RSSAuthor Archive for Steve MacArthur

Steve MacArthur

Steve MacArthur is a safety consultant with The Greeley Company in Danvers, 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.

Just in time for the holidays: Shoes are dropping all over the place, including business occupancies!

Just when you thought that maybe, just maybe, 2020 had run out of surprises, our friends in Chicago have taken one last (hopefully) opportunity to create a little chaos in the future by introducing us to their latest brainchild—the Life Safety chapter standards and performance elements prescribing the management of business occupancies.

I don’t know that there’s anything particularly surprising in the mix, and, ultimately, may help healthcare organizations endure the scrutiny of surveyors that insist on applying healthcare occupancy requirements to business occupancies. In some ways, it also helps to clarify certain general concepts (for example, the protection of hazardous areas—I suspect you’ll be installing some door closers before too long) that were always applicable, but not always meted out during surveys. There are approximately 30 new performance elements (I count 29, but I can never tell when my math skills will legitimately start to deteriorate…) to chew on, but the “good” news is that these are not coming online until July 1, 2021, so perhaps you will have had enough time to really kick the tires in your clinics, etc.

These changes will be in play for behavioral health and critical access hospitals as well, you can find the links for each of those here.

There are also some EC and LS changes coming to behavioral health, but I think we’ll dig into those next time.

In the face of all of this, I hope that each of you has a safe and joyous holiday season and that we all get a really spiffy New Year. I think we’re earned it!

We’re only immortal for a limited time…

Just taking a quick cruise the FAQ pages and came across one or two items of interest; commentary as applicable…

Our friends in Chicago have given the thumbs up to using the current pandemic response to meet the emergency management exercise(s) requirements. Make sure you document the evaluation in accordance with the six critical areas of response:

  • Communications—what worked well and what did not
  • Resources and assets—what resources were abundant, adequate or lacking
  • Safety and security—what issues arose and how were they resolved
  • Staff responsibilities—what issues arose and how were they resolved
  • Utilities—what issues arose and how were they resolved
  • Patient clinical and support activities—what was abundant, adequate or lacking.

There is an indication that they may be “leaning” on EM when the survey process returns in earnest (and we all know how important that is…).

Moving on to the world of equipment management, specifically diagnostic imaging equipment, there is some relief relative to the completion of performance evaluations for certain systems (CT, MRI, NM, PET, but not mammography) for the duration of the declared state of emergency. I’d be curious as to how folks have been managing this in general; I suspect that some folks had these on the schedule before things came to a screeching halt, but we’re rounding the corner on a year’s worth of pandemic delight so probably want to keep an eye on where things stand. As with many things, the clock will be ticking once the state of emergency is discontinued, at which point you’ll have 60 days to get things scheduled. I bet there will be a lot of competition for external resources at that point…

We’ll close out this week’s edition with some fodder for the HVAC-heads in the crowd. I have to admit that the question being asked and the response don’t seem to match up particularly well and I do think there probably ought to be some mention of the manufacturers’ instructions for use (nothing like a little IFU to make one’s day). The question seems more along the line of “what should we be doing now,” but the response seems to focus a little more on “here’s what you do when this is all over,” when it comes to maintaining HVAC equipment being used to support COVID units. Again, I suspect the IFUs have a big part of where we should be at the moment. Hopefully, you’ve had enough ebb and flow of patients to be able to attend to something close to a normal preventive maintenance schedule and it probably couldn’t hurt to reach out to equipment manufacturers’ if we have significantly modified the use of existing systems and equipment. That said, I would certainly recommend including the bulleted items noted in the FAQ once we’re in a position to start returning things to “normal.”

Won’t you be glad when normal doesn’t have to be in quotation marks?

Hope you all remain safe and well!

Someone’s in the kitchen, but there are no banjos involved…

In the never-ending quest for generating new and challenging survey findings, our friends in Chicago have thrown down the gauntlet (or perhaps more aptly, the oven mitt) for a new focus area: the kitchen! Certainly, the kitchen has always been part of the fabric of most regulatory survey visits. If you think about it, kitchens are among the most risk-laden environments in healthcare. You’ve got all the classic physical environment risks—slips, trips, falls, fire, sharps, heat, humidity, chemical hazards, sanitation/cleaning, a lot of entry-level positions—the list goes on and on. You could make the case that the kitchen environment is among the least risk-free environments in any healthcare organization. I will stop short of calling it dangerous, but it sure is hazardous.

To that end, this week’s Joint Commission blog posting outlines some of the major focus areas for the survey process as it relates to the kitchen; the blog also includes a link to a checklist for reducing fire and other risks in the kitchen. If you don’t have a formal process for doing rounds in your kitchen(s), might be work kicking the tires on this one.

Hope you all are well and staying safe. While I think we’re starting to make the adjustments to the “new normal,” the post-Thanksgiving spike (if there is one, and there’s no reason to think there won’t be) should be arriving shortly, so keep up the good work and we’ll get through this!

Be afraid, be very afraid…but do it anyway!

Something of a mixed bag this week: Basically a couple of brief items with some interpolative commentary.

First off, in what is probably not really a surprise, the feds have not updated the status of the Public Health Emergency (PHE) (here’s the most recent correspondence in this regard) in a little bit, but I am hopeful that our sprint towards the New Year will prompt a revisitation. I guess one of the key thoughts moving forward is at what point are regulatory surveys impacted. It would seem that we are in a bit of a spike in cases (though how one can tell definitively is something of an art form), based on the information provided to folks traveling in and out of Massachusetts (which would include yours truly). While I can’t say that I’m getting used to being swabbed, I suspect that between now and Christmas, I’ll have a few more opportunities to embrace the swab.

At any rate, I’d be curious as to how folks are “falling” within their normal accreditation survey cycle. Early? Late? Pretty much on time? At some point, something’s going to have to give (and maybe that something involves virtual building tours and the like). I guess at this point all we can do is “stay the course,” and wait for the vaccine distribution challenge (we know it’s coming sometime)…

In other news, our friends in Chicago announced a revision to one of the performance elements dealing with the life safety implications of maintaining fire suppression systems. You might recall we chatted a bit about this back at the beginning of July, at least in terms of the whole spare sprinkler thang. If you accept (as I pretty much have at this point) that any change to a physical environment standard or performance element is “designed” to provide an opportunity for generating more findings (the sterling being the impending focus on the ambulatory care environments), then I think it would be prudent to really kick the tires on your spare sprinkler maintenance program to ensure that you are meeting not just the requirements of the revised performance element, but also the other related requirements. (The blog post above should serve as a good starting point, if you are so inclined.)

As always, please be well and stay safe. I appreciate everything you are and everything you do!

A cautionary tale for travelers: The only nose you’ll want to see this week…

I’m not sure how many folks will be traveling this week (the CDC is advising folks to refrain from travel). But having spent a goodly portion of the past few months traversing airports and the like, I can tell you, from personal experience, that compliance with the wearing of masks is better than it was, but there are still quite a few schnozzes on display. So, if you are traveling by public means, please be vigilant within your own practice and don’t be one of those folks that can nurse a 6-ounce bottle of water for a four-hour flight. Interestingly enough, United Airlines has started to call out folks for using consumption of food/beverage as a basis for leaving their masks off. I noticed it a lot this summer and it still seems to be a more common practice than I would prefer to see.

That said, please accept my sincerest wishes to you and yours for a most joyous Thanksgiving holiday and safe, definitely want you all to stay safe!

And as to the nose you want to see

Happy Thanksgiving!

We know it will never be easy, but will it ever get easier?

It’s always interesting (and perhaps a bit thrilling) when an announcement comes flying over the transom from our friends in Chicago unveiling “modifications” to the Environment of Care (EC) survey process for healthcare occupancies (e.g., ASCs, hospitals, critical access hospitals), but this ended up being a little less breaking news and a little more of a good news/less-good news situation.

For quite some time now, I have mulled over the general thought that the EC interview session portion of the accreditation survey process really doesn’t yield a lot of findings. My sense of the session is that it’s more of an evaluation of group participation than anything else and it appears that others in a position to do something about it are in agreement, at least as a function of identifying survey vulnerabilities.

At any rate, The Joint Commission recently announced that the EC interview session is going away (good news) to provide more time for surveying in the field, including even more focus on EC stuff for the clinical surveyors during tracers (less-good news). I am certainly not worried about folks getting into “big” trouble during this extra hour of time, but it is another hour of wandering around that is likely to generate at least a few more “dings” in the physical environment.

As the Chicagoans continue to battle the forces of CMS in their pursuit of deemed status and reported shortfalls in the surveying of the physical environment, there is a certain inevitability at play here, so I guess we’ll have to wait and see. My immediate prediction is that there will be an increase in EC/Life Safety findings over the next little while (and perhaps a little while after that…).

Now, if they would only remove the requirements to maintain the safety, security, HazMat, fire, medical equipment, and utility systems management plans—I don’t think they generate very many findings and they really don’t serve any real operational purpose for healthcare organizations. Fire response plans and emergency response plans make sense to me, but the rest of it should be captured through the annual evaluation process. Is it really that big a “step” to go from evaluating effectiveness of the EC plans to evaluating the effectiveness of the EC programs in whole? Somehow I don’t think so…

Hope you are all well and staying safe!

You probably already know about this, but…the threats just keep on coming

Just when you thought 2020 couldn’t get any more dramatic (we even had an earthquake this morning in Southern New England—I don’t know that I had ever knowingly experienced one before), but a warning from the Feds regarding nefarious “actors” (I placed that in quotation marks as an homage to my friend, and former editor, Scott Wallask) attempting to target healthcare facilities, et al. I’m sure your IT folks are all over this, but I’m thinking that if you were looking for a non-COVID-related emergency response exercise scenario, evaluating your organization’s response to this latest threat might be worth a look-see. It will be interesting to see how this develops over time as a subtext to everything else that’s going on. If you’re looking for greater detail, I think you’ll find these links useful:

It seems unlikely that this will be the last time we hear about such attacks.

In other preparedness news, under the category of “other things that happen while you’re busy responding to a pandemic,” there was a “hard landing” of a helicopter on the roof of USC Keck Medical Center out in Los Angeles. Fortunately, no one was badly injured, but it just goes to show you that (and it seems particularly so this year) you never know what’s coming next.

Hope you all are well and staying safe!

Masking Tape/Taping Masks: Essential PPE is still in the mix…

As 2020 continues to roll along with no apparent respite from dealing with COVID on the horizon, it’s probably not a bad idea to share some PPE-related resources with folks. I suspect that pretty much no one out there in the studio audience has the time to bolt down the rabbit holes of the interweb, but here are a few links to some (hopefully) useful resources:

When it comes to PPE, it’s always important to keep an eye on the folks at the Occupational Safety & Health Administration, who have provided some guidance relative to the use of PAPRs for personal protection. It has the appearances of being somewhat flexible in certain instances, but enforcement is still enforcement, so if you’ve got PAPRs in the mix, worth checking out.

Next up, the good folks at ECRI have pulled together a number of PPE-related resources to ensure that we’re providing appropriate/effective PPE to those folks on the front lines who are at the greatest risks of occupational exposure. If you think all this stuff kind of sounds like a risk assessment opportunity, I would be inclined to agree. At some point (hopefully sooner rather than later), when move on to the new “new” normal, our regulatory friends are going to be curious to find out how we “knew” that we were adequately protecting folks and, since they’ve been rather reluctant to accept performance data without some sort of assessment framework, these should work well within the confines of the documented risk assessment process.

Here they are:

While shoe covers don’t really fall under the PPE category in general (though sometimes they can), for anyone who has ever struggled with putting on shoe covers before “bunnying up” to go in the OR, I thought this might be a good for the end-of-the-year holiday wish list (I know it’s on mine—as soon as they make one that’s portable), check out the Bootie Butler. I’ve only seen this item in a pharmacy clean ante room, but I found it intriguing.

As always, I hope this finds you well and staying safe. I figure every day brings us closer to the end of this (and I suppose there’s a certain inescapable logic to that). I hope…

Rollin’, rollin’, rollin’, keep those (fire) door-ies rollin’…

Just because I am fascinated by all sorts of stuff (and I suspect that, since you’re still with me on this, you might be interested in all sorts of stuff, too), I came across a blog post regarding the ins and outs (or perhaps the more appropriate description would be “ups and downs”) of rolling steel fire doors. To be honest, I had no real appreciation of the complexities of these devices, though I certainly l know that anything in their path once activated is likely get a pretty good bruising. That said, I think once you check out the components pieces, you will see that there’s much that can go astray from a mechanical standpoint and remains an important part of your fire door inspection, testing, and maintenance process.

As another example of interesting “stuff” is a product that can be used to protect sprinkled areas that do not have suspended ceilings. I don’t know that everyone is going to have a ton of use for such a product (I first encountered it at an airport terminal in which renovation activities had resulted in the removal of the suspended ceiling but they still needed to provide sprinkler protection), but since it is classified by UL to meet NFPA 13 (recognizing that even the tenets of NFPA 13 can be nudged in any directions by an AHJ), it might just make your life a little easier if you need it. At the very least, check out the short video to get a sense of the product—it’s pretty cool. And if anybody out there has used the product, I’d be keen to hear about your experiences, so please do.

Finally, since I’d hate to let a week go by without some regulatory folderol and hoo-hah, our friends in Chicago have announced some performance element changes for hospitals and other organizations having fluoroscopy services. The new requirements are supposed to be implemented starting January 1, 2021. In looking over the changes, I don’t know that this is of earth-shattering impact (no asteroid, this) but it’s probably worth checking out to ensure that you’re in compliance.

That’s it for this week. Hope you all are well and staying safe. On to November!

The Fountains of Youth and Water Management Programs

As a follow to last week’s item about water management programs, I know a lot of folks are not using their drinking fountains (or as we know them in the Boston areas, bubblers—pronounced “bubblahs”—I was hoping to find an audio link, but if you doubt the veracity of that pronunciation, this sort of backs it up). How are you managing those as a function of your water management program?  I’ve seen a lot of these devices sitting idle (and not just in healthcare) and looks like they may be sitting that way for a while. Are you periodically having someone go around to operate them or have you modified other practices to keep an eye on these? Not quite sure why it took me so long to think about this—perhaps it’s the ever-growing drinking fountains covered in plastic. The other question I had in this regard is whether any of you are using this as an opportunity to remove them completely? Depending on the design of your building, these are sometimes placed in a way that reduces the clear width of an egress pathway or two. This might be the best opportunity evah to get rid of them.

Of course, the other dynamic that comes into play (though perhaps less in healthcare than in other industries) is the whole notion of how to manage facilities that are experiencing reduced utilization. Perhaps you have a business office or the equivalent, and you have folks working remotely or some other variation on the theme of forced vacancy. If that’s the case (or could become the case if COVID persists), then you might find the following information worth checking. Fortunately, resources continue to provide guidance in this regard and I don’t think there’s anyone among us that would wish to endure a breakout of waterborne pathogens in the midst of the current climate.

Check out the following resources:

Hope all is well and you folks are staying safe. See you next time!