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Punching above your weight: Virtual inspections are coming!

As we continue the endurance test that is 2020, one of the general concepts that keeps cropping up relates to external folks (I hesitate to characterize them as “agencies” because of the potential for this to extend well beyond intrinsically compliance or regulatory-related processes) wanting to “visit” with you while minimizing the potential for physical “exposure” to your organization. For example, those of you who have been able to complete construction and/or renovation projects that require oversight from various folks, including your contractors, as a function of the punch list process before one can “close out” the project—in full recognition that the closing out of a project tends to represent a process under which as much of the “to-do” list is handed over to the onsite facilities folks by the contractor. And, yes, I suspect that statement reveals something in the way of a bias regarding the close-out process—but it’s a shoe that fits far more often than I would like, based on my experience.

Be that as it may, virtual inspections can be very much a double-edged sword (once again mixing far too many metaphors) in that, in some instances, the less that is found, the better (think the regulatory compliance angle), and, in other instances, the more that is found, the more “real” the assignment of responsibility for repair, etc. (i.e., the project close-out process). A little bit ago, I was chatting with a facilities director who was bemoaning the fact that his contractor had elected to conduct the punch list inspection virtually (not exactly sure how the process was administered, but it sounds like the facilities folks did not have representation in that process until after the punch list was received). An internal review of the space revealed a number of items that were not otherwise complete that (for whatever reason; you might be able to guess one or two) did not make it to the virtual punch list.

Ideally, the virtual inspection process would be an effective means of ensuring that everything in your building is “up to snuff,” but is the technology at a reliable point? Particularly if you’re the one left “holding the bag” if conditions, etc., get missed during the process and show up sometime in the future. I know some of the tech solutions are more than fascinating at first blush, but how do you folks feel is the appropriate level of trust for the results of the virtual survey? Please weigh in as you see fit. I’m really curious about folks’ experiences.

As we head towards the inevitability of autumn, I hope this finds you in good health and safe. Please keep it that way!

Brother/Sister, can you spare a sprinkler head?

This week, I continue my ruminations on all things relating to outpatient care sites (Quick question: Is there anyone out there who doesn’t have responsibility for any outpatient care locations? I hope not, because this is probably getting a little tedious, though I guess in that hope it means that your existence has become more complicated over time, but if you don’t, you probably will). At any rate, this week’s tidbit revolves around the requirements for all (and I do mean “all”) properties having sprinkler heads to have a list of the sprinkler heads installed in the property, with the list being posted in the sprinkler cabinet. I think everyone is familiar with the requirements to have a stock of spare sprinklers, which would include all the types and ratings installed, with the number of spares guided by the following algorithm:

6.2.9.5 The stock of spare sprinklers shall include all types and ratings installed and shall be as follows (this also shows up in NFPA 25-2011 in Chapter 5) :

(1) For protected facilities having under 300 sprinklers – no fewer than 6 sprinklers

(2) For protected facilities having 300 to 1000 sprinklers – no fewer than 12 sprinklers

(3) For protected facilities having over 1000 sprinklers – no fewer than 24 sprinklers

By the way, the information contained in this week’s missive is sourced from the 2010 edition of NFPA 13 Standard for Installation of Sprinkler Systems, which came into play when CMS adopted the 2012 edition of the Life Safety Code® (LSC). As a cautionary note, now this information “lives” in NFPA 25 Standard for the Inspection, Testing & Maintenance of Water-Based Fire Protection Systems, so if you happen to have a state authority having jurisdiction that’s using a more recent edition of the LSC, then NFPA 25 is where you’ll find this stuff.

At any rate, back to that all-important list (and kudos to those of you who have your lists in place), bopping back to NFPA 13, we find the following:

6.2.9.7.1* The list shall include the following:

(1) Sprinkler identification number (SIN) if equipped; or the manufacturer, model, orifice, deflector type, thermal sensitivity, and pressure rating

(2) General description

(3) Quantity of each type to be contained in the cabinet

(4) Issue or revision date of the list

The Appendix provides a little more info:

A.6.2.9.7.1 The minimum information in the list contained in the spare sprinkler cabinet should be marked with the following:

(1) General description of the sprinkler, including upright, pendent, residential, ESFR, and so forth

(2) Quantity of sprinklers to be maintained in the spare sprinkler cabinet

Where the rubber meets the road, so to speak, is the requirement for an annual verification of all this stuff:

NFPA 25-2011: 5.2.1.4 The supply of sprinklers shall be inspected annually for the following:

(1) The correct number and type of sprinklers as required by 5.4.1.4 and 5.4.1.5

(2) A sprinkler wrench for each type of sprinkler as required by 5.4.1.5.6

5.4.1.5* A supply of at least six spare sprinklers shall be maintained on the premises so that any sprinklers that have operated or been damaged in any way can be promptly replaced.

A.5.4.1.5 – A minimum of two sprinklers of each type and temperature rating installed should be provided.

5.4.1.5.1 The sprinklers shall correspond to the types and temperature ratings of the sprinklers in the property.

5.4.1.5.2 The sprinklers shall be kept in a cabinet located where the temperatures will at no time exceed 100 degrees F.

5.4.1.4.2.1 Where dry sprinklers of different lengths are installed, spare dry sprinklers shall not be required, provided that a means of returning the system to service is furnished.

So that’s the partial skinny on sprinklers; the primary reason for plunking this down in front of you is because this showed up as a finding (mostly the list, but the other stuff is fair game) in a recent survey (not The Joint Commission, but these things tend to move through the various regulatory tribes).

I did want to leave you with a final thought for the week. I subscribe to a weekly email newsletter from James Clear (the following lives here); I find the newsletter interesting and much more often than not, useful, so I give you:

“What is the real goal?

  • The real goal is not to ‘beat the market.’ The goal is to build wealth.
  • The real goal is not to read more books. The goal is to understand what you read.
  • Don’t let a proxy become the target. Don’t optimize for the wrong outcome.”

Stay well and stay safe—that’s all I need you to do!

Burning with optimism’s flame: A future state in which surveys are less frightening…

As you are all no doubt familiar at this point, one of the key management processes promulgated by (or is it through?) the 2012 edition of NFPA 99 Health Care Facilities Code is that of the risk assessment as a means of determining how to best manage risks to folks using our facilities—patients, staff, visitors—it’s a tall order no matter how you parse it.

That said, I read a very interesting article in ASHE’S Health Facilities Management publication on how the industry might be able to start moving towards a standard process/practice with the (more or less) aim of being able to develop data that can truly demonstrate that the risk factors being used to determine the level of risk are supported by the numbers. Ultimately, the go-forward on this would be to have a robustly data-driven program for the management of equipment (utility systems equipment as well as medical equipment) that establishes a framework for performance, determining effectiveness, etc. that would be bulletproof during a survey. As a description of a useful future state (as opposed to the same ol’, same ol’ survey process of calm interspersed with periods of insane demands from our “customers”), I think you’ll find a lot to think about, so I encourage you to give it a look.

Moving on to what may be a trending esoteric finding, it appears that covering any outside cylinder storage locations might be one of which to be mindful. Strictly speaking, we are on the hook for protecting stored cylinders from overheating (with a target temperature of 130 degrees F—pretty hot stuff), which one might suppose is a least to some degree,  a function of geography (I would imagine there are some locales for which 130 degrees of ambient temperature might be an occurrence of some rarity. That said, if you do have cylinder storage space exterior to your facility, it might behoove you to document a little risk assessment (perhaps in coordination with your medical gas and vacuum testing vendor) to determine whether your cylinders are too hot to handle (strictly from a code perspective).

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!