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You might find this week’s post somewhat shocking!

One of the survey findings that I’ve noted as trending towards a standard “gotcha” (primarily during state surveys) relates to the topic of arc flash safety and, most particularly, to the labeling of your electrical panels. Generally speaking, much of this stuff is covered by NFPA 70E-2012 Standard for Electrical Safety in the Workplace, with the labeling requirements (section 130.5 (C)) being: “electrical equipment such as switchboards, panelboards, industrial control panels, meter socket enclosures, and motor control centers that are in other than dwelling units, and are likely to require examination, adjustment, servicing, or maintenance while energized” to be field marked with a label containing all the following information: (1) at least one of the following: a. Available incident energy and the corresponding working distance; b. minimum arc rating of clothing; c. required level of PPE; d. highest hazard/risk category (HRC) for the equipment; (2) nominal system voltage; (3) Arc flash boundary. NFPA 70E also requires the method of calculating and data to support the information on the label to be documented.

I know we tend to focus on hospital-specific safety concerns in this forum, but findings relating to the absence of arc flash safety labeling have surfaced enough (at least to my mind) to make it worth a mention. Part of my concern in this regard is that I see a fair number of electrical panels, etc., for which there is no arc flash safety labeling and, as near as I can tell, there appear to be no provisions for “grandfathering” existing non-compliant conditions. So you may want to take a look at your electrical panels and any other energized equipment that are “likely to require examination, adjustment, servicing, or maintenance while energized.”

And, while we’re on the subject, EC & M has a very nicely crafted presentation on arc flash safety and compliance; you’ll probably have to pony up an e-mail contact in exchange for a viewing, but I found the content to be fairly illuminating (and yes, that was a pretty gosh-darn hideous pun). Visit their site to find this info (and some other stuff as well).

The place of working dangerously: The importance of kitchen safety

Recently, I fielded a question regarding fire response plans for food services and got me to thinking about the importance (and challenges) of good safety practices in the kitchen.

My firm belief has always been that,  for all intents and purposes, the kitchen is among the most “dangerous” locations in the hospital (when you think of pretty much all the classic safety “risks”, the kitchen has them—fire, slips, trips, cuts, chemical exposures, etc.) and also possesses among the most (if not the most) transient work forces in healthcare. Add to that the frequency of the entry-level folks being new not only to healthcare, but sometimes the working world, success really rests on the effectiveness of education, from the point of onboarding through regular department education, including the conduction of fire drills.

In poking around on the web, I came across some information provided by the Lafayette (Indiana) Fire Department relative to commercial kitchen fire safety that I think is well worth checking out for some cues in how to work with the Food & Nutrition folks to ensure the education process is all that it can be. I have noticed over the years (my wife is a big fan of cooking shows) that the celebrity chefs don’t focus as much on fire safety as they do on food safety (though I suspect Gordon Ramsey might have a few choice words if one of his restaurants had a fire). And I also know that some of the key components of fire response in a kitchen is a little counter-intuitive relative to how folks are trained in general, particularly the activation of the suppression system before one tries to use an extinguisher. I think these folks deserve a fair amount of focused support and the information contained here. It really provides you with a good road map for ensuring that your kitchen areas are as safe as they can be.

2020 starts with a whimper…probably mine!

A fairly brief opening salvo for the New Year: I am hoping it will continue to be difficult to come up with material for this space because that will likely mean we’ve reached something of an equilibrium relative to funky compliance stuff. After the last decade, I think we can probably all use a bit of a rest from the madness…

For those of you keeping track of the goings on in Chicago, you’ve no doubt received any number of exhortations over the past couple of weeks to check out the “new” (the “improved” is somewhat implied, but if you order in the next five minutes, they’ll double your order!) Joint Commission website.  I will say that they have definitely spiffed up the look of the place—everything looks bigger and brighter. But (and isn’t there almost always one of them?), in retooling things, some of the less recent links to material are no longer working. To that point, I had saved a couple of links to share this week, and now that they don’t work, I can’t quite say what it was that I found of particular interest (shame on me for not leaving a better trail of bread crumbs, though perhaps those pesky birds…). So, if you do some archival digging in this space (and perhaps others as well), you may find yourself at the business end of an error message indicating a non-functioning link. Having said that, if you should follow a link from Mac’s Safety Space that dumps you somewhere in the ether, please let me know and I will either try to find the “current” whereabouts of the information you’re looking for or provide some level of analysis to assist you in your efforts.

As an almost completely unrelated item to finish this up for the week, I wanted to bring to your attention a recent finding relating to space heaters that might prove timely given this age of polar vortices (vortexes?) and all manner of cold weather. The finding relates to a portable space heater in a nurse station, with the enjoinder that, for the purposes of this performance element, nurse stations are considered patient treatment areas (looping back on the prohibition of portable space heaters in smoke compartments containing sleeping rooms and patient treatment areas). You can have them in offices that meet the definition of non-sleeping rooms, which are occupied by staff and separated from the corridor and are permitted to have portable space heaters (the heating elements must not exceed 212°F). I’m sure you know where the folks with the cold feet live, so make sure you keep a close eye on the heater situation.

Getting a word in edgewise: Take back the power!

We’re looking at a lot of cusps this week—the ending of one year and the beginning of another; the end of a decade and the beginning of the latest edition of the roaring ’20s, so I figured I’d do a quick kickoff post for your consideration.

I suspect that at some point in time over the years (or perhaps even over the minutes of each and every day), you have found yourself in a conversation that is more of a soliloquy (and not your soliloquy) as you attempt to “get a word in edgewise.” I find that engaging with a conversational steamroller is among the most frustrating occurrences (not the least being the steamroller’s seeming inability to “listen” and/or “hear” what anyone else is saying). So, as I was looking over various feeds last week, I came across an article about just this topic. Truth be told, while I found the information contained therein very thought-provoking, I haven’t been able to put these concepts to the test just yet so I can’t personally vouch for their efficacy. But I “see” the logic (and the simplicity) of the suggestions enough to definitely want to give it a try moving forward. I don’t know that I would call it a “New Year’s Resolution,” but anything that can increase the effectiveness of personal communications can’t be a bad thing.

On that note, please accept my fondest wishes for a 2020 full of personal and professional success and development and my thanks for sticking with me through the vagaries of my “head” space. I’m glad to have you all aboard!

I heard the bells! Or did I see three ships?

Yet another mixed bag of festive goodies for you this week: I know you’ve all been good (our profession doesn’t really leave a lot of room for anything other than good, so Santa Mac doesn’t even need to make a list and check it once or twice).

First up, a set of HazMat-related items for your consideration:

I’m not sure how many of you folks are still managing ethylene oxide sterilization systems, but it does appear that there’s a movement afoot (or a continuation of an existing movement) to really pare back on the use of ethylene oxide. At present, the proposed rule seems to be aimed at folks using larger quantities of ethylene oxide (more than 1 ton of ethylene oxide per year), but I suspect that the next pass may well start to push down through the smaller-scale users. To that end, the information on the EPA website is probably worth looking at to determine where your current processes and equipment might fall on that continuum. I don’t know any safety professional who is keen to have the stuff in their “house”, but there remains reusable medical equipment that can only be appropriately sterilized (per manufacturer Instructions For Use) with ethylene oxide, so hopefully things will catch up and we can move past this risk.

Next up, an interesting article on increasing climate friendliness in your surgical procedure rooms. I guess anything that can reduce energy costs is worth investigating, though it may work better for those of you planning renovations or new construction of surgical procedure rooms. At any rate, I find that it’s always kind of interesting to see what’s working for folks (recognizing the importance of knowing what doesn’t work as well), so a tale from the land of the New English.

Extending the renovation/construction thought, Becker’s Hospital Review recently published an article discussing healthcare facility construction trends to watch in 2020. I suspect that Becker’s is something that might be on the reading list of the folks in the C-Suite, so it might be worth working their take on construction into your pleas for resources. It certainly can’t hurt.

Finally (I haven’t decided if I’m going to have anything for you next week—I’d rather you enjoy your families), I wanted to share a link to a blog by Peter Martin of Gosselin-Martin Associates that shares some quotes and insights gathered over the last year (and a fitting jumping off point for the (hopefully) next roaring ’20s). If you’re not familiar with Peter and Gosselin-Martin, I would encourage you to do a little checking of the additional blog entries as well as the services they provide. I’ve corresponded fairly often with Peter over the years and I’ve found him to be a consummate professional and a very thoughtful guy—an excellent resource to be sure.

On that note, I will extend my best wishes to each and every one of you for a joyous holiday and that “roaring” start to the ’20s mentioned earlier. Be safe (not that you need me to tell you that) and I’ll be back in almost no time flat!

It appears that everything isn’t meant to be OK…

You may recall a few weeks back we were discussing some recent survey findings relative to the placement of eyewash stations once one has determined that one needs an eyewash station (or stations). At the time, my dream was to clarify those findings and have them vanish into the ether (which is pretty much where they belong). But alas, that dream crashed upon the rocks of an overreach—can’t say for sure if this signals a sea change or is based on a reluctance to overturn a judgement call in the field. The ruling from the home office read thusly (but not justly): “The organization must do a risk assessment to determine if substances that may be in the sink would not splash onto the person using the eyewash station and inadvertently be contaminated.”

And so, I guess we add an additional imponderable to the equation: How do we install the eyewash station close enough to the area of greatest risk without placing the eyewash in a location that could be adjudged to be too close to the risk area? I suppose the ultimate goal would be to try to remove the hazard entirely, but with all the focus on disinfection and the likelihood that whatever disinfectant in use is going to be firmly in the high-risk zone, that seems unlikely to win favor during survey. Is it possible to “sell” engineering controls to a surveyor that is looking to find things to cite? I think we can all agree that the use of PPE and other forms of engineering controls are probably never going to be the interventions we would hope for them to be, but it is often so difficult to protect folks from themselves.

That said, I suppose it wouldn’t be the worst idea to do a little global evaluation of your eyewash station locations (much like a conjunction function) and add yet another risk assessment to the mix. If you’ve got a survey coming up in the near future, it may save you some aggravation.

 

Thank you for being round pegs in a square world…

As this is a somewhat shortened week (in complete recognition that safety never takes a holiday), I just wanted to briefly touch base to thank you all for hanging out (and hanging through) the various twists and turns of the last decade or so. Sometimes being the safety “cop” can be a frustrating endeavor, but this week I’d like to (and I’d like you to do so as well) focus on the folks I encounter who “get it right” all day, every day. That’s not to say that I’ve run into any perfect organizations (and I will count myself among the imperfectionists), but there are those (and I count you all among that number) who understand that the process of improving the safety of an organization is not so much about yesterday as it is about tomorrow (and the next day) and the commitment to those tomorrows is what sets us apart from (and sometimes in opposition to) other folks. It takes a unique set of skills to embrace all that is safety in healthcare (and elsewhere) and I am proud to be able to provide some level of service to your cause.

At any rate, please accept my sincerest wishes to you and your families for a most joyous Thanksgiving—and an enormously safe Friday after for those of you about to shop—I salute you!

More safety goodness next week!

Sticker shock: Compliance your way (not someone else’s)!

As we continue our October re-visitation of some of your more evergreen topics and I was thinking that I had covered this particular topic recently, but it turns out it was rather a long time ago—2012, to be exact (my, my, my, how time flies!).

I guess the general thought/concern relates to whether any particular piece of equipment has to have a due date sticker or some variation thereof. And, interestingly enough, while this still surfaces from time to time, the requirement (or lack thereof) has not really changed in the last seven or so years. Is there a benefit to having a due date so line staff can include a visual when they are using a piece of equipment? Absolutely! If you use color-coded outdate stickers, can it make it easier to discern when something is in arrears? It sure can! Can an outdate sticker call into question the efficacy of your process if there are too many of the “wrong” color floating around? Yup!

If you’re going to use them, then by all means make full use of them. Make sure line staff understand what information is contained on the sticker. Make sure they understand that if a sticker gets removed during the cleaning process, that is an important piece of information to communicate to clinical engineering or whoever is responsible for maintaining the equipment. And, please—for the love of all that is good and practical—try to stay away from policies that speak to the necessity of a sticker being present; another evergreen survey truth is that non-compliance with an internal process is one of the toughest survey findings to clarify. Everything (and anything) you do that is not specifically required by code and regulation should make sense from an operational standpoint. If there’s a program element that has, shall we say, evolved (or mutated) over time and is giving you compliance fits, take it out, dust it off, and make sure that whatever it is brings value to the process. And if it doesn’t? Time to move on!

In a world of magnets and miracles: Shifting the sands of compliance

At the risk of engaging in non-sequiturial (which autocorrect keeps insisting should be non-equatorial) content, I want to touch on a couple of short items that came across my desk over the last couple of days. I don’t know that they specifically relate to each other, but I can imagine a sufficiently powerful pattern recognition program that could link the two (think really, really big picture).

First up, we have some conversation relative to CMS’ efforts to increase the validity of the process by which CMS oversees (or validates) the work of the various accreditation organizations (AO) as they engage in the deemed status survey process. Until recently, the CMS validation process involved a survey visit close on the heels of the AOs (typically within 60 days or so) to see how closely the completed survey met the expectations of CMS vis-à-vis the Conditions of Participation. Historically, there have always been gaps between what was found by the AOs and what was found by CMS, with a lot of pushback on the part of the AOs relative to the timing of things—healthcare organizations are, if nothing else, fluidity personified. So, in response to the timing pushback, CMS has started co-surveying with TJC in real time; so, instead of dealing with your usual complement of TJC surveyors, you also get to host—at the same time—a group of CMSers. Ostensibly, the purpose of the CMS team is to observe the survey efficacy of the Joint Commission team,  but I think you can see where what has never been a “pleasant” experience could really go sideways. I personally have not heard any tales of folks having experienced this type of event, but I feel certain that someone I know will be able to share some stories of daring do and horror-filled antics. Any takers? It would seem (based on a blog post from TJC) that some organizations have expressed gratitude for not having to go through two separate survey events, and there’s a general sense that the CMS/AO survey findings are of a piece, so I guess that’s a good thing. But somehow…

At any rate, at the moment, if your organization is going to have this extra special survey experience, there will be prior notification, but there appear to be plans afoot to end up at a point in which these extra special surveys will be completely unannounced. It also appears that moving in that direction will require some modification to the language in the Conditions of Participation that authorize the validation surveys. According to the blog, the current process is in place through federal FY 2020 (October 1, 2019 through September 30, 2020), so I guess we’ll have to wait and see how things go.

To take this in a completely different direction (well, maybe not completely…) I came across an article providing some advice on conducting one-on-one meetings with staff. As a consultant, it’s been rather a while since I’ve had to administer one-on-one staff meetings, so this may be old hat to you folks with current operational oversight of line staff, but it did prompt me to think about past practices and I can see where this might be helpful in a lot of different ways. I am a firm believer in trying to make every encounter more useful and I think this might be a strategy worthy of your consideration. So, if you need something to read as we start the wind-down of summer (it’s the last week of August—how did that happen?!?), I think this would be worth your time (and please let me know if you think otherwise—any and all feedback is most appreciated!).

Have a safe and festive Labor Day!

Don’t forget to leave room for amazement: The perils of occupational fatigue

If you’ll bear with me, friends, this week deals not so much with the harsh realities of our vocation, but with the hope that those harsh realities can be effectively managed.

One of the true blessings of my work as a consultant is the opportunity to change things up on a regular basis—meeting new people and seeing new places while still renewing acquaintances encountered on the journeys of the past 18 years. And, as I think about it, I do hope (at least some of the time) this blog provides you with some level of diversion, but occupational fatigue (aka work burnout) is more common than serves anyone’s benefit.

I am in the habit of collecting things that interest me, and sometimes I’ll encounter something of sufficient interest that I want to share it with you folks. In wandering around the internet in the wake of the anniversary of the first moon landing, I came across a blog post (written by Brad Stulberg) describing some ways of dealing with work burnout that I felt was worth sharing.

As with so many things that “occur” to me, it’s not so much the revelatory aspect of the piece (though there is that to some degree), but rather the “tone” of the article that really caught my attentions to the extent that I wanted to share this with you. It doesn’t necessarily relate to safety in a global sense (though I could make the case that it does relate to personal safety to a fair degree), but I think anything that can shift the direction of conversation, even for the briefest of moments, is time well spent.

So, a short one this week, but that should give you some time to seek out a little amazement—you can never have too much magic in your life!