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Making a checklist, making it right: Reducing compliance errors

As you may have noticed, I am something of a fan of public radio (most of my listening in vehicles involves NPR and its analogues) and every once in a while, I hear something that I think would be useful to you folks out in the field. One show that I don’t hear too often (one of the things about terrestrial radio is that it’s all in the timing) is called “Hidden Brain”, the common subject thread being “A conversation about life’s unseen patterns.” I find the programs to be very thought-provoking, well-produced, and generally worth checking out.

This past weekend, they repeated a show from 2017 that described Dr. Atul Gawande’s (among others) use of checklists during surgical (and other) procedures to try to anticipate what unexpected things could occur based on the procedure, where they were operating, etc. One of the remarks that came up during the course of the program dealt with how extensive a checklist one might need, with the overarching thought being that a more limited checklist tends to work better because it’s more brain-friendly (I’m paraphrasing quite a bit here) than a checklist that goes on for pages and pages. I get a lot of questions/requests for tools/checklists for doing surveillance rounds, etc. (to be honest, it has been a very long time since I’ve actually “used” a physical checklist; my methodology, such as it is, tends to involve looking at the environment to see what “falls out”). Folks always seem a little disappointed when the checklist I cough up (so to speak) has about 15-20 items, particularly when I encourage them not to use all the items. When it comes to actual checklists that you’re going to use (particularly if you’re going to try and enlist the assistance of department-level folks) for survey prep, I think starting with five to seven items and working to hardwire those items into how folks “see” the environment is the best way to start. I recall a couple of years ago when first visiting a hospital—every day each manager was charged with completing a five-page environmental surveillance checklist—and I still was able to find imperfections in the environment (both items that they were actually checking on and a couple of other items that weren’t featured in the five-pager and later turned out to be somewhat important). At the point of my arrival, this particular organization was (more or less) under siege from various regulatory forces and were really in a state of shock (sometimes a little regulatory trouble is like exsanguination in shark-infested waters) and had latched on to a process that, at the end of the day, was not particularly effective and became almost like a sleepwalk to ensure compliance (hey, that could be a new show about zombie safety officers, “The Walking Safe”).

At any rate, I think one of the defining tasks/charges of the safety professional is to facilitate the participation of point-of-care/point-of-service folks by helping them learn how to “see” the stuff that jumps out at us when we do our rounds. When you look at the stuff that tends to get cited during surveys (at least when it comes to the physical environment), there’s not a lot of crazy, dangerous stuff; it is the myriad imperfections that come from introducing people into the environment. Buildings are never more perfect than the moment before occupancy—after that, the struggle is real! And checklists might be a good way to get folks on the same page: just remember to start small and focus on the things that are most likely to cause trouble and are most “invisible” to folks.

Don’t bleed before you are wounded, and if you can avoid being wounded…

…so much the better!

Part of me is wondering what took them so long to get to this point in the conversation.

In their latest Quick Safety utterance, our friends in Chicago are advocating de-escalation as a “first-line response to potential violence and aggression in health care settings.”  I believe the last time we touched upon this general topic was back in the spring of 2017 and I was very much in agreement with the importance of “arming” frontline staff (point of care/point of service—it matters not) with a quiver of de-escalation techniques. As noted at the time, there are a lot of instances in which our customers are rather grumpier than not and being able to manage the grumpies early on in the “grumprocess” (see what I did there?!?) makes so much operational sense that it seems somewhat odd that we are still having this conversation. To that end, I think I’m going to have to start gathering data as I wander the highways and byways of these United States and see how much emphasis is being placed on de-escalation skills as a function of everyday customer service. From orientation to periodic refreshers, this one is too important to keep ignoring, but maybe we’re not—you tell me!

At any rate, the latest Quick Safety offers up a whole slate of techniques and methods for preparing staff to deal with aggressive behaviors; there is mention of Sentinel Event Alert 57 regarding violence and health workers, so I think there is every reason to think that (much as ligature risks have taken center stage in the survey process) how well we prepare folks to proactively deal with aggressive behaviors could bubble up over the next little while. It is a certainty that the incidence rate in healthcare has caught the eyes and ears of OSHA (and they merit a mention in the Quick Safety as well as CDC and CMS), and I think that, in the industry overall, there are improvements to be made (recognizing that some of this is the result of others abdicating responsibility for behavioral health and other marginalized populations, but, as parents seem to indicate frequently, nobody ever said it would be fair…or equitable…or reasonable…). I personally think (and have for a very long time, pretty much since I had operational responsibilities for security) that de-escalation skills are vital in any service environment, but who has the time to make it happen?

Please weigh in if you have experiences (positive or negative are fine by me) that you’d feel like sharing—and you can absolutely request anonymity, just reach out to the Gmail account (stevemacsafetyspace@gmail.com) and I will remove any identifying marks…

E to the E to the E to the E: Next step(s) towards a reporting culture

Thinking that this may have gotten lost in the year-end shuffle, I wanted to take a moment to cover a little ground relative to Sentinel Event Alert (SEA) #60: Developing a reporting culture: Learning from close calls and hazardous conditions. I believe (I was going to say “know,” but that’s probably a little more hyperbolic than I can reasonably venture, but I’m basing it on your “presence” here—you folks are all about getting better and on the off chance that I provide something useful to that end, I’m pleased to have you along for the ride) that you folks are committed to ongoing evaluation of performance, occurrences, funky happenstance, etc. and so little of this will come as anything resembling revelation. That said, I think we do need to prepare ourselves for the wild and wacky world of surveyor overreach and draconian interpretation. Part of my “concern” (OK, perhaps most of it) revolves around the innate simplicity of the thrust of SEA #60. It’s straightforward, cogent, and all the things you would want through which to develop a compliance framework:

  • Establish trust
  • Encourage reporting
  • Eliminate fear of punishment
  • Examine errors, close calls and hazardous conditions

But, how do you know when you’ve actually complied with this stuff? Is this more of an activity-driven requirement: We’re going to do A, B, and C to “establish” trust, then we’ll do D, E, F, G, and H to encourage reporting? (Aren’t we already encouraging reporting?) And the whole “eliminate fear” thing (I’ve had one or two bosses that would have a hard time not administering some sort of retributory action if you messed up)…how do you pull that off? Likely, the examination of errors and close calls is a normal part of doing business, but the examination of hazardous conditions seems less of a fit in this hierarchy. My own tendency when I find a hazardous condition is to try and resolve it (I do love a good session of problem-solving), but maybe it’s more of an examination once someone reports the condition as hazardous. Not quite sure about that.

At any rate, there’s lots of information available on the subject, including an infographic on the 4E methodology, as well as the usual caches of information, etc. which you can find here and here and here.

I am a big fan of encouraging the reporting of stuff by the folks at the point of care/point of service, so to the extent that this moves healthcare in that direction, I’m all for it. So, my question to you is: Does  this represent a shift for the way in which you practice safety in your organization or perhaps gives you a little bit more leverage to get folks to “say something if they see something”? Does this help or is it just so much “blah, blah, blah”?

Philo-safety: Improving our practice in 2019

In case it has not become abundantly clear over the last decade or so of penning this blog, there is something about this time of year that sets me to pondering the enormity of just about anything and everything (if I’m not doing onsite work, my morning routine is to get my first 10K steps in before breakfast—plenty of time to contemplate, ruminate, and various other solipsistic activities). To enhance the “environment” of the morning walk, I listen to podcasts that tend to cover other folks’ life experiences. One of my favorites is the Nerdist podcast, which tends to lean towards tech and entertainment coverage, but lately there’s been a conversational thread relating (to various degrees) to the philosophy of stoicism (please bear with me: I’ll loop this back around in a minute).

For those of you not familiar with the roots of stoicism, it goes back to the times of the ancient Greeks and, if I may steal a passage from Epictetus (bet you never expected to find him here—and neither did I!), the foundational notion geos a little something like this: “In life our first job is this, to divide and distinguish things into two categories; externals I cannot control, but the choices I make with regard to them I do control. Where will I find good and bad? In me, in my choices.” (if you’re interested in finding out more about the particulars of Epictetus and the philosophy of stoicism, you can find a bunch of stuff here).

So in looking at that dynamic, I started to think about the importance of how we, as safety professionals, interact with our “charges.” By that, I mean: Do we react to circumstances or do we respond to them? While there is a case to be made for react and respond as synonyms, I think that there is a subtle (OK, maybe not that subtle) shift from a “reaction” to a “response.” To me, “response” tends to be the result of a more thoughtful, measured consideration of whatever issue, concern, etc., we might be facing. Framing this in this age of social media, I think we need only glance at Twitter (and sometimes the various newscasts) if you’re looking for some reactive materials, but “response” seems rather more in short supply than is good for any of us. At any rate, my personal challenge for this year is to work towards the “response” side of the equation and to reduce the level of reactivity (including while driving in Massachusetts!).

One of the things that can (and does, to one degree or another) influence our reactive versus responsive nature is the presence of what can euphemistically be referred to as “implicit social cognition,” which manifests itself as hidden or unconscious bias. One could certainly debate how much impact implicit social cognition has on our individual lives, practices, etc., but there is a group at Harvard University that is trying to collect data on just this topic with anonymous testing and other activities. I’ve always been fascinated by the various psychologies that influence the workplace environment and I think the folks at Project Implicit are looking at some really interesting stuff. I haven’t done a deep, deep dive into their materials yet, but I did take the first Implicit Association Test and I can definitely see how this process might help each of us understand some of our inner workings. I do believe that the more we can learn about ourselves and how we interact with others can only help the “quality” of those interactions. To that end, I would encourage you to check out the materials noted here and if you do (no pressure), please let me know (you can share it with the group or with me directly at stevemacsafetyspace@gmail.com).

And here’s to a safe, healthy and productive 2019!

Last Call for 2018: National Patient Safety Goal on suicide prevention

While I will freely admit that this based on nothing but my memory (and the seeming constant stream of reasons to reiterate), I believe that the management of behavioral health patients as a function of ligature risks, suicide prevention, etc., was the most frequently occurring topic in this space. That said, I feel (reasonably, but not totally) certain that this is the last time we’ll have to bring this up in 2018. But we’ve got a whole 52 weeks of 2019 to look forward to, so I suspect we’ll continue to return to this from time to time (to time, to time, to time—cue eerie sound effects and echo).

If you’ve had a chance to check out the December 2018 edition of Perspectives, you may have noticed that The Joint Commission is updating some of the particulars of National Patient Safety Goal (NPSG) #15, which will be effective July 1, 2019, though something tells me that strategies for compliance are likely to be bandied about during surveys before that. From a strategic perspective, I suspect that most folks are already taking things in the required direction(s), so hopefully the recent times of intense scrutiny (and resulting survey pain for organizations) will begin to shift to other subjects.

At any rate, for the purposes of today’s discussion, there is (and always will be) a component relating to the management of physical environment, both in (and on) psychiatric/behavioral health hospitals and psychiatric/behavioral health units in general hospitals (my mother-in-law loves General Hospital, but I never hear her talking about risk assessments…). So, the official “environmental risk assessment” must occur in/on behavioral health facilities/units, with a following program for minimizing the risks to ensure the environment is appropriately ligature-resistant. No big changes to that as an overarching theme.

But where I had hoped for a little more clarity is for those pesky areas in the general patient population in which we do/might manage patients at risk to harm themselves. We still don’t have to make those areas ligature resistant, with the recommendation aimed at mitigating the risk for patients at high risk (the rest of the NPSG covers a lot of ground relative to the clinical management of patients, including identification of the self-harm risks). But there is a note that recommends (the use of “should” in the note is the key here, though I know of more than a handful of surveyors that can turn that “should” into a “must” in the blink of an eye) assessment of clinical areas to identify stuff that could be used for self-harm (and there’s a whole heck of a lot of stuff that could be used for self-harm) and should be routinely removed when possible from the area around a patient who has been identified as high risk. Further, there is an expectation that that information would be used to train staff who monitor these high-risk patients, for example (and this is their example, but it’s a good ‘un), developing a checklist to help staff remember which equipment, etc., should be removed when possible.

It would seem we have a little time to get this completed, but I would encourage folks to start their risk identification process soon if you have not already done so. I personally think the best way to start this is to make a list of everything in the area being assessed and identify the stuff that can be removed (if it is not clinically necessary to care for the patient), the stuff that can’t be removed (that forms the basis of the education of staff—they need to be mindful of the stuff that can’t be removed after we’ve removed all that there is to be removed) and work from there. As I have maintained right along, in general, we do a good (not perfect) job with managing these patients and I don’t think the actual numbers support the degree to which this tail has been wagging the regulatory dog (everything is a risk, don’t you know). Hopefully, this is a sign that the regulatory eyeball will be moving on to other things.

The coexistence of safety leadership and empathy

Two items this week; one survey-related musing and a suggestion for your holiday season reading list.

Monthly GFCI testing: How are you making that happen? While I believe this came up during a mock survey (albeit by an “official” accreditation organization that starts with the letter “C,” ends with a “Q” and greets you if you look in the mirror…), these things sometimes feed on themselves, so to speak. And, since this is one for which I suspect folks might have some challenges, I figured I’d open this Pandora’s Box just in time for the holiday season.

In this particular mock survey, the facilities folks were asked to produce documentation of the monthly testing of the ground fault circuit interrupter (GFCI) receptacles, which is required as a function of the manufacturer’s instructions for use. In this particular instance, the response was generally minimal, with some questioning back as to the validity of the question. Of course, a quick web search for the GFCI receptacles in question (manufactured by Hubbell) revealed that, why yes indeedy, the monthly testing is right there in the details (I think this may be a good take on who lives in the details, but I digress). In this particular instance, the hospital wasn’t doing it, hadn’t done a risk assessment—either as a singularity or as a function of including the receptacles in an Alternative Equipment Management (AEM) program. So, I put the question to the studio audience: How many of you folks out there are doing the monthly testing of the GFCI (or are you not)? Have you gone the AEM route for this one? Seems like it would be a good candidate with which to get your feet “wet” relative to the risk assessment process. Somehow, I think this might be the dawn of the latest “gotcha” finding, so maybe a little fair warning is in order.

Moving on to the bookshelf (I still read books—I don’t mind using a tablet for some stuff, but for real “reading,” I still like the tactile sensation of a book), I’m in the middle (well, a little past middle, say ¾) of a book entitled “Forged in Crisis—The Power of Courageous Leadership in Turbulent Times” by Nancy Koehn. The book contains five stories of historical figures (Ernest Shackleton, Abraham Lincoln, Frederick Douglass, one less well-known to me—Dietrich Bonhoeffer—and Rachel Carson). So far, and probably because his story was the least familiar to me, the Dietrich Bonhoeffer portion of the book was most interesting. He was a minister in Germany during the period leading up to, and through, World War II. I won’t spoil any of the details but one key element of Herr Bonhoeffer’s leadership that’s identified (among others) is empathy, with the point being “the more volatile the larger environment, the more crucial it is for…others with significant authority to appreciate the experiences of those with less power and fewer options.” For a number of reasons (some personal, some professional) that struck me as a very useful quality to possess when one is trying to manage a large and complex environment, particularly consideration of that less power/fewer options dynamic. At any rate, I’m all in favor of lionizing positive role models, so if you have some reading time over the holidays, you might find this a most compelling read.

You might have succeeded in changing: Using the annual evaluation to document progress!

I know some folks use the fiscal year (or as one boss a long time ago used to say, the physical year) for managing their annual evaluation process, but I think most lean towards the calendar year. At any rate, I want to urge you (and urge you most sincerely) to think about how you can use the annual evaluation process to demonstrate to leadership that you truly have an effective program: a program that goes beyond the plethora of little missteps of the interaction of humans and their environment. As we continue to paw through the data from various regulatory sources, it continues to be true more often than not that there will be findings in the physical environment during your organization’s next survey. In many ways, there is almost nothing you can do to hold the line at zero findings, so you need to help organizational leadership to understand the value of the process/program as a function of the management of a most imperfect environment.

I think I mentioned this not too long ago: I was probably cursing the notion of a dashboard that is so green that you can’t determine if folks are paying attention to real-life considerations or if they’re just good at cherry-picking measures/metrics that always look good. But as a safety scientist, I don’t want to know what’s going OK, I want to know about what’s not going OK and what steps are being taken to increase the OK-ness of the less than OK (ok?!?). There are no perfect buildings, just as there are no perfect organizations (exalted, maybe, but by no means perfect) and I don’t believe that I have ever encountered a safety officer that was not abundantly aware of the pitfalls/shortcomings/etc. within their organizations, but oh so often, there’s no evidence of that in the evaluation process (or, indeed, in committee minutes). It is the responsibility of organizational leadership to know what’s going on and to be able to allocate resources, etc., in the pursuit of excellence/perfection; if you don’t communicate effectively with leadership, then your program is potentially not as high-powered as it could be.

So, as the year draws to a close, I would encourage you to really start pushing down on your performance measures—look at your thresholds—have you set them at a point for which performance will always be within range. Use the process to drive improvement down to the “street” level of your organization—you’ve got to keep reaching out to the folks at point of care/point of service—in a lot of ways they have the most power to make your job easier (yeah, I know there’s something a little counterintuitive there, but I promise you it can work to your benefit).

At any rate, at the end of the process, you need to be able to speak about what you’ve improved and (perhaps most importantly) what needs to be improved. It’s always nice to be able to pat yourself on the back for good stuff, but you really need to be really clear on where you need to take things moving forward.

It’s been a quiet week in Lake Hazard-be-gone: Water and Legionella

Not a ton of “hair on fire” stuff in the news this week, so (yet again), a quick perusal of something from the “things to consider” queue.

It seems likely that Legionella and the management of water systems is going to continue to have the potential for becoming a real hot-button issue. I suppose any time that CMS issues any sort of declarative guidance, it moves things in a (potentially) direction of vulnerability for healthcare organizations. That said, it might be worth picking up the updated legionellosis standard from ASHRAE to keep up with the current strategies, etc. I don’t know that there’s any likelihood of eradication of Legionella in the general community (by the way—and I’m sure this is the case, but it never hurts to reiterate—those of you with responsibilities for long-term care facilities are definitely in a bracket of higher vulnerability). But there remains a fair amount of risk in the community, as evidenced by the most recent slate of outbreaks. Water is definitely the common denominator, but beyond that, this can happen anywhere at any time, so vigilance is always the end game when it comes to preventive measures.

As a final thought for the week, I wanted to share a blog item (not mine) that I found very interesting as food for thought (the concept is very powerful, though you may have a tough time convincing your boss to embrace it, as I think you’ll see): treating failure like a scientist. You can find the whole post here, but the short take is that you may have a positive or a negative result of whatever strategy you might employ—each of which should be considered data points upon which you can make further adjustments. Not everything works the way you thought it would, but rather discarding something outright if it doesn’t succeed, try to figure out the lesson behind the failure to make a better choice/strategy/etc. moving forward. The blog covers things more elegantly than I did here, but I guess my closing thought would be to have the courage (maybe “luxury” is the better term) to really learn from your mistakes—if we were perfect, there would never be a need for improvement.

Time to bust a cap in your…eyewash station?!?

Howdy folks! A couple of quick items to warm the cockles of your heart as winter starts to make its arrival a little more obvious/foreboding (at least up here in the land of the New English) as we celebrate that most autumnal of days, All Hallows Eve (I’m writing this on All Hallows Eve Eve)…

The first item relates to some general safety considerations, mostly as a function of ensuring that the folks who rely on emergency equipment to work when there is an emergency are sufficiently prepared to ensure that happens. It seems that lately (though this is probably no more true than it usually is, but perhaps more noticeable of late) I’ve been running into a lot of emergency eyewash stations for which the protective caps are not in place. Now I know this is partially the result of too many eyewash stations in too many locations that don’t really need to have them (the reasoning behind the desire for eyewash stations seems to lean towards blood and body fluid splashes, for which we all know there is no specific requirement). At any rate, my concern is that, without the protective caps, the eyewash stations are capable of making the situation worse if someone flushes some sort of contaminant into their eyes because stuff got spilled/splashed/etc. on the “nekkid” eyewash stations. The same thing applies to making sure the caps are in place for the nozzles of the kitchen fire suppression system (nekkid nozzles—could be a band name!—can very quickly get gunked up with grease). We only need these things in the event of an emergency, but we need them to work correctly right away, not after someone wipes them off, etc. So, please remind the folks at point of care/point of service/point of culinary marvels to make sure those caps are in place at all times.

The other item relates to the recent changes in the fire safety management performance element that deals with your fire response plan. Please take a moment to review the response plan education process to ensure that you are capturing cooperation with firefighting authorities when (periodically) instructing staff and licensed independent practitioners. One of the ages-old survey techniques is to focus not so much on the time-honored compliance elements, but rather to poke around at what is new to the party, like cooperation with firefighting authorities (or 1135 waiver processes or continuity of operations plans or, I daresay, ligature risk assessments). It would seem that one of the primary directives of the survey process is to generate findings, so what better way to do that than to “pick” on the latest and (maybe not so) greatest.

Have a safe reorientation of the clocks!

I’ve been there, I know the way: More Executive Briefings goodness

You’ve probably seen a smattering of stuff related to the (still ongoing as I write this) rollout of this year’s edition of Joint Commission Executive Briefings. As near as I can tell, during the survey period of June 1, 2017 to May 31, 2018, there were about 27 hospitals that did not “experience” a finding in the Environment of Care (EC) chapter (98% of hospitals surveyed got an EC finding) and a slightly larger number (97% with a Life Safety chapter finding) that had no LS findings. So, bravo to those folks who managed to escape unscathed—that is no small feat given the amount of survey time (and survey eyes) looking at the physical environment. Not sure what he secret is for those folks, but if there’s anyone out there in the studio audience that would like to share their recipe for success (even anonymously: I can be reached directly at stevemacsafetyspace@gmail.com), please do, my friends, please do.

Another interesting bit of information deals with the EC/LS findings that are “pushing” into the upper right-hand sectors of the SAFER matrix (findings with moderate or high likelihood of harm with a pattern or widespread level of occurrence). Now, I will freely admit that I am not convinced that the matrix setup works as well for findings in the physical environment, particularly since the numbers are so small (and yes, I understand that it’s a very small sample size). For example, if you have three dusty sprinkler heads in three locations, that gets you a spot in the “widespread” category. I don’t know, it just makes me grind my teeth a little more fiercely. And the EP cited most frequently in the high likelihood of harm category? EC.02.02.01 EP5—handling of hazardous materials! I am reasonably confident that a lot of those findings have to do with the placement/maintenance of eyewash stations (and I’ve seen a fair number of what I would characterize as draconian “reads” on all manner of considerations relating to eyewash stations, which reminds me: if you don’t have maintenance-free batteries for your emergency generators and you don’t have ready access to emergency eyewash equipment when those batteries are being inspected/serviced, then you may be vulnerable during your next survey).

At the end of the day, I suppose there is no end to what can be (and, clearly, is) found in the physical environment, and I absolutely “get” the recent focus on pressure relationships and ligature risks (and, soon enough, probably Legionella–it was a featured topic of coverage in the EC presentation), but a lot of the rest of this “stuff” seems a little like padding to me…