All Entries in the "Emergency management" Category
Taking care of business
Earlier today, I was conducting an EC/EM interview session with a very participative group and I was complimenting them on their ability to speak to improvement efforts in areas that are not necessarily in their scope of practice. Now, my experience has been that the folks most familiar/expert with the EC function being discussed tend to dominate the conversation (sometimes in a good way, sometimes not) and I thought it was cool that these folks were so familiar with what others in the group felt was important. To my compliment, the observation was made (and I thought this was absolutely the grandest definition of what a high-performance team can achieve) that they mind each other’s business. In that simple turn of phrase (not an exact quote – sometimes paraphrase is the best I can do), the whole concept of what the EC team can embrace and accomplish was crystallized: It’s not about what may or may not be “somebody else’s job” (or “not my job”); it’s actually using the team concept to make and sustain improvements. In the old days we used to call that type of organizational behavior “silos,” which is OK if you’re storing grains and such, but when the goal is organizational improvement, we want to be more like a snack mix with all sorts of nuts and fibrous bits.
And please keep in mind, it’s not necessarily about never having any issues to correct. As long as there are human beings in the mix, there will be corrections to make – be assured of that. But if you can harness the power of a group of committed individuals who accept responsibility, hold each other accountable, and care enough to “mind each other’s business,” you can accomplish so much. There’ll always be stuff to do, but think about the power of getting stuff done.
Brings a smile to my face – how ‘bout you?
Panic in Detroit – Panic at the Disco – Panic at the Surgery Center…Fire in the Hole!
I’m presuming (and please don’t attempt to disabuse me of this notion) that you are all dutifully conducting security risk assessments on a regular basis. As you conduct them, I’m sure you find risks of some events that are greater than some other areas. So, I to ask: When you’ve completed your security risk assessment, do you identify specific strategies, including the use of technology, for minimizing those risks to the extent possible? If you’re not including that facet in the risk assessment process, you might want to consider doing so.
Recently, I was looking at a survey report in which an ambulatory surgery center was cited during a TJC survey because they had not installed a panic alarm “at the registrar’s desk in order to obtain immediate assistance in an emergent or hostile situation.” Now, as with so many things that have been popping up during surveys, I don’t disagree with the concept of having panic alarms at those customer service/interaction points where unhappy folks (or folks of any ilk) can experience the need to vent their frustrations, etc. But in that disagreement, I think I’d first be looking at what tools have been provided to staff to actively manage, if not de-escalate, these negative encounters. I would much prefer to avoid having to use a panic alarm by appropriately managing the encounter, much like I would just as soon not “need” to have an emergency eyewash station.
I’m a great believer in the proactive management of risk, but I’m also a great believer in implementing risk management and response strategies that make operational sense. So, the question to the studio audience is: Where have you installed panic alarms and where have you not installed panic alarms, and why? There’s always the risk that some surveyor will disagree with your strategy, but if that strategy was derived through thoughtful analysis of the involved risks, does that not meet the intent of all this?
I like the concept of best practice as much as anyone, but I also recognize that there is a tremendous amount of variability in the safety landscape. Just because something works in one place does not necessarily mean that it will work in all cases—that’s the mystical, magical, and ultimately mythical power of the panacea. One size doesn’t fit all—never has, never will. But if we’re going to be held to that type of an expectation, how does that help anyone? Ok, jumping down from soapbox for now, but rest assured, you’ll see me back up here before too long.
I need to know
Another challenge that’s been rearing it’s ugly little head is the requirement for staff and licensed independent practitioners (LIP) to describe or demonstrate actions to be taken in the event of an environment of care incident, as well as knowing how to report an environment of care risk. I will freely admit that this one can be most tricky to pull off).
The tricky piece, at least in my estimation, is that any data that would be gathered during survey would be the result of direct interaction with staff in the care environment. For staff, one strategy would be for them to contact their immediate supervisor to report a risk, or to be able to articulate the use of a work order system to notify facilities, biomedical, safety, and/or environmental services of conditions needing resolution. Alternatively, some hospitals have a single phone number for reporting unsafe conditions. Presumably, staff can also speak to their specific roles in emergency response activations such as fire, security, disaster, etc.
As to the LIPs, this task can be exponentially more difficult as, strictly speaking, the expectations of this group are pretty much the same as the rest of the house. I’m presuming that you have an emergency phone number to report codes and fire events. An LIP who is able to articulate familiarity with those codes and events would be useful toward a finding of compliance. They really ought to be able to articulate past the point of ignoring something and to at least be able to put in motion some sort of reasonably attainable resolution.
Again, I’ve not seen this come up a great deal with the LIPs, though certainly the rest of the cadre of front line staff would be considered targets during a survey. I think the key approach is to very clearly and very simply define what constitutes appropriate responses of staff and practitioners. When The Joint Commission doesn’t specifically define what they mean in a standard, it behooves us to define how compliance works in our organizations.
If they don’t know by now…you must be remarkably emergency-free
Lately, I’ve encountered some consternation relative to emergency management, specifically EM.02.02.07, for communicating in writing to each licensed independent practitioners their role in an emergency and to whom they would report in an emergency.
From my experiences, there are any number of ways to demonstrate compliance with this performance element, and to be honest, I’ve not heard of any Joint Commission surveyors “pushing” on this issue, but it could certainly be a vulnerability. One way folks comply with this standard is through credentialing and/or re-credentialing, making use of a process that is already in place. I’m presuming that you have e-mail access for your medical staff members, in which case a simple summary of their duties/roles in an emergency response activation would suffice. Another thought would be handouts at your regularly scheduled medical staff meetings, though, depending on attendance, this might be a tough one to sell if you have a particularly picky surveyor. Anything along these lines would be quite adequate as a demonstration of compliance with this standard.
By the way, the standard does not specify a frequency, so–at least for the moment—you need only document one communication of this nature. It would certainly be appropriate to inform medical staff of substantive changes in their roles, etc., but that would not be considered a standards-based requirement.
Take our survey for a chance to win $100!
HCPro is asking for your help! To ensure that we meet your training products and services needs in 2012, please take a moment to respond to a short survey.
Are you in infection control? Take this survey.
Are you more facility safety and security (environment of care, emergency management, etc.)? Take this survey.
Involved in OSHA? Take this survey.
Complete a survey and be entered into a drawing to win a $100 gift certificate to HCMarketplace, to be spent on any HCPro product of your choice.
Follow the leader
Another survey condition that has been surfacing of late—which you could say makes it a “sighted citation—” is the bundling of EC-LS-EM findings and generating a further finding under Leadership for not ensuring that the care environment was appropriately managed. Generally, this seems to occur when there are “enough” EC-LS-EM findings to drive a condition-level status as a function of the CMS Conditions of Participation. Unfortunately, at least at the moment, it is not clear how much “enough” is required to drive the finding to this precarious level.
Not having personally participated in the applicable surveys, I can’t tell whether or not there may have been mitigating circumstances that resulted in the survey team feeling that the organization was not appropriately mustering resources to manage risk in the physical environment. That said, I can certainly tell you that one of the things that seems to thread its way through these findings is a gap in correcting deficiencies identified during maintenance and testing, including timely follow-up testing for failed systems, and timely follow-up in general. It is absolutely imperative that we have a process for managing identified deficiencies, including the identification of any interim measures (these ain’t just for life safety folks any longer, boys and girls) that would be implemented to compensate for the deficiencies. It is clear to me that there has been a shift toward the ongoing management of deficiencies through a formal process, at least in terms of survey expectations.
Although it is well understood that healthcare is not swimming in money, our overall charge is to ensure that the care environment is appropriately managed at every moment of every day; people’s lives are potentially at risk here, and we have got to be absolutely certain that we are doing everything in our power to protect them.
Random acts of impenetrable prose
Could I have a volunteer from the audience?
Whilst working in the upper part of the Midwest, I found an interesting take on how one might gather volunteers to help out as “victims” when conducting an emergency response exercise that calls for said victims (“paper” patients are OK in a pinch, but isn’t it way more fun/realistic to have some flesh-and-blood types to run through the process?) In this particular area, high school students, in order to fulfill their obligations for graduation, are charged with participating in X number of community service hours during their (hopefully) four-year stint. If I may opine for a moment, I think the community service idea is way cool and with any luck, might bring back the whole “taking care of each other” mindset that seems to have fled screaming into the night. I see way too much trash dumped by roadsides, etc., to think that we are accelerating as a culture toward a positive destination . . . but I digress.
At any rate, a process was set up with the schools that allowed for participation in emergency exercises to count toward the community service requirement. How cool is that? I don’t know if you have such a program in your neck of the woods, but I think it’s definitely worth checking out. And if you’re already doing this, how come you didn’t share it with the group? Shame, shame, shame…
Mac’s Brief on the September TJC Executive Briefings, Part 2
As promised, I continue going the standards The Joint Commission (TJC) unveiled as the top 10 most frequently cited standards for the first six months of survey year 2011 at the annual Executive Briefings meeting. Five (count ‘em) of those standards were in the environment of care (EC)/life safety (LS) world. Here are the last three:
TJC cited 47% of hospitals for LS.02.01.30 (whew, finally under 50%). This is where things went slightly awry for yours truly as it was apparently indicated that the findings (generally under EP #2, which refers to the fire protection features of hazardous areas) have to do with signage. At EB, an example was given of proper labeling of a vent stack from sterile processing that might have hazardous materials (isn’t that why we have EC.02.02.01?) Also mentioned was the concept of the risk assessment (did you really think that was ever going to go away?) to determine what soiled utility rooms should be locked or otherwise secured. Again, my thought was that this was covered under EC.02.02.01 or maybe EC.02.01.01, but in the Life Safety chapter? I didn’t see that one coming!
When it comes to standard EC.02.03.05 (of which 42% of hospitals were cited), I think the safety community has to come together and convince our maintenance and testing vendors that we are sick and tired of having our heads handed to us because they “buried” some deficiency on page 17 of a report only to have the surveyor find the stinking thing and say, “So, what about this?” We need to have a list of deficiencies identified during any maintenance and testing activity provided to us, before the vendors leave the building. We can no longer afford to wait a month or six weeks to get the report of findings; the clock starts ticking the moment these concerns are identified and we need to be jumping on them quickly and assertively, which may entail including the implementation of some sort of interim measure to ensure that we are not placing folks at risk. I absolutely understand that doing so is, in many ways, nothing but a pain in the tuchus; but until such time, as we are proactively managing this stuff, this is going to continue to be among the most frequently cited standards. I say we end it here—who’s with me? FREEDOM! Sorry, got a bit carried away there. Must be ‘cause I’m wearing my (metaphorical) kilt . . .
Finally, LS.02.01.35 (of which 36% of hospitals cited): This standard relates to all things sprinklers—the 18- inch rule, stuff hanging on sprinkler piping, cabling tied to sprinkler supports, all that stuff. Again, this is very much a numbers game. What’s the likelihood that somewhere, above some ceiling, the cable monkeys have run some conduit or other detritus over a sprinkler line or tied it to a support? Very bloody likely, I’d say, very bloody likely.
Getting back to this infection control thingy (as promised in my last post), it was announced that the life safety surveyors are receiving education relative to basic IC issues, including scope cleaning and the separation of clean and dirty scopes. The announcement brought up a thought—for those of you with not-so-generously-proportioned scope cleaning areas, particularly when the soiled and clean processes are separated only by distance and not by a physical barrier, you might want to consider a risk assessment to determine whether your processes are pristine. I know you are doing the best you can, but sometimes you have to take those types of decisions out, dust ‘em off, and look at them again to make sure they are still viable. It may be your only defense during a survey, and I say you can’t have too many of them, only not enough.
This is a public service announcement
This is a public service announcement—with guitars! (Okay, maybe not guitars) or perhaps this will work:
Money well spent…imagine that.
Every once in a while I like to share stuff that folks are developing in other areas of concerns/disciplines, and I think this one is a peach. In fact, I think it’s so useful, I’m just going to thank my good friend and colleague Marge McFarlane for sharing this with me, which helps me to share with you, and then shut the heck up:
The American College of Emergency Physicians is proud to announce the release of its newest training, Hospital Evacuation: Principles and Practices. The training can be found here.
We hope that you take the time to view the course and pass the information along. A description of the course can be found below:
“Healthcare facilities must be ready to tackle anything that comes their way. In times of disaster, natural or technological, they must remain open, operational, and continue carrying out their functions. When the situation escalates to a level that endangers the health and/or safety of the facilities patents, staff, and visitors, evacuation of the endangered areas is necessary. Safety and continuity of care among evacuees during a disaster depend on planning, preparedness, and mitigation activities performed before the event occurs. At the completion of the course, hospitals and other healthcare providers with inpatient or resident beds will have basic training and tools to develop an evacuation plan. This one-hour course will take the participant through the stages of preparing for a facility evacuation. It begins by performing an assessment of possible vulnerabilities and the resources available to a facility. Next, the course walks the learner through the development of a functional plan for a healthcare facility, and identification of key personnel positions implemented when a facility evacuates and the roles and responsibilities of each. The course concludes by addressing recovery issues, both plan development and operational.”
Good stuff, and I encourage each one of you with anything more than a passing interest in such things to check it out.
How soon is now, how safe is safe enough?
During a recent Joint Commission survey, a concern was raised because the hospital’s pediatrics and OB units were not “equipped” with the same security system, etc. I’m not certain whether the result was a specific finding, but the question, in and of itself, is instructive when it comes to the science of assessment.
First off, I’ve never actually seen the areas in question, so I will engage in a little bit of conjecture, but I think the general themes can be applied in your house, particularly if you don’t have a whole lot of pediatric patient volume. Now certainly, the historical focus on abduction prevention has been primarily on the security of newborns, which I think we can all agree is a vulnerable patient population. That said, there are certainly risks involved in providing for the security of pediatric patients (and maybe some adult patients as well—it’s getting kind of crazy out there in the world), risks that would have to include abduction.
From a regulatory standpoint, there is very little specific guidance beyond the caveat of ensuring that you are not compromising life safety concerns as you install security systems. Locking doors in egress paths can be tricky and, in virtually every instance I can think of, the process was much more complicated than was originally presumed, but that’s a story for another day. We know what the result will be if our security efforts are not sufficient/appropriate, etc.: something will happen and that something will not be good. But that raises the somewhat rhetorical question of whether you can “rest” based on nothing bad happening. Is that a legitimate conclusion to make? Variations on this theme have become very noticeable during surveys this year. Maybe it’s something identified by a vendor that you haven’t gotten around to fixing, maybe it’s a new piece of technology that you have budgeted for next year, but that’s going to take time to purchase, install, educate staff, etc. Maybe (as is more or less the case in the recent survey mentioned above) from an operational standpoint, your pediatrics unit is in a small part of a regular medical/surgical unit and the geography of the space does not lend itself to the same security measures as you have on your OB unit.
These are all real life occurrences and each has its own security or EC implications that need to be managed. But (and this is a sizable one), you have to be able to articulate where you are in the process and how you are making sure that any elevated risks that are the result of not being able to do something right now are being appropriately managed. I hate to say this, but it’s been coming up far too often in surveys this year for this to be ignored: you absolutely need to discuss and document the management of these types of risks, including those all-important interim measures (if they are needed). Otherwise, you leave yourself vulnerable to a survey finding for which it is very difficult to negotiate a “settlement” either during survey or as part of the clarification process.
There are no standards that specify a time frame for completion, a technology enhancement, etc. That’s the responsibility of each organization to manage. But with that responsibility comes the obligation to manage any associated risks in fairly transparent fashion (I think I’ve managed to avoid invoking the transparency card until now): frontline point of care/point of service staff need to be able to articulate how we are managing risk until such time as solutions can be implemented. If they can’t, the risk of a survey finding rises exponentially. It’s no longer enough for leadership to know what’s going on, the folks in the field have to know, too. Pediatrics staff need to articulate how they are managing abduction risks for their patients. And if you have pediatrics in the ED, there needs to be some competency there as well. We can’t always do what we want when we want to do it, which is the reality of healthcare. But we do need to understand and share the risk implications of all those decisions and non-decisions.
