A number of states have passed (or are in the process of passing) laws legalizing the use of medical marijuana. Now, I don’t really have a dog in this fight as far as it goes, but I do think it may present some challenges for security professionals in hospitals as to how best to manage cannabis as a personal possession. What was once a fairly straightforward “it’s not legal” situation could now become rather a point of contention when someone wants to know what happened to their prescription pot (I’m thinking that this could bring a whole new meaning to medication reconciliation…).
At any rate, to those of you in the studio audience who are in (various) states of legalized marijuana: How are you managing this as a potential customer interaction? How have you managed this type of contraband in the past and how are you going to manage it in the future? Back in the day, confiscated pot could be turned over to the local police; are they even interested anymore? The DEA still classifies medical marijuana as a Schedule I substance and I suspect that there are any number of hospitals that are licensed only for Schedules II-V, so your pharmacy director may have some insight into a way forward. At any rate, if anybody out there has actually been able to come to grips with this issue, I would love to hear what you’ve got going.
Apropos of nothing, on the face of it, I wanted to share with you a cautionary tale relative to the importance of accurate (and complete) communications, particularly in those perilous moments when you have a less than satisfied customer. As you might guess, I travel by air a fair amount of the time (and no, this isn’t a beef about delays. I count myself pretty fortunate in that regard. Delays are an inevitable function of any commute, doesn’t matter what mode, but I digress) and, without getting into too much detail, a process that had always worked in the past suddenly did not “go” the way I expected/had experienced literally tens, if not hundreds, of times in the past.
The initial encounter with the airline folks did not yield much in the way of satisfaction; in fact, I don’t think I would be hyperbolic in describing the handling of that interaction as bordering on indifferent. I try to keep an even keel in such matters, but I will tell you that I was a wee bit frustrated. I also knew that there was a process for airing my concerns, so I elected to save it for another day.
At this point (and yes there is a point to all this and I’m almost there), I had a pretty good idea of what was going on (clearly, at least in my mind, it was a systems issue and one part of the system wasn’t communicating very effectively with another part of the system), so I contacted customer service and explained my plight. The person I spoke with was very empathetic and offered a solution that she guaranteed would resolve the issue; I came away with a very positive feeling, but guess what? The solution didn’t work. There were a few more back and forths with a few more ideas/solutions, but nothing that really addressed what I was convinced was the issue. The customer service folks promised to investigate and let me know.
Well, it turns out that it was a systems issue and at least some folks at the airline knew of its existence and had been working on it for a couple of weeks. They weren’t sure when the issue would be resolved, but I was okay with that—because I now knew what was going on. The “problem,” as I now see it, is that the folks who knew there was a problem and what the “symptoms” of the problem were, didn’t let everyone in the customer service process know what was going on. There is nothing more effective in answering someone’s questions than being able to speak directly to the issue—even if the resolution is not immediate.
How many times in our work lives have we been less than proactive in providing everyone in the process a complete picture of what’s going on? Inevitably, one can look back and figure out exactly when full disclosure fell by the wayside and frequently results in hard feelings, etc. It all kind of dovetails back to the mantra of “if you see something, say something,” though in this case, it’s more along the lines of “if you know something, say something.” While one may not intend to be secretive, sometimes it’s tough to defend “compartmentalization” or whatever euphemism you might adopt. When it comes to safety, the more everyone knows, the more effectively risk can be managed.
I’m reasonably certain that we’ve dealt with this before, but there’s been a wee bit of a bump in survey findings relative to the practical assessment of PFI’s as a function of Interim Life Safety Measures.
It’s really quite simple, when you come right down to it. The Joint Commission standards require us to assess for Interim Life Safety Measures, based on the criteria in our policy, any Life Safety Code® (LSC) deficiencies that cannot be immediately corrected (BTW – it’s a good idea to define immediately in your policy – the standard holds no specific definition, so it’s a bit of self-determination – but don’t go crazy trying to define immediately as something much more than the end of the shift/end of the day). Okay, that’s a pretty solid LSC deficiency that we can’t fix right away.
So, the next question in this little chain is this – what is the defining characteristic of a PFI? Why, it’s a Life Safety Code deficiency that is going to take some time to resolve (something very much less than immediately)! So, as a simple quid pro quo arrangement (or equation, if you like), we have:
PFI = ILSM Assessment
Where you have the first, you must also have the second, otherwise you could find yourself staring down the barrel of a Situational Decision and potential Joint Commission re-survey. Is there anyone in the studio and broadcast audience that has any desire to endure that fate?
I didn’t think so – so, make sure you have ILSM assessments for each of your PFI’s and you will avoid this particular world of hurt. You should go check right now…
Another contractor-related “impression” that’s surfaced lately (and this is not just in hospitals – this can be in your own backyard) is that fascinating phenomenon of the contractors that show up not exactly when you were expecting them and before you got a chance to let your neighbors know that there will be a project going on.
Admittedly, this (hopefully) doesn’t happen too often in healthcare (it better not, at any rate), but I still run across instances when clinical and other staff in areas adjacent to construction/renovation projects feel that they haven’t received much in the way of effective communication prior to the onset of the crash, bang, boom.
Now I know sometimes this is a little bit of the “it’s easier to get forgiveness than it is to get permission” concept (and yes, I also understand that that is a frequent mantra when it comes to taped-over door latches, door wedges, and other sins upon the life safety components of the building), but it’s not like the work isn’t going to happen, so the bestest thing you can do is to reach out to the neighbors to enlist their advocacy on your behalf. Face it, there’s going to be commotion that’s going to reach the eyes/ears/noses of everyone in adjacent spaces – including patients (the reason we are here, n’est-ce pas?)
If we can get the folks managing care to act as advocates for our sawing and drilling and dropping stuff and (quietly) swearing and playing the radio, etc., then (as with so many things) patients might not feel as inclined to provide negative feedback (no guarantees, but it certainly increases the chances of heading a complaint off at the pass).
One of the truisms of modern healthcare is that we cannot communicate enough, but if we keep everyone in the loop, the likelihood of a successful, complaint-free project increases quite a bit (I was tempted to use the exponential qualifier here, but you don’t need me to go all hyperbolic on you at this late date). So, start talkin’!
In recent months, I’ve encountered a couple of instances in which some contractors doing various and sundry projects for hospitals did something (what follows is merely my opinion) incredibly boneheaded – namely leaving roof access doors unsecured and unmonitored.
I’ve also encountered some instances in which contractors had gone to lunch (yes – they really were out to lunch!) and left their “work” unattended on a patient care unit (thankfully not a behavioral health unit, but still) – electrical closets open/unsecured, open ceilings, the whole gamut.
Now, one of my favorite observations is that the human race has an enormous capacity for doing stupid stuff (insert whatever relevant current event you think might be apropos evidence of such a sweeping generalization). And while we generally have pretty good controls over the folks who are working for us (that still doesn’t mean nothing will happen, but that measure of control can really pay dividends over time), but—and this seems to be on the increase—when we bring in folks from the outside (nominally because we are a wee bit under-resourced on the home front), we have to relinquish at least some of that control.
So I ask: When it comes to orienting contractor staff, on what topics do you focus? Do you make a general “don’t do anything stupid” statement as well as more specific concerns? I sometimes think that contractors forget about the complexities of providing a safe environment for patients. I honestly don’t think it’s a lack of capacity on anyone’s part, but in the heat of the battle, so to speak, and we’re charging towards a project completion date, etc., sometimes…
Anyone out there want to share any interesting examples of close calls / near misses, or even a sense of what you’ve done/learned to keep things on an even keel during construction/renovation projects involving external contractors? I know I’m not alone on this one – how about a little sharing?
Just a quick little list of recent survey findings – not necessarily having anything to do with the Top 20 most frequently cited standards. That said, I do think that this provides ample indication that the survey process is intent on identifying any EC/LS/EM deficiency that could be lurking in the furthest (farthest?) regions of your facility. So, how about:
Have you included (those of you who have them) lightning protection systems in your Utility Management inventory – or completed a risk assessment that indicates inclusion in the inventory is not appropriate?
Do you still maintain (at least) one hard copy of your organization’s Material Safety Data Sheets? If not, what’s your backup and how do you know it’s effective?
What about those rooftop exhausts for isolation rooms—have they been labeled? The biohazard symbol on your rooftop exhausts (or any isolation exhausts) makes quite a statement – and never goes out of style.
What about those flexible and rigid endoscopes? Have you included them in your medical equipment inventory or completed a risk assessment that indicates inclusion in the inventory is not appropriate?
How about those electrical receptacles in locations within 6 feet of sinks and other water sources—are they on GFCI protection? Could be the outlet, could be at the panel, but you need to know, ‘cause if you don’t…
Those of you who are performing manual disinfection of patient care devices / instruments, most frequently using an OPA product: Have you evaluated the process as a function of what is actually required by the manufacturer? This is a very complicated process (with lots of steps to go awry) and perfection is not merely the goal, it must be attained at every step, every time. Perfect, perfect, perfect…
What about those open floor plan areas (frequently ED’s, ICU’s, PACU’s, OR’s) where staff have all manner of equipment and stuff parked outside the rooms (hopefully not obstructing access to the zone shutoff valves) – have you officially designated those areas as suites, and updated the life safety drawings to reflect that designation? If you haven’t, that’s a survey slam dunk for an RFI – better get on it!
I know we’ve spoken of this in the past (or at least I think we have), you have to pay very close attention to the ins and outs of LS.02.01.30 EP #2, which has to deal with combustible storage areas greater than 50 square feet in area. (Storage room = door that self or auto-closes and latches.) And if there’s a “former” patient room (including procedure rooms in the OR, etc.) that’s been converted to storage (particularly if the conversion occurred after March, 2003), then you are looking at the requirements for “new” healthcare, which means sprinklers, one-hour walls, with a 45 minute fire-rated door. I know folks are trying to minimize corridor clutter, but you get right into a whole ‘nother pickle if you don’t watch for these kinds of transformations.
Anything ring any bells for anyone? Might be worth a little mental checklist to make sure you’ve got these areas covered.
In reviewing “stuff” from the past few months (September and October were pretty busy on the regulatory front), I wanted to mention (in case this hadn’t crossed your path) the Government Accountability Office’s (GAO) report on the security of radioactive materials in hospitals as a function of the Nuclear Regulatory Commission’s (NRC) existing requirements. The GAO found the NRC requirements to be somewhat lacking, based on a sample of 26 hospitals and medical facilities.
According to the highlights of the report (you can find the whole megillah at: www.gao.gov/products/GAO-12-925), the NRC did not agree or disagree with the findings of the report, feeling that existing security requirements are adequate. Some of the security lapses found during the GAO survey were such items as unsecured medical equipment containing radioactive material, unescorted access to radiological sources, even (darn it!) numerical keypad lock combinations inscribed on door frames.
Now I will tell you that this is all stuff I’ve encountered periodically during my consulting life (a boss of mine once told me “you can’t mandate intelligence”; then Ron White distilled that into “you can’t fix stupid”) and I will also tell you that sometimes all you can do is shake your head about this stuff. That said, I have no reason to think that the good folks at The Joint Commission (or indeed anybody else with a horse in the regulatory survey derby) are not abundantly aware of this report and it’s contents. So what follows is purely consultative in nature:
Read the report, look at the recommendations, perform a gap analysis at your facility, identify any improvement opportunities, present the risk assessment to your EOC committee and move forward. You may want to consider identifying the necessity for recurring review (which, natch, you should be doing as a function of your annual evaluation of the security management program), if you think you might lose track of this, but I think this should cover things quite nicely.
For those of you go-getters who’ve already run this race – what kind of stuff did you find? Any suggestions for the rest of the classes? Inquiring minds want to know!
Now I will be absolutely candid in telling you that there are some things that I pay attention to that are probably way beyond the pale when it comes to normalcy; I suspect that this is going to be one of those topics, but here goes.
In my travels, I observe a great many things and one of the things I follow most closely is the hand-washing habits of my fellow (male) travelers. One of my fondest wishes would be to have the power to surreptitiously identify those who do not wash their hands when completing their restroom activities–a silent but obvious j’accuse, if you will. And my conclusion is that way, way too many folks are not washing their hands enough, and in so doing (or not so doing), they are increasing the risk of infection to not only themselves, but the rest of us.
Now, I’ve ranted in the past about manually-activated faucets in combination with automatic hand dryers, and how the arrangement does not promote good hand hygiene (Yeah, I know you can use your elbow or some other appendage to turn off the faucet, but not all faucets are so easily turned off).
I want to have a paper towel to turn off the faucet, but even more importantly, I want a paper towel to be able to open the door– because I can’t trust that the people using the door before me washed their hands! As a corollary to that, I also like to have someplace to dispose of the paper towel once I’ve opened the door and I am very pleased to note that there is a marked improvement in the availability of waste containers right next to the door. As far as I’m concerned, it gives me hope (not a ton, but some) for humanity.
Now I know that there is a carbon footprint aspect to all this (and I try to be as green as I can be: as I write this, I’ve been lugging a trash bag full of recyclable plastic around New Mexico, hoping to find a recycling bin for plastic. I’m still looking.), but this may be one that we have to tolerate, at least for the time being. Viruses, etc. appear to be on the rise again, so I want to make sure that we all make it through this at least relatively unscathed. End of rant.
One topic upon which I’ve not weighed in is the proposed changes to The Joint Commission’s Emergency Management and Leadership standards to more clearly reflect the responsibility of organizational leadership to provide oversight of the Emergency Management function in both critical access hospitals and “regular” hospitals. (Details can be found here: http://tinyurl.com/buozat3)
The proposed changes have been open for comment since late October, but the field review process (which can – and hopefully has/will – include your thoughts and comments, boys and girls) is coming to a close (December 4, 2012 is the cutoff date) and I didn’t want you folks to miss out on the opportunity to shape the future (that’s probably a wee bit hyperbolic, but that’s me).
Now, to be completely honest with you, I hadn’t really looked too closely at the suggested changes, as much because I think there’s likely to be pushback from some folks to “soften” the language in the Leadership chapter regarding the anointing of an individual to be the “emergency manager” (that’s my euphemism). And after what happened in NYC post-Sandy, this could end up being a very interesting conversation.
I can’t honestly say that I disagree empirically with anything they’re proposing; they still seem convinced that hospital leaders will not take this stuff seriously (unless they are well and truly “on the hook”). I suspect that there’s going to be a lot of up-selling at individual hospitals that the changes mean that someone must be hired specifically to handle emergency management, which will, in turn, cause consternation among those in healthcare who count the beans, which will, in turn, result in TJC having to clarify what they mean.
But again, I don’t think that what they are suggesting is out in left field, or– to any great extent–unreasonable. I’ve been to any number of hospitals where the leadership oversight of the EM program is one “hat” among many, but not every healthcare organization is in the crosshairs of crazy levels of emergencies (part of me can’t escape the thought that Sandy, like Katrina, was an event above and beyond what they could normally expect to experience, based on past history), so there will always be some level of variability. In looking back at the last 18-24 months, we’ve had a lot of catastrophic events directly impacting hospitals. For whatever reason, hospitals had never really taken a direct hit from a tornado until last year; so, does what happened in Joplin last year change how you have to look at things, particularly in tornado country? Absolutely, but that’s how you have to manage risk – focus on what you know has happend/can happen, and then work on the rest of it as time permits.
At any rate, I would encourage any of you folks out there who have not taken advantage of the field review to weigh in and raise the conversation to an ever-more-thoughtful level. You folks, as I like to say, are living the dream– and your stories/challenges are invaluable to this process. Make yourselves heard, lads and lassies, make yourselves heard!
Continuing on our recap of survey adventures, we finish out the Top 10:
EC.02.06.01 – Establishment and maintenance of a safe, functional environment (#9, with 32% of hospitals having been cited)
A couple of somewhat disparate conditions are coalescing under this particular standard:
- Safety and suitability of interior spaces – this apparently is where the unsecured compressed gas cylinders are ending up when they are found during survey. Not necessarily the place I would have picked (I’d run with EC.02.01.01 EP #3 – minimization of safety risk in the environment), but I can see where it would fit;
- Management of ventilation, temperature and humidity in the care environment – this is one that will cause you so much heartache, it’s not funny. Temperature and humidity logs? You better have ‘em (and yes, I know that they are not specifically required in the regulatory verbiage, but that doesn’t mean a (insert descriptor of your choice) thing. Trust me on this, if on nothing else, ever!) Make sure that you have extremely reliable pressure relationships in every spot where you’ve got clean/soiled environments cheek-to-jowl; clean/sterile; sterile/soiled, etc. The air has got to flow from the good to the bad (euphemistically speaking), if it flows from the bad to the good, you are going to get lit up like a Roman candle during survey, likely resulting in a CMS visit to boot – none of us want that, none of us at all.
- Finally, and I don’t know that this got a whole lot of play in the official version, but there is a universal opportunity relative to cleanliness in the patient environment. There are some that I’ve seen who do a pretty good job, but I also know that I’ve not encountered anything close to perfect. If you have a surveyor with a mind to find dust, etc. somewhere in the patient environment, it will be found and it will be cited. Tell me the EVS folks aren’t shoveling against the tide sometimes…
EC.02.02.01 – Management of Hazardous Materials Risks (#10, with 29% of hospitals having been cited)
Lots of funky conditions can reside here, to name just a couple:
- Management of eyewash stations – weekly checks, temperature, obstructions, where they are installed, etc.
- Labeling secondary containers – if the chemical leaves its home vessel and is placed in another vessel, the second vessel (spray bottle, basin, sink) needs to have the hazard identified, unless the second vessel is absolutely attended until it is used/properly disposed – and even then, I’d do the label;
- Access to the Hot Lab in Nuclear Medicine – you’ve got to have a policy that makes sense about access, particularly for couriers delivering the materials – and remember, they’re already driving around with the stuff – if they want to swipe the stuff, they’ll just keep driving – so keep an eye on your stuff (George Carlin would want you to). That said, you should track down the July 2012 edition of Perspectives – there’s a lovely article on just this subject – can you say risk assessment? Thought so.
OK, we’ll do one more for this week, breaking into the next 10
EC.02.05.01 – Managing risks associated with Utility Systems (#11, with 28% of hospitals having been cited)
For those of you with older buildings and/or older utility system components, this one may keep you up at night. The sort of overarching way this is popping up during surveys (other than temperature, humidity, and ventilation, about which we’ve already spoken and will, no doubt, speak of again) is the inability of the system (whichever system it might happen to be) to achieve required results. Now, the sticking point here relates very much to what constitutes a “required result”. In case you hadn’t noticed, CMS is pretty much calling the shots when it comes to enforcement and, with increasing frequency, the practice of grandfathering older, lesser-performing systems is going by the wayside. If you (or someone you love) has a utility system that is not performing up to modern standards, then you had best get going on a risk assessment and identify mitigation strategies for appropriately managing the risks associated with the current performance level of the systems (and, perhaps, a plan for how you’re going to get to where you need to be).
The other condition that has been popping up is the identification, in writing, of inspection and maintenance activities (and the appropriate intervals) for all operating components of utility systems on the utility management inventory (which is, of course, populated through an arduous risk assessment process). It’s my understanding that continuous monitoring through the good graces of a building automation system is an acceptable means of compliance with this requirement, but if you don’t have a building automation system, you’d best be prepared to produce, in writing, the activities and intervals as noted above (a computerized work order system might work – but it has to be a pretty robust platform).
And so we’ve reached the end of yet another batch of fun facts and figures – next week, we’ll wrap it all up – until next year!