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Wagging the dog: Can Accreditation Organizations influence each other?

In last week’s issue of HCPro’s Accreditation Insider, there was an item regarding the decision of the folks at the Healthcare Facilities Accreditation Program (HFAP) to update their Infection Control standards for acute care hospitals, with the intent of alignment with CMS expectations (you can find the article here) We’ve certainly covered the concerns relative to Legionella and the management of risks associated with aerosolizing water systems and this may only be a move to catch up on ground already covered by other accreditation organizations (our friends in Chicago already require the minimization of pathogenic biological agents in cooling towers, domestic hot- and cold-water systems, and other aerosolizing water systems), but I’m thinking it might also be something of a “tell” as to where survey focus might be drifting as we embark upon the second half of 2018. Certainly, waterborne pathogens are of critical importance to manage as a function of patient vulnerability (ideally, we want folks to get better during their hospital stays), so it makes perfect sense for this to be on the radar to some degree. At this point, the memorandum from CMS outlining their concerns has been with us for about a year, with an immediate effective date, so hopefully you are well-entrenched in managing those water systems. If this one is still on your to-do list, I think it’s probably advisable to making it a priority to get it to your “to-done” list. But you should definitely check out the latest “clarification” from CMS. While the memo indicates that this does not impose any new expectations or requirements, it does make it a little clearer as to what surveyors are supposed to be checking.

As I think Mr. Gershwin once opined about summer and the easiness of living, it would be nice to be able to set a spell and take one’s shoes off, but vigilance is always the order of the day.

On a somewhat lighter note, I just finished reading Our Towns – A 100,000 Mile Journey Into The Heart of America, which outlines the efforts of a number of (mostly smallish) municipalities across the United States in positioning themselves for a positive future (positive positioning—I kind of like that). The focus is mostly on the socioeconomics of different parts of the country, with a focus on how diversity can be employed in bettering a community (that’s probably a little ham-handed as a descriptor, but you can find an excerpt here if you like). As my work allows me to travel to a lot of places, while I haven’t been to a lot of the same destinations as the Fallows, I do recognize a lot of the stories and a lot of the challenges facing folks lately (and I think you might, too). I would describe the tone of the book as hopeful, so if you’re looking for something to read at beach/pond/summer cottage, etc., you might consider giving Our Towns a shot.

 

A quiet week in Lake Forgoneconclusion: Safety Shorts and Sandals!

But hopefully no open-toed sandals—maybe steel toed sandals…

Just a couple of quick items as we head out of the Independence Day holiday and into the heat of the summah (and so far, scorching has been the primary directive up here in the Northeast—hope it’s cooler where you are, but I also hope it didn’t snow where you are either…but I guess if you were in Labrador last week, all bets are off).

When last week’s musings on the ligature risk stuff in the July Perspectives went to press (or when I finished my scribbling), the new materials had not yet made their way to TJC’s Frequently Asked Questions page, though I thought that they might—and that’s exactly what has happened. To the tune of 17 new FAQs for hospitals, so if you haven’t yet laid eyes on the July Perspectives, head on over to the FAQ page and immerse yourself in the bounty (that’s a somewhat weird turn of phrase, but I’m going to stick with it).

While you’re there, you should definitely poke around at some of the other stuff on the FAQ page. There are lots and lots of recommendations for risk assessment types of activities, so if you’re looking for some risk minimization opportunities, you might find some useful thoughts. Of particular note in this regard is the practical application of safety practices in those organizational spaces for which your oversight is somewhat more intermittent; I’m thinking offsite physician practices or medical office buildings and similar care locations. Depending on where you are and where they are, it might not be quite so easy to keep a really close eye on what they’re doing. And while I tend to favor scheduling surveillance rounds with folks in general, I also know that if you don’t stop by from time to time, you might not catch any lurking opportunities (and they do tend to be lurksome when they know you’re coming for a visit). In a lot of the survey results I’ve seen over the last 18 months or so, there’s still a pretty good chunk of survey findings generated during the ambulatory care part of the survey process. Safety “lives” at the point of care/service, wherever that may be—definitely more ground to cover now that in the past. At any rate, I think you could use the FAQ stuff as a jumping off point to increase the safety awareness of folks throughout—and you can do that independently of anyone’s vacation schedule (including your own).

Hope you and yours had a most festive 4th!

Will it go ’round in circles? More managing the physical environment relative to suicide risk!

Hopefully you have already gotten a chance to look through the July 2018 issue of Perspectives for the latest reveals on how (at least one accrediting body) is working through the issues relating to ensuring each organization has a safe environment for the management of behavioral health patients. There is a fair amount of content (this comes to us in the form of FAQs—presumably these will find their way to the official FAQ page, if they have not yet done so) and splits up into three general categories: inpatient psych units, emergency departments (ED), and miscellaneous. (I’m going to guess that the FAQs relative to managing at risk patients in acute care settings is going to merit their own FAQ edition, so I guess we’ll have to stay tuned.)

I don’t know that I would term anything to be particularly surprising (lots of emphasis on the various and sundry risk assessment processes that comprise an integrated approach to such things), though they do make some efforts to describe/define, going so far as to indicate that only patients with “serious” suicidal ideation (those with a plan and intent) need to be placed under “demonstrably reliable monitoring” (aka 1:1 monitoring), with the further caveat that the monitoring be linked to immediate intervention, which means something in terms of competency, education, experience, etc. Clearly (and I completely agree with this) there is an expectation relative to who does the monitoring that probably doesn’t include a rookie security officer or other newbie. I personally have advocated for a very long time the use of folks who are specifically prepared for these types of activities, so maybe that idea is going to approach something of a standard. We shall wait and see.

Another interesting item is the indication that if you (and, yes, I mean you!) designate a room in your ED as a “safe room,” then the expectation (at least for TJC) is that room (or rooms if there are more than one) would be ligature resistant. Makes sense, but I think it does represent something of a caution for those of you looking at designating safe rooms in your EDs (and perhaps extending to the inpatient side of things—probably in the next installment). I guess the other interesting thing (and this probably doesn’t apply to all) relates to freestanding EDs: the recommendations (you can check out the November 2017 issue of Perspectives for the particulars if you’ve not yet done so) for EDs would apply. I understand that this is rather a big deal in general and is very close to endlessly complex in the practical application of the management of risks. I think this is one “ball” we’re going to be keeping an eye on for the next little while.

To end this week in the truth is stranger than almost anything category, I was looking through an email (devoted to all things culinary) and I noted a headline: “We’re All Using Clorox Wipes Wrong, Apparently” and I said to myself, “Dwell times have entered the vernacular of the American household” (I’m not saying it’s anything more than a toehold, but still) and darned if I wasn’t pretty much spot on. The other “revelation” is the absence of bleach in some of the kitchen wipe products identified in the article (I think I knew that, but I can’t really say when I might have acquired said knowledge). There’s also some information on what surfaces should be cleaned with certain kitchen wipes, etc. At any rate, I thought it worth sharing, at least as an example of how our work can span all demographics.

Happy Independence Day to all!

Education < / = / > Achievement: Don’t Let Survey Prep Get in the Way of Good Sense

I’d like to start off this week with an interesting (and hopefully instructive) tale from the field:

I was doing some work recently at an organization that is facing down the final six months of its survey window. This was my first visit to the facility and I was working on getting a sense of the place as well as identifying the usual list of survey vulnerabilities. As we’ve discussed before, one of the things that’s always in the mix, particularly with the gang from Chicago, is the care and feeding of emergency eyewash stations. This particular organization has adopted the strategy of having folks at the department level perform the weekly testing (a sensible approach from my standpoint—I think the most important piece of the weekly testing is helping to ensure that folks who might actually need the eyewash in an emergency actually know how the darn thing works), but the documentation form had two columns: one for the date and one for the signature of the person doing the test. The sheet did not, however, have any instructions on it, which prompted me to inquire as to how folks would know what (and why) they are checking, since the purpose is not just to run the water. The response to my inquiry was rather noncommittal, which is not that unusual, so I continued to collect data relative to the process. So, over the course of the facility tour, we found a couple of eyewashes with missing caps and no clear indication on the testing form that this had been identified as an issue. OK, not crazily unusual, but pointing towards a process that could use some tweaking. A couple of eyewashes with obstructed access provided a little more data.

Then we made our way to the kitchen. No real compliance issues with the eyewash itself, but I noted that they were checking the eyewash station on a daily basis and recording the temperature at that same frequency. Now, the ANSI standard does not require daily verification of eyewash flushing fluid temperature, so I asked about this particular practice (BTW: Nowhere else had we seen this practice—at least not yet …) and was informed another hospital in the region had been cited for not doing the daily temp checks (I have not been able to verify that this was an actual survey finding, but sometimes believing is enough … to cause trouble). And then we headed over to the lab and ran into a similar practice (they were just verifying the temps during the weekly test) and the feedback there was that a College of American Pathologists (CAP) surveyor had told them a story about an individual that had suffered eye damage because the (low temperature) water from the eyewash interacted with a chemical. This was not written up as a finding, but was relayed as an anecdotal recommendation.

The “funny” thing about all this (actually, there are a couple of process gaps) is that each of the eyewash stations in question are equipped with mixing valves, which pretty much mitigates the need for daily or weekly temperature checks (you want to check the temp when you’re doing the annual preventive maintenance activity). But the more telling/unfortunate aspect of this is that (independent of each other) these folks had unilaterally adopted a process modification that was not in keeping with the rest of the organization (it has been said, and this is generally true, that you get more credit for being consistently wrong than inconsistently right). Now, one of the big truisms of the survey process is that is almost impossible to push back when you are not compliant with your own policy/practice. And while I absolutely appreciate (particularly when the survey window is closing) wanting to “do the right thing,” it is of critical importance to discuss any changes (never mind changes in the late innings) with the folks responsible for the EOC program. While I pride myself on not telling folks that they have to do something that is not specifically required by code or regulation, some of the regulatory survey folks don’t share that reticence. The other potential dynamic for these “mythical” requirements is when a surveyor tells an organization something that doesn’t show up in the actual report. I run into this all the time—they may “look” at the finding in the report, but what they sometimes react to is what the surveyor “said.” Compliance has way more than 50 shades of whatever color you care to designate and what works/worked somewhere else doesn’t always work everywhere, so folks make these changes without knowing what is actually required and end up increasing the potential for a survey finding.

And healthcare isn’t the only pursuit in which incomplete communications (or making sure that communications are as complete as they can be) can have an impact. At the moment, I am reading An Astronaut’s Guide to Life on Earth by Col. Chris Hadfield (this, apparently, is going to be the summer for reading astronaut memoirs, be that as it may) and I came across a passage in which Hadfield describes a debriefing following a practice spacewalk in which one of the instructors noted that while Hadfield has a “very clear and authoritative manner,” he encouraged the folks participating in the debrief to not be “lulled into a feeling of complete confidence that he’s right.” As soon as I saw that, I was able to tie it back to the management of surveyors who speak in a “very clear and authoritative manner” and sometimes turn out not to be worthy of complete confidence that the surveyor is correct. If you are doing something that, in good faith and the extent of your knowledge, is the “right thing” and somebody (even me!) comes along and says you’re not doing that right, never be afraid to ask to see where it says that in the code/regulation, etc. (BTW: I’m not giving you permission to be obnoxious about it!) Surveyors (same for consultants) see a lot of stuff and sometimes compliance becomes a fixed idea, or process, in their head, but that doesn’t mean it’s the only way. And if you hear something that makes you think you have a vulnerability (something you’ve heard through that pesky grapevine), talk it out before you make any changes. That gives everyone in your organization a fighting chance at compliance.

As a final note, if you’ve forgotten about Col. Hadfield’s most notable performance (beyond the astronaut thing), check it out:

Documentary evidence: Sounds like you’re going to have to push a little more paper next survey!

A few weeks ago, our friends in Chicago upped the ante in releasing the updated documentation list for the Life Safety portion of the survey (you can find it—and I really, really, really suggest that you do so sooner rather than later—by logging into your Joint Commission portal and the clicking through the following internal links: > Survey Process, > Survey Activity Guide, > Additional Resources). And this is definitely a case of the list having shifted towards documentation of activities and conditions for which folks have been struggling to get in line. Now, from anecdotal discussions with folks, there’s not always a ton of time available for document review. So, in a lot of instances, the focus is on inspection, testing and maintenance of fire alarm and suppression systems equipment, emergency and standby power supply systems, medical gas and vacuum systems, with some “drift” into fire drills and other more or less standard areas of concern/coverage, including the management plans (sometimes—and those don’t appear to have earned a mention on the updated list).

However, according to that same updated document list, looks like a lot of focus on inventory lists (operating components of utility systems; high-risk operating components on your inventory, infection control components); “embracing” (you can think of that as reviewing and adopting) manufacturer recommendations for inspection, testing and maintenance of utility systems or outlining the Alternative Equipment Maintenance program being used. And the same types of things for medical equipment—inventory, high risk equipment, consideration of manufacturer recommendations, etc. It also appears that there will be focus on sterilizer inspection, testing, and maintenance; compliance of your hyperbaric facilities (if you have them) with Chapter 14 of NFPA 99-2012; testing manual transfer switches in your emergency power supply system. Let’s see, what else…oh yes, for those of you with recently (I’m guessing that pesky July 6, 2016 date is the key point in time) constructed or renovated procedural areas, you need to make sure that you have (and are testing) task lighting in deep sedation and general anesthesia areas (the annual testing requirement is for a 30-minute test).

I’m sure there’s other stuff that will pop to the surface as we move through this next phase of the survey process; I’m curious about how much in-depth looking they’re going to be able to do and still be able to get to the lion’s share of your building (unless they start using unmanned drones…). I’m also curious that they don’t specifically indicate the risk assessment identified in Chapter 4 of NFPA 99-2012 (it has been asked for during CMS surveys), but that may be for the next iteration. Part of me can’t help but think back to those glory days when we wished for adoption of the 2012 Life Safety Code®; I guess we can take full advantage of the operational flexibilities inherent in suite configuration and a couple more things, but it never really seems to get any easier, does it?

At any rate, please hop on your organization’s TJC portal and give the updated list a look. If you see something that gives you hives, sing out: we’re all here to help!

With a purposeful grimace and a terrible sound: Even more emergency management!

As much as I keep promising myself that I’ll poke at something more varied, the news of the day keeps turning back in the direction of emergency preparedness, in this case, just a little bit more on the subject of continuity of operations planning (COOP).

Late last week, our friends in Chicago proffered the latest (#41) in their series of Quick Safety (QS) tips, which focuses on elements of preparedness relating to COOPs (nobody here but us chickens). Within the QS tip (small pun intended), our Chicagoan overlords indicate that “continuity of operations planning has emerged as one of the issues that…need to address better in order to be more resilient during and after the occurrence of disasters and emergencies.” The QS also indicates a couple of best practice focus areas for COOPs:

  • Continuity of facilities and communications to support organizational functions.
  • A succession plan that lists who replaces the key leader(s) during an emergency if the leader is not available to carry out his or her duties.
  • A delegation of authority plan that describes the decisions and policies that can be implemented by authorized successors.

Now, I will freely admit that I always thought that this could be accomplished by adopting a scalable incident command structure, with appropriate monitoring of critical functions, inclusive of contact information for folks, etc. And, to be honest, I’m not really sure that having to re-jigger what you already have into something that’s easy for surveyors to discern at the 30,000-foot survey level is going to make each organization better prepared. I do know that folks have been cited for not having COOPs, particularly as a function of succession planning and delegation of authority (again, a properly structured HICS should get you most of the way there). So, I guess my advice for today is to figure out what pieces of your current EOP represent the COOP requirements and highlight them within the document (I really, really, really don’t want you to have to extract that stuff and create a standalone COOP, but if that helps you present the materials, then I guess that’s what you’d have to do…but I really don’t like that we’ve gotten to this point). At any rate, the QS has lots of info, some of it potentially useful, so please check it out here.

As a closing thought: I know folks are working really diligently towards getting an active shooter drill on the books, with varying degrees of progress. As I was perusing various media offerings, I saw an article outlining the potential downsides of active shooter-type drills. While the piece is aimed at the school environment, I think it’s kind of an interesting perspective as it relates to the practical impact of planning and conducting these types of exercises. It’s a pretty quick read and may generate some good discussion in your “house.”

What the world needs now: Effective management of workplace violence

By now I’m sure you’ve all noted the unveiling of the latest Sentinel Event Alert (#59 for those of you keeping count) from our friends in Chicago; this particular SEA represents the third swing at concerns and considerations relative to workplace safety, inclusive of workplace violence. But, as I look at the information and guidance provided in the May 2018 issue of Perspectives, it makes me wonder what pieces of this remain elusive to folks, beyond the “normal” operational challenges of providing effective safety education to staff on a regular basis.

So, my questions for the group are these:

  • Have you clearly defined workplace violence?
  • Have you put systems into place across your organization that enable staff to report workplace violence events, inclusive of verbal abuse?
  • Have you identified all the potential sources of data relative to workplace violence occurrences?
  • Are you capturing, tracking, and trending all reports of workplace violence, inclusive of verbal abuse and attempted assaults, when no harm occurred?
  • Are you providing appropriate follow-up and support to victims, witnesses, and others impacted by workplace violence, including psychological counseling and trauma-informed care?
  • Are you reviewing each case of workplace violence to determine the contributing factors?
  • Are you analyzing data related to workplace violence, and worksite conditions, to determine priority situations for intervention?
  • Have you developed any quality improvement initiatives to reduce incidents of workplace violence?
  • Have you provided education to all staff in de-escalation, self-defense, and response to emergency codes?
  • Are you evaluating on an ongoing basis the effectiveness of your workplace violence reduction initiatives?

If your response to any of these questions is “no” or “not sure,” it’s probably worth (at the very least) some discussion time at your EOC and/or organizational QAPI committee, but I have a strong suspicion that most of you have already identified the component pieces identified above in your own efforts. That’s not to say that there aren’t improvement opportunities relative to workplace violence (as there likely always will be), but I do think we’ve made some pretty decent strides in this regard over the past few years. There was a time when the incidence rate was sufficiently concentrated to certain healthcare environments (cities, urban areas, etc.), but, and this is probably the toughest risk element to truly manage, it appears that workplace violence can happen at any time, anywhere. In some ways, it reminds me of the early days of the Bloodborne Pathogens standard and Universal Precautions; it was frequently a struggle for safety and infection control folks to sufficiently encourage good behaviors (and lord knows hand washing can still be a struggle), but much of what was initially viewed as foreign, inconvenient, etc. has finally been (something close to) hardwired into behaviors.

Again, I’m not convinced that this revisitation of covered territory helps anything more than increasing the risks of getting hammered during a survey if you can’t specifically identify how your program reflects their expert advice, but maybe it will help to gently remind organizational leaders that this one’s not going to go away.

And you may find yourself in another part of the survey process (more HazMat fun)

And you may ask yourself, well, how did I get here?

As is sometimes the case, I like to respond to questions from the “studio” audience and last week I received a question from the field that I think is worth a few inches of verbiage here. The question, as luck would have it, relates to the ascendancy of EC.02.02.01 (with 63% of the hospitals being surveyed taking hits), the management of hazardous materials and wastes.

While it may seem a little incongruous, with a side order of daunting, I think that the primary reason for the ascendance of EC.02.02.01 is that there are any number of things that can generate findings, particularly from the clinical surveyors (not that the LS surveyor couldn’t find stuff, but from what I’ve seen in recent survey reports, a lot of the HazMat findings are being generated during “regular” tracers). So, in no particular order:

  • emergency eyewash equipment (availability/accessibility/documentation of testing & maintenance)
  • availability and use of personal protective equipment (PPE) in accordance with product Safety Data Sheets (SDS)
  • management of hazardous energy sources, particularly as it relates to managing lead PPE;
  • labeling of secondary containers
  • management of hazardous gases and vapors (particularly as a function of ventilation, but also monitoring if you happen to have folks still using glutaraldehyde and/or cadmium-based products)
  • ensuring appropriate staff education is in place, particularly Department of Transportation education for staff signing manifests
  • with the odd issue relating to staff being able to competently access SDS

We’ve certainly spent our fair share of time talking about eyewash equipment (surveyors are as prone to over-interpretation as anyone, so you better have a clearly articulated risk assessment in your back pocket), and, interestingly enough, on May 31 (my birthday!), the folks at HCPro are hosting a webinar on the evergreen topic of eyewash stations, so you may want to give that look-see (listen-hear?).

I think the stuff surveyors are kicking folks on is pretty straightforward. I mean, just think about unlabeled or inappropriately labeled secondary containers—what’s the likelihood that you’ve got one out there somewhere in your organization? An unlabeled spray bottle; a biohazard container for which the label was washed off—lots of opportunities for the process to come up short.

At any rate, the list above is representative of what I’ve seen (in consulting practice and in actual survey reports). Anybody have any other potential findings that they’ve seen?

Inadvertent inundations: Oh, what fun! 2017 most frequently stubbed toes during survey!

As luck would have it, the latest (April 2018) edition of Perspectives landed on the door step the other day (it’s really tough to pull off the home delivery option now that it is an all-electronic publication) and included therein is not a ton of EC/LS/EM content unless you count (which, of course, we do) the listings of the most frequently cited standards during the 2017 survey season. And, to the continued surprise of absolutely no one that is paying attention, conditions and practices related to the physical environment occupy all 10 of the top spots (I remain firm in my “counting” IC.02.02.01 as a physical environment standard—it’s the intersection of IC and the environment and always will be IMHO).

While there are certainly no surprises as to how this list sorts itself out (though I am a little curious/concerned about the rise of fire alarm and suppression system inspection, testing & maintenance documentation rising to the top spot—makes me wonder what little code-geeky infraction brought on by the adoption of the updated Life Safety Code® and other applicable NFPA standards has been the culprit—maybe some of it is related to annual door inspection activities cited before CMS extended the initial compliance due date), it clearly signals that the surveying of the physical environment is going to be a significant focus for the survey process until such time as it starts to decline in “fruit-bearing.” I do wish that there was a way to figure out for sure which of the findings are coming via the LS survey or during those pesky patient tracer activities (documentation is almost certainly the LS surveyor and I’d wager that a lot of the safe, functional environment findings are coming from tracers), but I guess that’s a data set just beyond our grasp. For those of you interested in how things “fell,” let’s do the numbers (cue: Stormy Weather):

  • #1 with an 86% finding rate – documentation of fire alarm and suppression systems
  • #2 with a 73% finding rate – managing utility systems risks
  • #3 with a 72% finding rate – maintenance of smoke and other lesser barrier elements
  • #4 with a 72% finding rate – risk of infections associated with equipment and supplies
  • #5 with a 70% finding rate – safe, functional environment
  • #6 with a 66% finding rate – maintenance of fire and other greater barrier elements
  • #7 with a 63% finding rate – hazardous materials risk stuff
  • #8 with a 62% finding rate – integrity of egress
  • #9 with a 62% finding rate – inspection, testing & maintenance of utility systems equipment
  • #10 with a 59% finding rate – inspection, testing & maintenance of medical gas & vacuum systems equipment

Again, I can’t imagine that you folks are at all surprised by this, so I guess my question for you all would be this: Does this make you think about changing your organization’s preparation activities or are you comfortable with giving up a few “small” findings and avoiding anything that would get you into big trouble? I don’t know that I’ve heard of any recent surveys in which there were zero findings in the environment (if so, congratulations! And perhaps most importantly: What’s your secret?), so it does look like this is going to be the list for the next little while.

The mystery of the disappearing EP and other tales

I have no way to be certain of the numbers, but I do know of at least one organization that fell victim in 2017 to an Element of Performance (EP) that has since gone “missing.” Once upon a time, EC.02.05.03 (having a reliable emergency electrical source) had an EP (#10, to be precise) that, among other things, required hospital emergency power systems (EPS) to have a remote manual stop station (with an identifying label, natch!) to prevent inadvertent or unintentional operation. (I’m not really sure how a big ol’ stop button that’s labeled would prevent somebody from inadvertently operating the emergency power system; it would surely help if the inadvertent operation happened, but prevention…)

So, to follow this back to the applicable NFPA citation NFPA 110-2010 5.6.5.6, we find “(a)ll installations shall have a remote manual stop station of a type to prevent inadvertent or unintended operation located outside the room housing the prime mover, where so installed, or elsewhere on the premises where the prime mover is located outside the building.” The Explanatory Material goes on to indicate that “(f)or systems located outdoors, the manual shutdown should be located external to the weatherproof enclosure and appropriately identified.” So, that all seems pretty straightforward, don’t you think.

Well, recently (last week) I was working with a hospital that had not bumped into EC.02.05.03, EP 10 and, since I had not yet committed the standard and EP numbers to memory (every time things get changed, I swear to myself that I will not memorize the numbers, but somehow it always ends up happening…), we went to look at the online portal to the standards. And we looked, and looked, and looked some more, and could not find the EP for the remote manual stop. I just figured that I had sufficiently misremembered where this EP, so my plan was to look at survey reports that I know included RFIs for not having the remote manual stops and go from there. So, I looked it up in the survey report, checked the online portal and, guess what? No more EP 10 (in the interest of the complete picture, this EP also requires emergency lighting within 10 seconds at emergency generator locations and a remote annunciator (powered by storage battery) located outside the emergency power system location). Now, from a strict compliance standpoint, as the 2010 edition of NFPA 110 is the applicable code edition based on adoption of the 2012 Life Safety Code® (and I did check the 2013 and 2016 editions, each of which contain the same requirements), I can only guess that the requirements contained in EP 10 are still actionable if your (or anybody else’s) AHJ sees fit to cite a deficiency in this regard, so it’s probably worth keeping a half an eye out for further developments if you have not yet gotten around to installing the lighting, remote stop, and annunciators for your emergency power system equipment locations.

Also, just to alert you to (yet) another offering from ECRI, this past week saw the unveiling of the Top 10 Patient Safety Concerns (download the white paper here). There are a few items on the list that should be of interest to you folks (in bold):

  1. Diagnostic errors
  2. Opioid safety across the continuum of care
  3. Care coordination within a setting
  4. Workarounds
  5. Incorporating health IT into patient safety programs
  6. Management of behavioral health needs in acute care settings
  7. All-hazards emergency preparedness
  8. Device cleaning, disinfection, and sterilization
  9. Patient engagement and health literacy
  10. Leadership engagement in patient safety

I haven’t delved too much into the latest emergency preparedness stuff (ECRI’s take, as well as the Johns Hopkins report), but I’ve queued that up on my reading list for this week, just as soon as I dig out from our most recent wintry spectacular—currently raging outside my window, so I’m going to send this on its way before the power gets too dodgy…