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A wrench in emergency planning for behavioral health facilities

Joint Commission (formerly JCAHO) standard EC.4.12, EP 7, requires hospitals to identify alternative sites for care, treatment, or service that meet the needs of patients during an emergency.

Behavioral health facilities run into a complication in this regard, because their options are likely to be somewhat more limited than those of a “regular” hospital.

I recommend that behavioral health facilities consult with their state departments of public health to help identify those resources for which it would be appropriate and, perhaps most importantly, useful to reach out to as alternate care sites.

Chances are, there are other organizations in your region that are in the same situation. This definitely has a lot of potential for “in helping one, we help all.”

If weapons of mass destruction are among your true worries . . .

While terrorism involving weapons of mass destruction (WMD) is possible, the defining question for hospitals is this: Is a WMD attack among those things for which we can reasonably expect to respond?

For most organizations, that answer would be probably not (never say never).

That being said, if you really feel that development of a WMD response plan for your organization is an appropriate utilization of resources, then my recommendation would be to start with your radiological and chemical exposure plans and build a terrorist scenario option into those plans.

The broader advice is to develop tight, functional, basic response plans and then weave in any nuances you might encounter.

You want this response plan to be as close to a “no-brainer” for staff members as you can possibly make it. If they know their first step is to take out the chemical exposure plan in the event of a WMD incident, that will get you the most consistent, appropriate response.

A quick reminder about our Hospital Safety Symposium

I’ve been working on my slide presentations for the Second Annual Hospital Safety Symposium, so our upcoming show has been on my mind.

I hope to see many of you at the symposium, which will return to Las Vegas on May 8-9. During my sessions, I’ll be discussing risk assessments, clarifying EC survey citations, and what’s on the horizon for the EC standards in 2009.

You can click this link for our full agenda and registration info.

A federal emergency prep link to click

When developing or reviewing your emergency operations plan, it might not be a bad idea to come up with something that dovetails with the FEMA’s Homeland Security Exercise and Evaluation Program, which apparently represents a national standard for conducting emergency response exercises.

I can’t recall having run across this before in my travels (props to Steve Shea at Winchester Hospital in Winchester, MA, for bringing this to my attention), but it looks like a serious matter. It appears to tie in with eligibility for grant monies, etc., so it would seem that this is going to be, in my words, a big deal.

There’s a bunch of stuff through the link above, so run wild.

Reducing alarm decibel levels, NFPA 72 style

I was chatting with someone about the decibel level that fire alarms must be set at, and I thought, “Hey, a nice blog idea.”

The National Fire Alarm Code (NFPA 72) requires fire alarms to have an output (i.e., sound level) at least 15 decibels above the average ambient sound level or 5 decibels above the maximum sound level having a duration of at least 60 seconds, whichever is greater. You measure this decibel level 5 ft above the floor in the occupied area.

That said, NFPA 72 does say that audible signaling volume can be reduced, or in some cases, eliminated, when:

  • Approved by the AHJ (generally the local fire department)
  • Visible signaling is in place

If a fire alarm horn is so loud that the PA announcement can’t be heard, I would consider that an improvement opportunity and time to call the fire inspector.

PAPRs, TB fit-testing, and your take

Now that OSHA can enforce annual fit-testing provisions for TB respirators, there’s been a lot of talk about increased use of PAPRs, which don’t require fit-testing because of their design.

But here’s one disadvantage of PAPRs: From a sensitivity to patients standpoint, I think in an emergency, “hooding up” to deal with patients might fly for a bit, but I think ultimately the “comfort level” for patients in isolation will be strained if there’s too much care in the hood.

Imagine if you’re a patient and every time the nurses come in, they have full hoods on-it’s not a cozy image.

Have you considered a more pervasive use of PAPRs to ensure appropriate levels of protection?

Looking for someone who recently posted a TB comment to this blog

Hi everyone, it’s Scott Wallask at HCPro checking in.

I’ve got a quick question: We got a comment posted to Steve Mac’s item about TB fit-testing last week, and the comment from our end appears to be plagued by a software bug. We can’t tell who it was who posted the comment.

If you posted to the blog about the TB fit-testing requirement, could you email me privately?

It’s a problem more on our end, we’re not trying to bust anyone’s chops.


Scott W.

Speaking of EC.4.12 and the 96-hour rule . . .

My advice to clients has been to go through their hazard vulnerability analysis and identify those events that, either by themselves or in sequence, could result in community support and resources being inaccessible for a period of up to 96 hours.

Now my firm belief is that there are really very few events that would result in “isolation” of this magnitude, and if you know what those events would look like during incipient stages, you could probably take additional actions to mitigate that potential for isolation.

Additionally, I’ve also advised folks that once they have identified the cadre of events that meet the 96-hour mark, to further identify:

  • Those events are likely to immediately result in that level of isolation
  • Those events for which a period of time would pass before isolation sets in

Based on those deliberations, I tell folks to focus their planning activities accordingly.

What have you done to prepare for the 96-hour rule? Click the comments link below and let me know.

No plans for quick sand, meteors, or coffee running out

I have become rather reluctant, over time, to recommend that organizations develop too many event-specific disaster plans.

My best consultative advice is to focus on adoption and integration of an all-hazards approach to incident command (most folks seem to be going the HICS IV route). An adequately functional incident command process for your organization will serve you much better in the long run, as it is applicable regardless of the type of event.

Remember, the purpose, if you will, of an incident command structure is that you can respond appropriately to whatever emergency comes down the pike, regardless of its nature.

What are your thoughts about the costs of annual TB fit-testing?

So I see that OSHA–thanks to President Bush signing off on the federal budget–now has the ability to enforce its annual fit-testing requirements for tuberculosis (TB).

This one is going to have some hidden costs. The fact of the matter is, compliance even with initial fit-testing is certainly (based on my observations) inconsistent at best, so some folks are going to have to come at annual fit-testing basically from ground zero.

At any rate, it seems to me that somewhere in the regulatory language (maybe in the post-TB standard stuff) there was some sort of cost estimate that was fairly minimal. And, as I think about it, this isn’t even getting into the issue of fit-testing staff members who are going to be using PAPRs in the event of a decon event.

It’ll be interesting to see if OSHA actually goes after this with any gusto–could get ugly.

What do you think? Is this a big deal? You can click on the comment links below to post your thoughts.