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If this is really accurate, how big of a deal is this to you?

First off, I will indeed stipulate that any instance of workplace violence, whatever causative factors might be in play, is at least one too many instances of workplace violence. We deal with what appears to be an increasing potential for angry (and I’m using that as a catch-all—there are so many shades in the spectrum of rage) feelings to be acted upon, sometimes at the most minute of stimulations (I was going to use provocation, but I have certainly witnessed instances of acting out in response to so little, it boggles my mind). In response, it appears that our friends in Chicago are pushing towards a more demonstrative focus on issues related to workplace violence through the establishment of some new standards in the EC chapter.

From a practical standpoint, I don’t know that there’s anything so “new” here that folks are going to have to reconfigure their programs. In all likelihood, the elements being promulgated are among the things that you’ve been looking at for more than a little while (I did remember a time when workplace violence wasn’t quite so prevalent in healthcare and there were some places for whom this was not a topic of great consideration). So, the things that will clearly be a focus in the coming survey cycle include: an annual analysis of workplace violence prevention considerations, which would in turn result in mitigation of risk elements that cannot be resolved; monitoring of workplace violence occurrences, including reporting and investigation of said occurrences; providing education and training appropriate to the risks of workplace violence in the organization; and the participation of organizational leadership in these efforts, through establishment, and ongoing implementation, of a workplace violence prevention program. I am paraphrasing a wee bit here (you can find the verbiage here) but I guess the question I keep coming back to is: who isn’t doing this? I cannot imagine that there is a healthcare organization in the United States that is not struggling with this to some degree; the effective management of the risks associated with workplace violence.

The other interesting note from the above-referenced materials is the characterization of workplace violence occurrences being underreported, which may very well be the case, but it begs the question of what that actually means? There are certainly many points in the occurrence “chain” in which something might go unreported—and I suspect we have room for improvement there, if only in getting folks to the point where they’ll speak up. But underreporting beyond someone choosing not to speak up seems fraught with peril; the occurrences that come to the attention(s) of committees, services, etc. are not easily dismissed, etc., particularly as a function of regulatory reporting. I suppose this is one way to “leverage” an existing program by playing the compliance card (XYZ agency requires us to do this, etc.), but given the difficulties associated with the retention of staff, etc., how is it not in everyone’s best interests to have an effective process? I do not believe that we are in the habit of knowingly placing folks at risk without some level of preparation, but I also know that, for a fair number of safety professionals, the competing priorities that tend to reduce the opportunities for providing direct education to frontline workers are more bountiful than ever. I think we need to try and use the numbers to advance the cause of education and preparation for staff to deal with these ever-more-likely-to-happen events.

Time has come today: There’s late and there’s LATE

Depending on where you are, you may be bumping up against process elements that are causing certain activities to be “late,” even beyond the grace periods you’ve woven into your management plans, etc. And with the Delta variant becoming more and more of a factor, there is a fair likelihood that the challenges of scheduling activities, particularly those provided by resources external to your organization. I wish that I had a “magic bullet” for this, beyond invocation of the ongoing Public Health Emergency and making use of the 1135 Waiver process (remember when it was really unclear as to what that all meant?). But I think those items should be enough, with a little judicious planning and discussion, to get you over the compliance hump. If you need a primer on that process, be sure to visit the CMS website dealing with such things.

As a somewhat related aside, it does appear more than likely that our friends from Chicago (and, likely, others of the regulatory persuasion) will be moving towards a full embrace of the remote review of documentation. And while that may end up reducing a surveyor day or two from future surveys (they do have a lot of documents to review, so that time would shift from the onsite schedule), it also increased the importance of making sure that your committee minutes, annual evaluations, and other foundation documents provide as much compliance information as possible. Clearly document what waivers have been adopted and for how long; clearly document any risk assessments/mitigation strategies for compliance gaps or shortfalls. While I won’t ask you to “air out your dirty laundry,” you absolutely want to be forthcoming on the impact COVID response has had on normal operations. And if something is late, document the issue resulting in the tardiness of the activity and, again, use the risk assessment process to clearly document that you’re not putting folks at risk while things are sorting themselves out.

As a final note, the Chicagoans are working very diligently to try and get things back on track from a survey perspective, so if you’re expecting them any time soon (or they haven’t shown up yet), I think you need to plan on seeing them before the end of the first quarter of next year. That’s not to say there might not be outliers, but they’re definitely going to be knocking on your door before you know it.

Thanks for all you’ve done and continue to do. It’s made all the difference!

Processing processes: Keeping everything in front of you…

I’m thinking that there’s probably a fairly limited number of you folks for whom durable medical equipment (DME) is part of your “span of control,” though, as I think about it, there may be some confluences with the DME world for those of you who provide home care services to your patients. As a going concern, this doesn’t necessarily come up on my radar a lot, but sometimes the real world provides some examples of process gaps (I won’t go so far as to call them failures—I don’t have enough data to make that assertion just yet) that might be instructive.

There’s a member of my household who uses a device to provide breathing assistance while sleeping and has for quite some time. It would seem that the device in use is the subject of a recall notice from the Food & Drug Administration (FDA), which we learned about from a family friend. After doing some research on the web (because there had been no official notification received in this regard), as one is wont to do under such circumstances, it turned out that the device in question, which is indeed involved in the recall, had never been registered with the manufacturer. Once the registration of the device was completed, the recall notice showed up around a week later. We’re still digging into the particulars, but it would seem that the DME supplier did not include registering the device as part of their “service” nor was there an effective communication as to the need for the registration to be completed within the household. I use the descriptor “effective” because it is possible that the communication was provided (I suspect that that will be the “defense” rendered by the DME company), but was insufficient to ensure that the device was registered with the manufacturer. I suspect that in this instance, like in many others, the communication was designed more towards the knowledge base of the person or persons providing the content and not so much the knowledge base of the person (or persons) receiving the information.

I can “see” what probably happened with this whole thing, but I keep coming back to the thought that transferring the responsibility of registration, etc., to the end users seems to be a recipe for all sorts of problems. There are certainly times when the management of a device or process is most powerfully administered by the end users (for instance, weekly eyewash station checks), but in the absence of a true orientation and ongoing education process for those end users, some of the administration really should be in the hands of the most knowledgeable party/parties. That said, if you have folks at home using breathing assistance devices, it might be worth checking out the recall if you’ve not yet encountered it. Also, you might find it of value to bookmark the FDA’s safety communications page; it’s well-organized and has a lot of useful information. Again, this may not apply professionally to everyone, but it never hurts to consider process gaps as they may well be instructive in other areas.

Making movies on location…

One of the constants of any effective physical environment/safety program is the effort to ensure that folks at point-of-care/point-of-service are provided adequate education and training to ensure ongoing competency. I suspect that each of you make what use you can of the “regularly scheduled” activities like fire drills, surveillance rounds, tracers, etc., to be able to get face time with folks, but as healthcare organizations become increasingly more complicated, it makes me wonder to what extent it is possible to “get” to even a majority of folks in your organization.

As a subset consideration to this, with the intended focus on the outpatient settings, at what point does the safety competency of staff outside of your/our direct oversight become a significant (potential) vulnerability relative to the survey process? In a perfect world, everyone would receive the “same” basic orientation, but I think even that can be a difficult undertaking, particularly when it comes to the folks in the outpatient settings.

The question I have for group discussion is how much folks have been able to take advantage of mobile video technology to educate staff? I have never been a particularly big fan of computer-based learning as, at least in pretty much all the instances with which I am familiar, the programs tend to be a little too much “cookie cutter” for my liking. I also know that the past 15-18 months probably haven’t left a lot of time for big productions, but has anyone out there been able to harness technology in a sufficiently “personal” way to effectively provide education to the folks in your charge?

I’m curious as to whether anyone is developing their own content, etc. Please share if you’ve got something you’re working on, or anything you’ve finished. I suspect that things are going to become more complicated on the education front and some sharing of ideas and approaches might just be the key to future success!

If you remember nothing else: Nothing happens in isolation…

With the (presumed) onset of regulatory surveys including a more thorough review of survey results past, I would imagine that everyone out there in the listening/reading audience can name at least a couple (if not more) instances of non-compliance that were (for want of a better term) “missed” during survey. Just to use a simple example (which we touched upon back in the wilds of winter), your most recent surveyor may have stopped looking for improperly labeled breakers (spares in the on position; breakers in the on position not labeled, etc.). But the question becomes: How many more are out there…and how carefully did someone look post-survey? Certainly, whatever was identified would have been corrected as part of the plan of correction—you can’t be telling regulators that you did something that you didn’t do, now can you? But what about other potential findings? Now, I recognize that using this particular example is (hopefully) a wee bit hyperbolic in that (again, hopefully), the low risk findings are going to get a mulligan if there are recurrences. If you have really crappy luck, you could have an exit sign burn out every time you have a survey or something similar (can anyone say “improperly segregated compressed gas cylinder”?) but I would think that the little stuff is not going to drive a seriously negative survey result, with perhaps one exception.

The exceptional item (or items) are those in which the management of the care environment crosses into the realm of infection control and prevention: damaged/non-intact surfaces, stained ceiling tiles, etc. The reason for my concern with this stuff is it is really hard to manifest a solid process for managing these incidental conditions without hard-wired participation of point-of-care/point-of-service folks. I don’t know, I’m just having a hard time wrapping my head around taking issue with findings/conditions similar to those found in previous surveys. Now, if we’re talking widespread versus isolated, I can see widespread issues maybe pushing a survey in the wrong direction, but I still think the severity has to come in to play to some degree, as well as the (ever-present) potential for recurrence. To my mind, the stuff that gets broken/damaged tends to be because those are the things that suffer the most “abuse” (and I use that in the most general of meanings). It’s like the fire doors near the loading dock—tell me they don’t have a significantly greater potential for damage, during a survey or not.

At any rate, I think the important thing is to work diligently to ensure that those isolated findings are not the tip of a widespread iceberg. I don’t think we can just stop with what was cited anymore.

Next week, we’ll spend a little time with the “new” expectations relating to the management of workplace violence; I’m still trying to figure out if there’s anything that is truly “new” (I tend to think no, but you never know what might be hiding in the nuances), but we should at least start the discussion of where things seem to be going.

Hope you had a safe and festive Independence Day!

In your eyes: The light, the heat, the flushing fluid…

As is often the case (it probably says more about me than anything else, but what can one do?), it seems that there are always conversations to have about the practical nature of the risks of occupational exposure to injurious chemicals and how eyewash stations figure in the greater reality that is healthcare. In general, we know that eyewash stations are only “required” when there is a risk of occupational exposure to injurious chemicals (here’s a reasonable reinforcement of that interpretation), but somehow, everywhere I go there are eyewash stations in areas for which there is no risk of occupational exposure, etc. It’s possible that there might have been in the past, but the organization was able to make good use of the hierarchy of controls to reduce the risk of occupational exposure by either eliminating the hazard or substituting the product with something that is not injurious. That is not always going to be the case, but it occurs to me that rather than just talk about eyewash stations as a going concern, let’s look at what you can do to either remove ones you have or forego having to ever install an eyewash station in the first place. Which reminds me, if you are building new or renovating existing space, make sure the architects/designers with whom you are working understand when eyewash stations are actually required. I’m finding a lot of eyewash stations in new construction that don’t belong—soiled utility rooms, etc. It’s probably worth asking them for a list of locations where eyewash stations are earmarked for installation; it might save you some aggravation in the future.

At any rate, in the previous passage, I noted the “good use” of the hierarchy of controls, so I thought that this might be a good opportunity to walk through that general concept. Fortunately, this is a topic about which the good folks at NIOSH have given some thought. What follows is rather along the lines of a (very basic) primer, but there’s lots of good content available through the CDC/NIOSH portal.

Hierarchy of controls

  • Elimination: Remove the hazard
  • Substitution: Replace the hazard
  • Engineering Controls: Isolate people from the hazard
  • Administrative Controls: Change the way people work
  • PPE: Protect the worker with personal protective equipment

You may notice that eyewash stations don’t really figure in to the hierarchy, primarily because the role of eyewash stations is in the event of an emergency as the result of a failure of the above-noted controls to prevent the exposure (again, it’s kind of basic, but nonetheless true for its simplicity). I don’t know that there’s necessarily a right or wrong answer for any of this (which has a lot to do with why this is such a perennial consideration in the safety field), but I do know that using the hierarchy to work through how you manage risks of occupational exposure makes a great deal of sense (well, at least it does to me). Please look over the available information and let me know what you think.

I wish each of you and your families a most safe and festive Independence Day (the year is half over—who’d a thunk?!?). See you next week!

They blew the horns…and the walls came down!

Continuing our intermittent discussion about returning to normalcy on the facilities operations front, I’ve been reflecting on the monumental amount of facility modifications that have occurred over the last 15-18 months and what those modifications might portend for the future. I’ve seen all matter of materials used to facilitate containment of patient care units and I was wondering, now that there is lessening need for a lot of these temporary structures, if folks have been thinking about how they would “do it again next time” as they deconstruct the temporary walls. In some instances, I’m sure we’ve had loads of fun removing tape residue from various surfaces (where would we be without tape!?!) and perhaps gone back to review those pesky ILSMs that sprouted up over time. I’m still not sure how ILSM assessment will “play” with the 1135 waivers: Are they required, are they not, are they in the “eye of the beholder”?

At any rate, I’m hoping that somewhere in the hive mind of your organization there is a clear picture of what modifications were made on the fly, which prompted me to do a little poking around on the interwebs regarding the practical application of temporary barriers and I ran across this, which (if you’ve not seen it) I think you’ll find useful as a thought provoker (provocateur?).

Clearly, we are all about wanting to do things better and I think the questions/concerns/considerations raised in the article are definitely worthy of conversation as we plan for the next event. The “good” thing about temporary containment is we don’t have to wait for the next pandemic to get familiar with the modular concept. There are likely going to be construction and renovation projects coming your way and what better “test market” for containment?

So, that’s it for this week. I continue to hope that the true onset of summer will provide some level of opportunity for down time. The older I get, the more I appreciate the “beauty” of time off—even if it’s time off for home projects. Just to be able to focus on stuff that’s not related to “work” is pretty awesome—try it—you’ll like it!

Wishing you wellness and safety!

It’s these little things, they can pull you under…

I guess this week’s entry (as it appears that Spring is actually going to spring) falls into the “a little bit of this, a little bit of that” category; nothing monumentally earth-shattering, but (hopefully) useful.

First up, a recent post from the American Society of Health Care Engineering’s (ASHE) YouTube channel (somehow, it escaped me that such a thing existed—shame on me!) popped up on some feed somewhere (it may have been LinkedIn, but I can’t say for sure) and I found it a very interesting topic of conversation: “The Cost of No.” Given the givens, I suspect there are not too many in the audience who haven’t been at the receiving end of a “no” response (as opposed to no response, which is equally frustrating), and this video may give you some food for thought in how best to manage that impregnable wall. It’s not often that we get what we want, when we want, but I think the video offers some insight into how to plead a better case—to the point that it might increase the chances for a positive response “next time.” The video is pretty short (you can spare 158 seconds, can’t you?) and there are a number of other short videos that are worth checking out, so don’t forget to subscribe. You can start with “No” right here, but please check out the other stuff as well.

Moving on, in a designation that doesn’t seem to have been influenced by Hallmark, March is National Ladder Safety Month (I would have sent a card, but couldn’t even find a birthday card with a ladder that could have been repurposed) and I think we can all agree that ladders are an important part of the compliance picture. I’ll let you find your own “ladder unsafety” images—there are more than I can count, but I think we can also agree that the safe use of ladders could be more thoroughly hardwired into a lot of folks’ practice, including inspecting the ladders before use.

At any rate, I encourage you to set up a ladder safety session for your folks, particularly if you haven’t done so in a while – and what better month to do so. Here are some resources to help ensure folks embrace the heights of safety:

Until next week, hope you are well and staying safe. We’ve made it this far and I am confident we can make it through this together!

Breaking the law: Not something you want to be doing…

A very quick item this week, mostly because I want you to have the opportunity to take advantage of a resource that I think is well worth your time and you only need your ears…if you’re thinking podcast, you’re thinking in the right direction. For those you that might not be familiar with Gosselin/Martin Associates, they are a highly respected (at least by me—and I know I’m not alone) organization (and I’m paraphrasing a bit here) devoted to the systemic improvement to healthcare facilities management. From recruitment, education, mentoring, etc., Gosselin/Martin Associates are a most reliable resource on so many levels, but for this week, I would encourage you to check out their High Reliability—The Healthcare FM Podcast to check out the current climate as it relates to the legal ramifications of healthcare facilities management. As a going concern, amidst our current state of being, being familiar with the legal implications of what we do has arguably never been more important and the likelihood that that importance will increase is virtually a sure thing. As with all things everywhere, there is only so much black and white interpretation, etc., to go around, but I think you’ll find this discussion to be quite illuminating, if only to validate what you might already be thinking/experiencing, etc. The blog post for the podcast can be found here and I very much encourage you to subscribe. I find it very stimulating to listen while I am walking in the morning (bedtime probably won’t work—this won’t put you to sleep!), but I suspect you’ll find your own “best time.” I hope you take a few moments to check out High Reliability.

As always, hope you are well and staying safe!

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

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

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

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

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