner room (typically Zone III). Now, you would think (and upon that thought, perhaps make an assumption) that The Joint Commission would provide some level of MRI safety training to their surveyors. That being the case, one could then have a process that does not require screening of the surveyors, based on their training in MRI safety. I think that MRI staff would need to specifically ask the surveyor if he or she had received MRI training before allowing the surveyor to proceed (and I guess the question for you folks in the audience would be whether you think the MRI staff would be comfortable asking the surveyor the question—it might be worth practicing). Even if the surveyor is in the company of folks from your organization that the MRI staff would “know” have been trained in this regard, is that enough to consider the risk as being appropriately managed—that sounds an awful lot like a risk assessment, if you ask me (yes, I know you didn’t, but you know I can’t resist invoking the mighty assessment).

So, it’s probably worth a concerted look during your end-of the-year surveillance activities (unless, of course, you’ve already done your second visit to the MRI this year, but may be worth a revisit); the sentinel event data published most recently by TJC (http://www.jointcommission.org/assets/1/18/2004-2015_3Q_SE_Stats-Summary.pdf) provides no hard evidence (or at least hard, discernible evidence) that hospitals are not appropriately managing the risks associated with the MRI environment, but I think we could probably consider any sentinel event involving the magnet as something to be avoided (much like findings relating to MRI safety). If you have a solid process, then great. But if not, might be a good opportunity to harden that particular survey target.

A most excellent start…

Recently, the AORN Journal published an editorial penned by Kelly Putnam, the managing editor, highlighting the role nurses play in preventing surgical fires (see here for detail). The piece raises a lot of interesting points about some of the operational considerations that come into play when it comes to appropriately managing fire risks in the surgical environment. But what really caught my eye—and my imagination—was the conclusion, which goes a little something like this: “Perioperative nurses are integral to a team approach to fire safety. Nurses are responsible for performing preoperative risk assessments and informing other team members of the risks associated with each procedure, identifying potential fire hazards, helping to find system fixes that improve patient safety, and conveying the details of fire-related incidents to other stakeholders at the institution.”

Now those of you who’ve been following this space for a while will no doubt note the presence of one of my favorite (okay, pretty much #1 on the hit list) phrases: risk assessment. And not only does the risk assessment get a shout out, it’s within the framework of a team approach to managing fire safety in surgery. As I pondered this, I was thinking, wouldn’t it be cool if we could use this as a jumping off point for nursing involvement in a team approach to risk assessment that focuses on the management of the whole darn care environment? I’ve been yammering at just about every opportunity my “sense” that one of the desired end products of the current focus on the care environment by regulatory surveyors is the demolition of the “barrier” that exists (in smaller doses than formerly, to be sure, but not entirely gone) between the “clinical” and “non-clinical” functions of any healthcare organization. It is my firm belief that the organizations that will most effectively manage the survey process are those organizations that have developed a true collaboration of staff across the care continuum. In a very real sense, everyone in your organization is taking care of patients—directly or indirectly, everyone influences the “patient experience.” And at the end of the day (and yes, I recognize that the Urban Dictionary refers to that little turn of phrase as a “rubbish phrase used by many annoying people…”): CARING FOR THE PATIENT IS CARING FOR THE ENVIRONMENT!

Start printing up the t-shirts and bumper stickers…

Now be thankful…

While the events of recent weeks seem to focus our attentions on the darker side of humanity, before jumping into this week’s “serious” topic, I did want to take a moment to wish you all a most joyous Thanksgiving. Your continued presence in this community is one of the things for which I am thankful, so I will, in turn, thank each one of you for that presence—without you, there wouldn’t be much purpose to this little rant-o-rama! And a special thanks to Jay Kumar from HCPro, who manages to keep things going!

And so, onto the business at hand. In the aftermath of the Paris terror attacks, the folks at the Department of Homeland Security are encouraging hospitals and other healthcare organizations to review our security plans and to work towards exercising them on a regular basis (you can read the full notice here). The notice contains a whole bunch of useful information, including indicators to assist in identifying suspicious behaviors and to build a truly robust process for reporting suspicious activity. It’s always tough to say how much of an event could have been prevented if folks were more skilled in identifying threats before they are acted upon, but I guess we always have to use such events as a means of improving our own situations. At any rate, I think it would behoove everyone in the audience to take a look at the materials referenced in the notice. A lot of times, I think we find ourselves “casting about” for direction when it comes to the practical application of how we become better prepared, particularly in the healthcare world of competing priorities. I also know that it is sometimes challenging to get folks to seriously participate in exercises—I don’t know that we’ll ever completely get away from having to deal with what I will characterize as moderate indifference. The events in Paris (and Mali) only point out that this is a risk shared by everyone on the planet, whether we would want it or not. And the more we educate folks to recognize threatening situations, the better able they will be to keep themselves safe. I wish there were a simple solution to all this, but in the meantime, the strategy of increased vigilance will have to do.

May I? Not bloody likely! The secret world of ‘NO EXIT’ signs

There’s been something of a “run” on a particular set of findings and since this particular finding “lives” in LS.02.01.20 (the hospital maintains the integrity of egress), one of the most frequently cited standards so far in 2015 (okay, actually egress findings have been among the most frequently cited standards pretty much since they’ve bene keeping track of such things), it seems like it might not be a bad idea to spend a little time discussing why this might be the case. And of course, I am speaking to that most esoteric of citations, the “NO EXIT” deficiency.

For my money (not that I have a lot to work with), a lot of the “confusion” in this particular realm is due to The Joint Commission adopting some standards language that, while perhaps providing something a little bit more flexible (and I will go no further than saying perhaps on this one, because I really don’t think the TJC language helps clarify anything), in doing so, creates something of a box when it comes to egress (small pun intended). The language used by NFPA (Life Safety Code® 2000 edition 7.10.8.1) reads “any door, passage, or stairway that is neither an exit nor a way of exit access and that is arranged so that it is likely [my italics] to be mistaken for an exit shall be identified by a sign that reads as follows: NO EXIT.” To be honest, I kind of like the “likely” here—more on that in a moment.

Now our friends in Chicago take a somewhat different position on this: Signs reading ‘NO EXIT’ are posted on any door, passage, or stairway that is neither an exit nor an access to an exit but may (my italics, yet again) be mistaken for an exit. (For full text and any exceptions, refer to NFPA 101 – 2000: 7.10.8.1.) If you ask me, there’s a fair distance between something that “may” be mistaken for something else, like an exit and something that is likely to be mistaken for something else, like that very same exit. The way this appears to be manifesting itself is those pesky exterior doors that lead out into courtyard/patio areas that are not, strictly speaking, part of an egress route. Of especially compelling scrutiny are what I will generally describe as “storefront doors”—pretty much a full pane of glass that allows you to see the outside world and I will tell you (from personal experience) that these are really tough findings to clarify post-survey. Very tough, indeed.

So it would behoove you to take a gander around your exterior doors to see if any of those doors are neither an exit nor an access to an exit and MAY be mistaken for an exit. For some of you this may be a LIKELY condition, so you may want to invest in some NO EXIT signs. And please make sure they say just that; on this, the LSC is very specific in terms of the wording, as well as the stroke of the letters: “Such sign shall have the word NO in letters 2 inch (5 cm) high with a stroke width of 3/8 inch (1 cm) and the word EXIT in letters 1 inch (2.5 cm) high, with the word EXIT below the word NO.” This way you won’t be as likely to be cited for this condition as you may have before…