RSSAll Entries in the "Uncategorized" Category

Panic in Detroit – Panic at the Disco – Panic at the Surgery Center…Fire in the Hole!

I’m presuming (and please don’t attempt to disabuse me of this notion) that you are all dutifully conducting security risk assessments on a regular basis. As you conduct them, I’m sure you find risks of some events that are greater than some other areas. So, I to ask: When you’ve completed your security risk assessment, do you identify specific strategies, including the use of technology, for minimizing those risks to the extent possible? If you’re not including that facet in the risk assessment process, you might want to consider doing so.

Recently, I was looking at a survey report in which an ambulatory surgery center was cited during a TJC survey because they had not installed a panic alarm “at the registrar’s desk in order to obtain immediate assistance in an emergent or hostile situation.” Now, as with so many things that have been popping up during surveys, I don’t disagree with the concept of having panic alarms at those customer service/interaction points where unhappy folks (or folks of any ilk) can experience the need to vent their frustrations, etc. But in that disagreement, I think I’d first be looking at what tools have been provided to staff to actively manage, if not de-escalate, these negative encounters. I would much prefer to avoid having to use a panic alarm by appropriately managing the encounter, much like I would just as soon not “need” to have an emergency eyewash station.

I’m a great believer in the proactive management of risk, but I’m also a great believer in implementing risk management and response strategies that make operational sense. So, the question to the studio audience is: Where have you installed panic alarms and where have you not installed panic alarms, and why? There’s always the risk that some surveyor will disagree with your strategy, but if that strategy was derived through thoughtful analysis of the involved risks, does that not meet the intent of all this?

I like the concept of best practice as much as anyone, but I also recognize that there is a tremendous amount of variability in the safety landscape. Just because something works in one place does not necessarily mean that it will work in all cases—that’s the mystical, magical, and ultimately mythical power of the panacea. One size doesn’t fit all—never has, never will. But if we’re going to be held to that type of an expectation, how does that help anyone? Ok, jumping down from soapbox for now, but rest assured, you’ll see me back up here before too long.

She’s a laughing, giggling whirly bird – oh heli!

Interesting development on the survey front in the last couple of weeks. I’m not at all sure what it means, but I thought I would share it with you all, make of it what you will.

During a recent survey in the Sunshine State, a hospital was cited for not having the “recommended (maximum) rotor circumference signage on the pad nor the other recommended signs that are recommended by the FAA” (signs such as “MRI in use,” etc.). Now we could certainly have a good time parsing the whole “recommended signs that are recommended” phraseology, but I keep coming back to that word “recommended.”   How far do we have to go to ensure that we have somehow accounted for every recommendation for every possible risk that we might encounter?. Yeah, beats me, too, but in the interest of furthering the applicable knowledge base, let’s step to the web for some edification:

First I draw your attention to the Advisory Circular issued by the FAA back in 2004. I can’t seem to lay my mitts on anything more contemporary than this, but if you find something more recent, please share.

Now, as we scan the first page of this most comprehensive document, we see a little statement that I think makes the TJC survey citation a little more squishy than I would prefer: “This AC is not mandatory and does not constitute a regulation except when Federal funds are specifically dedicated for heliport construction. “ To me, “not mandatory” sounds like a really big case of the “we don’t have to’s,”  what do you think?

Turning to Chapter 4, Hospital Heliports (this is on page 95 of the document), I will freely admit that there’s a lot of interesting/cool information. (Did you know that the FAA recommends Portland Cement Concrete for ground level facilities—who knew? Do you have Portland Cement Concrete for your ground level facilities? I certainly hope so). Anyway, the chapter describes a lot of important stuff about hazards and markings, including MRI impact, etc.

I’m going to guess that you’ve been having helicopters fly in and out of your airspace on a regular basis, and in all likelihood, some of you are already up to speed on this.  For those of you for whom this might be virgin territory, my advice would be to consult with the folks actually doing the flying and find out what they want to see with your helicopter setup. This would constitute what I euphemistically refer to as a risk assessment. You may have encountered that term once or twice here in Mac’s Safety Space. I can’t imagine that you’d not have heard by now if the pilots using your pad have issues. (I’ve never found them to be shy about safety—nor should they be.) Still, it’s never a bad idea to reach out periodically to make sure that everything is both hunky and dory; it’s really the least we can do.

AHAP Conference opportunities

The Association for Healthcare Accreditation Professionals (AHAP) is hosting its 6th Annual Conference May 10, 2012 – May 11, 2012 in Orlando, FL. It offers so many amazing opportunities to save money, get expert advice, and show off your hospital a bit. I should also note that if you’re one of the first 50 paid registrants you’ll receive a free full-day ticket to any Walt Disney World® Theme Park*! Download the online brochure to learn more.

So what is it and why am I talking about it? The 6th Annual AHAP Conference brings together survey professionals from across the country to discuss solutions and best practices to achieve continual survey readiness and compliance with ever-changing standards and regulations.

What are the opportunities?

  •  Accreditation Specialist Boot Camp.
  • Presentation of the first annual Accreditation Professional of the Year award
  • Unique roundtable discussion with representatives from HFAP, DNV, the American Heart Association, and The Joint Commission
  • Exciting new poster event featuring research and best practices from your peers. Find out how to submit a poster and save 50% on your registration.
  • Learn about:
    • Regulatory changes in 2012 and top RFIs: Staying ahead of The Joint Commission and CMS
    • What accreditation professionals need to know about Life Safety Code®
    • To certify or not to certify? Seeking The Joint Commission disease-specific certifications
    • Making the switch from The Joint Commission to DNV: One hospital’s experience with both surveys
    • Understanding tracer methodology and the survey process
    • A practical approach to policy management
    • Suicide Risk: Solutions to rapid assessment, Environment of Care, and documentation issues
    • Understanding hospital recognition programs for optimal cardiovascular and stroke care

Learn more.

*Offer ends March 8th.

Manufacturer recommendations?!? We don’t need no stinkin’ manufacturer recommendations…

As you’re no doubt aware, there is some movement afoot relative to the inclusion (or exclusion, depending on your preference and organizational experience) of the risk assessment concept when it comes to the establishment of preventative maintenance frequencies for medical equipment. The Joint Commission has historically encouraged the use of data and past performance to provide a backdrop for the most efficient utilization of clinical engineering resources. However, CMS has been pretty adamant and absolute in their preference for manufacturer recommendations for PM frequencies to be the “be all, end all” source for determining such things.

As we take on the next in our informal series—CMS – what up with them?—we bounce once again to the web–

Click here.

–and find that, lo and behold, there has been some relaxation in terms of scheduled PM frequency. The caveat, at least for the moment, is that although we can judiciously schedule preventative maintenance activities to our heart’s content, we’d best not stray from the manufacturer recommendations for what those activities will include.

Now, off the top of my head, I can’t think of too many instances in which you would modify manufacturer recommendations for such activities, but maybe you can. I’m not sure how effective this will be; my gut says it helps in the long run; the fundamental change is toward a more flexible planning (they’d have been looking for us to follow manufacturer recommendations for the PM activities anyways, so this is really nothing new as near as I can tell – please feel free to disabuse me of that notion).

What say all you clinical engineers out there?

You’ve got a new favorite…

Generally speaking, we in Safety Land don’t get too involved with Centers for Medicare & Medicaid Services (CMS) doings until they show up on our doorstep. But sometimes, the Feds weigh in on matters that can have far-ranging implications for safety operations. I think we need go back no further than the turn of 2010 to 2011, when it looked as if CMS was going to turn the whole world into a healthcare occupancy. Fortunately, through the good graces and advocacy of ASHE, that’s a bullet dodged. Bravo.

At any rate, there is a means of tracking interpretations, utterances, and the like—and it’s web-based (your tax dollars actually at work):

https://www.cms.gov/SurveyCertificationGenInfo/PMSR/list.asp

Basically, this site is a repository of all sort of what we might euphemistically characterize as “CMS Survey and Certification memoranda, guidance, clarifications and instructions to State Survey Agencies and CMS Regional Offices.” (Okay, not my characterization; it’s what CMS calls this stuff.) Certainly not everything found here is germane to safety and the environment, but it is searchable. (I couldn’t offer an opinion yet on how efficient the search capacity might be; to be determined.) The information could be considered a—if not the—final word on what’s happening at the ol’ Centers for Medicare & Medicaid Services. I don’t know that you would need to check it every day (and I can’t quite find a means of signing up for e-mail notifications of new postings), but probably worthy of a drop in from time to time.

And I’ll return to claim your hand – as the King of California

I generally don’t single out any of the myriad potential demographics of this portion of the blogosphere, but the Joint Commission’s January 2012 Perspectives, has singled out of you good folks keeping the safety faith out in California, based on some state-level legislation promulgated back in 2010.

The focus of the legislation is those folks engaged in CT scanning activities, which I’m going to guess includes just about everyone (the standard applies to ambulatory, critical access, and hospital accreditation). I don’t see this as a particular nuisance for folks. I believe that everyone with a compliant radiation control program is on top of this, but if you’re not—even if outside of California—this new element of performance (EP) might be worthy of consideration moving forward.

EP #17 (an “A” EP) under EC.02.04.03 requires at least an annual measurement of the actual radiation dose produced by each CT imaging system, and further requires that the radiation dose displayed on the system is within 20% of the actual amount of radiation dose measured. Naturally, the dates of these verifications would be documented (and, by extension, made available during survey.)

(We’ll be chatting more about what documents and documentation could be considered “reviewable” during survey—it’s a long list.

Now, a 20% margin is a pretty wide range, I would say. In fact, if there’s anyone out there in Cali who’d care to weigh in, would you mind speaking to how you’re managing this process and what your experiences have been? I’m going to guess the 20% tag is fairly attainable on a regular basis, but maybe not. It’s not really something that I’ve focused on in the past. It does seem that legislation on the coasts tends to ripple across the compliance landscape, so maybe a future concern is best dealt with now.

At any rate, if you have stories to share, by all means, please include us.

In your eyes – the light, the heat … the chemicals?

A couple of weeks ago, a client was asking me about who should be performing the weekly checks of eyewash stations. A clinical surveyor consultant had given them the impression that this should be the responsibility of maintenance staff. Now, I’m not sure if this direction was framed as a “must” or a “would be a good idea,” but what I can tell you is that there is no specific regulatory guidance in any direction on this topic. I do, however, have a fairly succinct opinion on the topic—yeah, I know you’re surprised to hear that!—which I will now share with you.

Certainly we want to establish a process to ensure the checks will be done when they need to be done. I agree that maintenance folks are typically more diligent when it comes to such routine activities than clinical folks often are. However, from an end-user education standpoint, I think it is way more valuable for the folks who may have to use the device in the area to actually practice its operation. If they do have a splash exposure, they would have a moderately increased familiarity with the location, proper operation, etc., of the device. Ideally, the eyewash will never have to be used because all our engineering controls and PPE will prevent that splash (strictly speaking, the eyewash is a last resort for when all our other safeguards have failed or otherwise broken down.

I’m also a believer (not quite like Neil Diamond, maybe more like Smashmouth) that providing for the safety of an organization is a shared responsibility. Sure, we have folks who call ourselves safety professionals help guide the way. But real safety lives at the point of care/point of service, where everyone works. So it’s only appropriate that each one of us take a piece of the action.

Now be thankful…

As we begin 2012, I am curious as to how folks fared with their EC programs last year (2011). Whether it be blessing, curse, reason to give thanks, reason to give up—never! – what worked for you, what didn’t work , and what do you feel comfortable sharing with the rest of the safety community?

From my experiences, I witnessed yet another year in which folks were charged with doing more with less. I have no sense that 2012 will be bringing any wealth of riches to hospital safety programs. Part of the problem is the safety community has once again proven itself as more than adept at finding a way to make things work, make sure folks are safe, and generally make sure the wheels don’t fall off the safety bus. So, to paraphrase that estimable sage, one P. Frampton: I want you to show me the way. The only unique thing about challenges is how we meet them. In the spirit of giving, I exhort you to share your wisdom with this community.

And in exchange? You would have my personal gratitude and my warmest wishes to you and your family for a most joyous New Year. (Hey, I’ve got a budget too…)

I need to know – the re-rise of glutaraldehyde-based disinfectant

One of the developments of the last few years that pleased me most was the move away from glutaraldehyde-based disinfectants to safer alternatives. But now—and I am at a loss to understand what is prompting this—I am seeing a resurgence in the use of the glutaraldehyde-based disinfectants. As we are more or less familiar, glutaraldehyde is a fairly complicated environmental hazard to manage (not the most complicated, but up there on the list), with requirements regarding monitoring of conditions, ventilation, etc. For the big picture, the following link will do nicely: www.osha.gov/Publications/glutaraldehyde.pdf

So what is pushing us back toward a, oh I don’t know, certainly a more hazardous material? You’ll get absolutely no argument from me when it comes to the importance of properly disinfecting reusable medical devices; the rate of hospital-acquired infections is so much greater than we as safety professionals can live with. I had heard of some instances in which devices like endoscopes were stained following disinfection using OPA-like products, but my understanding was that any discoloring on the surface of devices was residue of proteinaceous materials that weren’t completely removed during the pre-disinfection process. (You can’t really call it staining as these devices are generally impermeable, so if it can’t sink in, it can’t stain.) So, I ask you: What up with this? I want to be able to help folks move in the right direction, and I’m not convinced that moving back toward glutaraldehyde is the right direction. If you folks are privy to something that allows this to make sense, please share. It is, after all, the time of the season. Hope to hear from you soon.

A cup of coffee, a sandwich, and…the boss!

If you’ve not yet procured a copy of the November 2011 issue of The Joint Commission Perspectives, I would encourage you to do so. There is a very interesting article that focuses on a strategy for establishing more effective communication between the folks charged with managing the physical environment (that would be you) and hospital leadership.  Now I think this is a pretty cool idea, but I couldn’t say with any degree of certainty how widespread a success it might be as there are a number of variables involved (and that’s not counting personalities). That said, it’s certainly a strategy worth pursuing, if it doesn’t pursue you first.

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