In their pursuit of continuing relevance in an ever-changing regulatory landscape, The Joint Commission announced what appears to be a fairly significant change in the survey reporting process. At first blush, it appears that this change is going to make the post-survey process a little simpler, recognizing that simplification of process sometimes ends up not being quite so simple. But as always, I will choose to remain optimistic until proven otherwise.
So the changes in the process as outlined in this week’s missive shake out into three categories: scoring methodology, post-survey follow-up activities, and submission time frames for Evidence of Standards Compliance (ESC). And I have to say that the changes are not only interesting, but appear to represent something of a shift in the framework for administering surveys. Relative to the scoring methodology, it appears that the intent is to do away with the “A” and “C” categories, as well as the designation of whether the performance element is a direct or indirect impact finding. The new process will revolve around a determination of whether a deficient practice or condition is likely to cause harm and, more or less, how frequently the deficient practice or condition is observed. As with so many things in the regulatory realm, this new methodology reduces to a kicky new acronym: SAFER (Survey Analysis For Evaluating Risk) and comes complete with a matrix upon which each deficiency will be placed. You can see the matrix in all its glory through the link above, but it’s basically a 3 x 3 grid with an x-axis of scope (frequency with which the deficiency was observed) and a y-axis of likelihood to result in harm. This new format should make for an interesting looking survey report, to say the least.
Relative to the post-survey follow-up activities, it appears that the section of the survey report (Opportunities for Improvement) that enumerates those single instances of non-compliance for “C” Elements of Performance will “no longer exist” (which makes sense if they are doing away with the “C” Element of Performance concept). While it is not explicitly noted, I’m going to go out on a limb here and guess that this means that the deficiencies formerly known as Opportunities for Improvement will be “reported” as Requirements for Improvement (or whatever RFIs become in the SAFER model), so we may be looking at having to respond to any and all deficiencies that are identified during the course of the survey. To take that thought a wee bit further, I’m thinking that this might also alter the process for clarifying findings post-survey. I don’t imagine for a moment that this is the last missive that TJC will issue on this topic, so I guess we’ll have to wait and see how things unfold.
As far as the ESC submission timeframes, with the departure of the direct and indirect designations for findings comes a “once size fits all” due date of 60 days (I’m glad it was a “45 days fits all” timeframe), so that makes things a little less complicated. But there is a notation that information regarding the sustainment of corrective actions will be required depending on where the findings fall on the matrix, which presumable means that deficiencies clustered in the lower left corner of the matrix (low probability of harm, infrequent occurrence) will drive a simple correction while findings in the upper right corner of the matrix will require a little more forethought and planning in regards to corrective actions.
The rollout timeframe outlined in the article indicates that psychiatric hospitals that use TJC for deemed status accreditation will start seeing the new format beginning June 6 (one month from this writing) and everyone else will start seeing the matrix in their accreditation survey reports starting in January 2017. I’m really curious to see how this is all going to pan out in relation to the survey of the physical environment. Based on past practices, I don’t know that (for the most part) the deficiencies identified in the EC/EM/LS part of the survey process wouldn’t mostly reside in that lower left quadrant, but I suppose this may result in focus on fewer specific elements (say, penetrations) and a more concerted approach to finding those types of deficiencies. But with the adoption of the 2012 Life Safety Code®, I guess this gives us something new to wait for…
Lots of information to cover this week, so let’s get started.
Effective July 1, 2016, there are a few EC performance elements that will be ushered into the archives; in looking at the provided information, which includes rationales for the removal of each EP: the decision-making process pretty much sorted out into four categories; 1) the EP is implicit in another EP in the standard; 2) the EP is duplicative of another EP in the standard; 3) the EP reflects an issue that should be left to the discretion of the organization, or, 4) the EP is considered part of regular operations and is reflected elsewhere in the standards. So that all seems pretty rational (which is a most excellent starting point for a rationale), but there have been instances in the past when the removal of an EP has ended up complicating compliance (the most prominent example being the removal of the EP requiring the triennial review of safety-related policies and procedures, which was “replaced” with the expectation that the annual evaluation process for each EC management plan would be inclusive of a review of policies and procedures), so this latest revelation may end up being something of the proverbial double-edged sword.
That said, I don’t see anything that I would consider particularly problematic: interventionary powers for immediate threats to life and/or health; managing the risks inherent with allowing patients to smoke; self-determination when it comes to soliciting input to aid the process for selecting and acquiring medical equipment; interim measures and re-testing of emergency power system components when there are failures; a little more flexibility regarding the practical administration of your improvement activities relative to EC. These all seem fairly benign. It does make me wonder if this is as much the result of these EPs not being surveyed to the same extent as other in the EC chapter, but wondering doesn’t necessarily get us very far. At any rate, if folks have some thoughts they’d care to share, I’m all ears!
Next up, we encounter our latest acronym PEP—short for Physical Environment Portal. As I noted to my friend and colleague Jay Kumar, there are many more rhyming opportunities for PEP than for portal, so I’m down with this.
This month’s update focuses on the some of the problematic aspects of LS.02.01.10, which mostly deals with the requirements revolving around your fire-rated barriers. Interestingly enough, it appears that the compliance gaps relate to managing rated doors and rated barrier walls (I’m sure you are all just as shocked as I am with that information). There are a couple of click-through links to Joint Commission Resources, which are basically reprints of some Clarification & Expectations columns from the June and July 2012 editions of EC News. I’m thinking you may already have those in hand, but if not, they are offered free of charge (you just have to register). The example of improved compliance is kind of interesting in a rather non-illuminative way, but that may just be me. So (and this may be a function of having to come up with compelling content every month), a not particularly peppy PEP this month, but what can you do?
As a final bit of info this week, I don’t know if you saw the marketing for the July Environment of Care Base Camp session, but I found it interesting that they’re really playing up the “you can’t get this information anywhere else” card, with a further indication that any other EC educational programs are based on findings from last year. Basically, they’re saying that if you pony up the dough, you can find out what the focus of the physical environment survey is this year (presumably based on the first few months of 2016), which sounds just a little bit extortionate to me. If memory serves, the purpose of the whole Physical Environment Portal was to provide healthcare facilities and safety professionals insight to the process and allow for more effective preparation, etc. Which I guess only serves to indicate that you get what you pay for…but should you have to pay for information regarding the expectations of regulatory inspectors/AHJs? It’s like having to go to a conference to have access to all this great content, etc., and no really useful way to determine if what you missed was of critical importance. I’m thinking that our budgetary focus would be more towards making operational improvements as opposed to spending time away at a conference, but perhaps I’m just a wee bit crazy…
Thanks to Jay Kumar for the “hep to PEP” line! See you next week…
As we continue our crawl (albeit an accelerated one) towards CMS adoption of the 2012 edition of NFPA 101 Life Safety Code® (LSC), we come face to face with what may very well be the final step (or in this case, leap) in the compliance walkway. While there is some language contained in the final rule (and in the press release) that I feel is a little contradictory (but after all, it is the feds), the summary section of the final rule does indeed indicate that “(f)urther, this final rule will adopt the 2012 edition of the Life Safety Code (LSC) and eliminate references in our regulations to all earlier editions of the Life Safety Code. It will also adopt the 2012 edition of the Health Care Facilities Code, with some exceptions.” I suspect that there will be multiple machinations in the wake of this, but it does appear that (cue the white smoke) we have a new pope, er, Life Safety Code®! You can find all 130+ pages here.
Interestingly enough, the information release focuses on some of the previously issued categorical waivers seemingly aimed at increasing the “homeyness” (as opposed to homeliness) of healthcare facilities (primarily long-term care facilities) to aid in promoting a more healing environment. It also highlights a couple of elements that would seem to lean towards a continuation of the piecemeal approach used to get us to this point, so (and again, it’s the feds), it’s not quite framed as the earth-shattering announcement that it appears to be:
- Healthcare facilities located in buildings that are taller than 75 feet are required to install automatic sprinkler systems within 12 years after the rule’s effective date. So, the clock is ticking for you folks in unsprinklered tall buildings
- Healthcare facilities are required to have a fire watch or building evacuation if their sprinkler system is out of service for more than 10 hours. So, a little more flexibility on the ILSM side of things, though that building evacuation element seems a little funky (not necessarily in a bad way).
- For ambulatory surgery centers (ASC), all doors to hazardous areas must be self-closing or must close automatically. To be honest, I always considered the requirements of NFPA 101-2000:22.214.171.124 to be applicable regardless of occupancy classification, but hey, I guess it’s all in the eye of the beholder.
- Also, for ASCs, you can have alcohol-based hand rub dispensers in the corridors. Woo hoo!
I guess it will be interesting to see what happens in the wake of this final rule. I guess this means we’ll have to find something else upon which to fret…
As a related aside, if you folks don’t currently subscribe to CMS News, you can sign up for e-mail updates by going to the CMS homepage and scrolling down to the bottom of the page. I will tell you that there’s a lot of stuff that is issued, pretty much on a daily basis, much of it not particularly germane to the safety community, but every once in a while…
It’s a new dawn, it’s a new day, it’s a new life for you. What do you plan on doing now?
There are a couple of developments on the Joint Commission front. They’re deleting some 131 performance elements from across the accreditation manual; a few are EC-related, but none in the EM or LS chapters, I want to take a few moments to look at the tea leaves before I weigh—maybe I’ll include in our upcoming edition of portal chortlings—we’re about due for a fireside chat, but anyways…
This just in: The Clarifications and Expectations column penned by Mr. Mills is “on hiatus,” but scheduled to return in June 2016. Curiouser and curiouser…
Last week I was working with a client on answering a citation that had come up during a TJC survey (not their survey, but someone else’s—sometimes folks will share post-survey intel). The finding was related to the storage of toilet paper and paper towel in a housekeeping closet, based on (presumably) the notion of the housekeeping closet as a “soiled” area and the toilet paper and paper towel being “clean” supplies (remembering that when we use toilet paper, the rolls are right next to the toilet OMG…OMG…OMG!). Now I am reasonably certain that (much like some other conditions and/or practices I will note in a moment) there are no specific regulatory standards that speak to how and where one is to store paper supplies, etc., so, once again, we come up against the assumed role of the surveyor cadre in prescribing practices instead of assessing how well a risk is being managed. Are there housekeeping closets that are somewhat less reputable looking than others? Absolutely! Are there risks associated with storing paper products in housekeeping closets? Absolutely! Are there risks associated with storing paper products in clean utility rooms, including the potential for pests? Absolutely! Is this a discussion that could go on forever? Absolutely!
To paraphrase the late, great Lewis Allen (you probably know him just as “Lou”) Reed, I am sick of it. I am sick of seeing findings like “linen cart cover was not down,” “solid bottom shelf was not in place,” “materials stored under a sink,” “toilet paper and paper towel stored in a housekeeping closets,” “cardboard boxes in clean utility rooms.” The whole concept of the management of the physical environment is supposed to be based on managing the risks is that very same physical environment. Show me how whatever condition being cited is actually resulted in a risk that is being appropriate managed—not merely the possibility of a potentially increased risk if the planets are in the correct alignment, etc., etc., ad nauseum. Every time I think about the “war on cardboard,” I grind my whole being (not just my teeth); yes, there are places where cardboard ought not be broken down (sterile supply areas, etc.) but those locations are very limited. Show me that we’re not managing the cardboard appropriately. Show me real evidence (not online pictures) that we are legitimately dealing with cardboard critter condos. I absolutely, beyond any shadow of doubt, understand and recognize the risk potential of cardboard, but if there’s no evidence that the cardboard boxes are doing anything more than appropriately holding the contents of said boxes, how does that become a citable offence? When I think of the hundreds of thousands of dollars that have been wasted purchasing plastic bins that (channeling T. Swift here) never, ever, ever, ever (is that too many “evers”?) get cleaned…check ’em out if you don’t believe me. And never mind the kabillion of labor hours devoted to removing all the whatevers from those cardboard boxes and putting them in the plastic bins as opposed to delivering the box full of stuff and then throwing that every same box away when it is empty. In fact, I would submit to you that by getting rid of the cardboard, we have made it exponentially more difficult to manage expiring product. Old days: case with expiration date on it; when case is empty, throw case away—boom! New days: plastic bin almost empty so we dump more product in on top of the old stuff (Oh sure, we’re taking the old stuff out and then placing it in a bag on top of the new stuff to ensure the old stuff gets used first. Yup, that’s what’s happening, yes indeedy…) I’m sure each of you can think of some “practice” that’s being enforced in your organization that is based on not much in the way of logic (logic doesn’t seem to prevail as much as it used to—I can’t think that that’s a good thing). I think we need to take a stand. (“I’m rather unhappy about the current state and I’m not inclined to support it any longer” or the more pointed “I’m mad as hell and I’m not going to take it anymore.” We safety professionals are more inclined towards the genteel first versions when in polite conversation, but deep inside, you know what I’m talkin’ about!)
Okay, that’s probably enough on that topic for the moment (I’m going to guess that there may be one or two heads nodding in the affirmative at this point in my screed, though perhaps there are others that might disagree). If there’s such a strong feeling about this stuff, then the regulators should be very clear about those “clarifications and expectations.” There’s a process for reviewing the survey results before the final results are provided to each organization. Use it to remove these findings that are truly no more than surveyor bias (yeah, it’s like how tough it is to reverse an official decision in sports). Unless, of course, the purpose of the current survey process is to generate as many findings as humanly possible…nah—who’d believe that!
So join us next week as we add another section to our construction of the immortal portal cortile chortle…
Well, maybe ignore is a bit strong…
One of the recurring themes from my childhood was the not-infrequent exhortation from my mother: Don’t go looking for trouble (probably not an uncommon theme for everyone out there in the studio audience). But one of the more common themes that I’ve been running into are those instances in which trouble was lurking in the weeds, but folks weren’t necessarily successful in identifying/locating trouble spots. As near as I can tell, the worst thing that can happen during a survey (from a safety perspective) is when a surveyor identifies a condition or a practice about which you had no clue. It doesn’t happen a lot, but it does happen (usually followed by “Wow, I didn’t know that”).
There are a number of reasons for such a happenstance—sometimes folks really don’t know about something (though, dear reader, you are probably not in that number as we discuss a whole bunch of esoteric stuff). For instance, I still get a lot of folks who (and I have to believe that they are being completely candid) don’t know that hand sanitizer expires (or medicated lotion soap…or disinfectant wipes) or they are supremely confident that that is someone else’s concern (usually EVS when it comes to the many soaps, sanitizers, and disinfectants that populate the healthcare landscape). To my mind, it all goes back to the role of point of care/point of service folks (and I give the caregivers equal billing/accountability with the service-givers on this count) in being able to identify and report or otherwise manage risks in the physical environment.
But we as safety professionals have to be wicked diligent (as I pen this, it’s the day after the Boston Marathon, so that’s my gratuitous reference to Boston cultchah) in really working to ferret out all these little foibles, imperfections, etc. I think I’ve said this before in this forum (and no doubt will again), but whichever regulatory survey team shows up at your front/back/side door, they are going to find “stuff”—the human condition does not easily attain perfection, which leaves us vulnerable, vulnerable, vulnerable.
I recognize that everyone is stretched for time—too many meetings, too many spreadsheets, too many “too manys” to count—which only serves to “push” the maximization of the not-enough’s (not enough time, not enough resources, not enough support) in this adventure. Think of it as a challenge—there are folks out there doing stuff you would rather they not do—sometimes you only see the result (damaged walls and doors, unsealed penetrations, spills, thrills, chills) and we all have to be more effective in keeping on top of things.
Past lessons learned are a wonderful thing, but sometimes you have to go at things a little differently, so go out there and find some trouble spots. You’ll be glad you did!
Eventually, I will run out of these, but hopefully not before the EC portal is perfectly populated and otherwise polished off…
Late last week brought the announcement of new material being posted to The Joint Commission’s Environment of Care portal, this month’s offering focusing on those pesky compliance issues relating to ensuring that building and fire protection features are designed and maintained to minimize the effects of fire, smoke, and heat. The performance elements chosen for additional coverage relate to unprotected openings in fire-rated walls and floors (Can you say “penetrations”? I thought you could!); fire doors have functioning hardware—positive latching, self- or auto-closing—and compliant gaps and undercuts; and making sure that openings in 2-hour fire-rated walls are rated for 1.5 hours.
I guess when it comes down to the perennial survey findings, after egress-related issues, the construction and maintenance of fire-rated barriers is something akin to an old friend. Depending on how many of these puppies (rated barriers—walls and floors; and fire doors), the likelihood of there being some sort of imperfection is fairly good, and since the Life Safety portion of the survey process devotes so much more time (than in the old days) to the inspection of these locations, I can’t say that it’s an overwhelming shock that those imperfections are being identified during the survey process. Interestingly enough, at least at the moment, there is no component of the new posting aimed at the organizational leadership element (yes, Virginia, there is no fireside chat this month on this topic) and the information on the portal page (say that 10 times fast) is a wee bit to the sparse end of the spectrum (there are a couple of links to the Joint Commission Resources webpage for some free downloads), though there is an “example of improved compliance” that provides a flowchart representation of the importance of barrier management as a function of protecting patients (and allowing for evacuation to exist as a last resort). I don’t know, it just seems like there’s something missing from this month’s update. (Mention of the BMP springs to mind. The spirit is represented in the free downloads—a pair of articles from EC News back in 2012, but no specific mention). I suppose one could make the case that there’s not a whole heck of a lot to be said about the practical aspects about maintaining rated assemblies, inclusive of walls, floors, doors, etc. Again, perfection for these life safety features is most elusive and often fleeting. So the question becomes: how do you “capture” these deficiencies as close to their genesis as you can?
One favorite concept of mine (and it gets a mention in the free downloads) is the bounty system as a function of your permitting process—I think (in case you really hadn’t noticed) that anything we can do to enlist the active participation of point of care/point of service staff in these activities—and what better way than to make a game of it? I guess it all comes down to a mix of reinforcing positive behaviors (for frontline staff who identify the miscreants without permits in return for cash and prizes—okay, maybe not so much) and discouraging negative behaviors (by giving the unpermitted miscreants the boot to give them time to ponder their wicked ways). I’ve never had the opportunity to actually operationalize an above the ceiling bounty system. Anyone out there have any success stories they could share? Or, indeed, if you have stories about bounty programs that didn’t quite make the mark, those are always worth sharing.
Not a really banger of a portal update this month (I wonder if the number of findings have been reduced yet—it will be interesting to see what type of impact the portal has on the number and nature of findings…), but I guess you can’t hit a home run at every at bat. Play ball!
Well, I don’t know that I’m disappointed, per se, but I was expecting The Joint Commission to add something new to its physical environment portal, but that appears not to be the case. I guess this calls for an extended drum roll…
But that’s not to say that our friends in Chicago have not been busy—anything but. In fact, it’s been quite a preponderance of stuff this past few days, starting with the 2015 Top 5 most-cited standards. Anyone who bet the under on findings in the physical environment came up a bit short, but surely that can’t be very much of a surprise. We’ve covered the particulars pretty much ad nauseum, but if there’s anybody out there in the studio audience that has any specific questions regarding our top 5, I would be happy to do so again.
So we have the following:
EC.02.06.01—Maintaining a safe environment
IC.02.02.01—Reducing infection risk associated with equipment, devices. and supplies
EC.02.05.01—Managing utility system risks
LS.02.01.20—Maintaining egress integrity
LS.02.01.30—Building features provided and maintained to protect from fire and smoke hazards
I suppose a wee bit of shifting in terms of the order of things, but I can’t say that there are any “shockahs” (after all, I am from Bawston) in the mix. Again, if someone has something specific they’d like me to discuss, I would be more than happy to do exactly that. Check out the online stuff; alternatively, you can also refer to the April edition of Perspectives.
But wait, there’s more…
We also have some new/updated resources for Life Safety Code® compliance, including guidance on how the facility tour is going to be administered, a comprehensive list of documents that would be included in the survey process, information regarding PFI change and equivalency requests, and a bunch of other stuff. You can find all this information online. Something tells me that, at some point, you may be able to link to all this stuff from the Portal (if that is not already the case, that’s what I would do).
And, to finish off a big week of new information, there is a new posting to help the Emergency Management cause. Namely, some resources having to do with the management of active shooter incidents, etc., featuring the joint resource for healthcare providers issued by the Departments of Homeland Security and Health and Human Services to assist with situational awareness and preparedness in the aftermath of the terrorist attacks in Brussels. The focus/intent being to use recent events as an opportunity to reinforce the importance of vigilance and security in our organizations. It is certainly an area for some concern (and, as always, an area of opportunity) and I think that it is very likely that this will continue to be a big piece of the survey puzzle when it comes to emergency management. The risks associated with acts of violence appear to be relatively unabated in society at large and it comes back to the healthcare safety and security professionals to ensure that our organizations are appropriately managing those risks to the extent possible and working towards an emergency response capability that keeps folks safe.
That’s the wrap-up for this week; not sure if any fireside chats are looming close on the horizon, but rest assured, we will keep you apprised of any and all portal-related activity.
If you asked a dog the question in the title above, would it say, “Woof”? (Though some might say kitchen…I sometimes do.)
I’ve been encountering a fair number of roof-related opportunities and I wanted to give the topic an airing. I’m not entirely certain what prompted my thinking about rooftops (it’s way beyond Christmas), but I can say that I’ve encountered a bit of a run on unsecured roof hatches/access doors in hospitals (and hotels, too—I suppose I spend as much time in hotels as I do in hospitals—a certain inescapable logic coming into play on that count).
I will admit that I’m no fan of hatches from a practical standpoint (being rather stout and not particularly tall in the physique department), but I’m kind of surprised at the number I’ve encountered that are not secured (and I’m not talking about something that’s sort of secured, though I’ve seen some not-particularly-well-secured hatches as well). I know it’s important for Facilities/Plant Ops staff to have access to roofs, as well as emergency responders, but leaving these types of locations without any security seems way beyond a reasonable strategy. We’re certainly no stranger to the stories of patients wandering off (and I suppose you can’t always predict who might be prone to wandering) and I don’t know that I would want to hang my hat on the “remote” likelihood of someone “stumbling” on to an unsecured roof hatch, so I would ask you to please be attentive to the hatches and “batten them down” if they should have any level of uncontrolled access.
But just so we’re clear, it goes beyond hatches. It is of critical importance that you have a very hardened perimeter for all your roof areas. I don’t know how many times I’ve found propped, unattended doors because someone didn’t feel comfortable “trusting” a vendor (e.g., window washers) with the key to the access door. And I think it is a very well-established truism that doors for which folks do not have keys tend to get propped (I bet we could distill that into some sort of mathematical equation) and the likelihood of the propping is in proportion (I’m guessing inverse, but maybe not) to the risks of leaving that door unsecured. It may even be worth considering having roof access doors and hatches on your “Elvis” list (i.e., that list of critical things to check when you know you’ve got surveyors in the building—oxygen cylinders, corridor clutter, etc.). It’s all part of making absolutely sure that no one is inadvertently put at risk (I don’t believe that folks would purposefully leave a roof door unsecured and unattended—and I hope there’s no one out there to challenge that belief with a real life example).
Finally, don’t forget about fall protection for the folks you allow on the roof, particularly if you have minimal or no parapets. Interestingly enough, our good friends at the Occupational Safety & Health Administration have a few choice thoughts regarding fall protection; you can start that journey here. Even if it’s somebody working for a contractor, if you have a fall, your organization is likely to be mentioned as prominently as the contractor—and if you ask me, that’s no way to get on the front page of the local newspaper. So, the secret word for the week is “protection”: protection of patients, protection of staff, protection of contractors—it’s all part of the mix.
Next up (unless my calendar is lying to me), we should have another fabulous edition of Portal Chortling, with perhaps a side of Fireside Chat. Stay tuned!
Or those wheels are going to be slipping all over the place…
This week’s offering is a little bit towards the random musings category, so hang on tight!
Friction vs. traction: I think that just about everyone in the safety community has experienced some level of pushback when they’ve tried to enact some change of process/expectation/behaviors to enhance the safety of their organization. And in so doing, you’ve discovered that the healthcare culture really does embrace change—it grabs change by the throat, throws it on the ground, and kicks it until it stops moving. This usually comes down to the classic “I’ve worked here for umpty-ump years and it’s never been a problem before,” etc., and while it doesn’t always seem so helpful in the moment, it does give you something in the way of useful feedback—they’ve actually noticed what you’re trying to do. For example, I can recall a time when the thought of physicians actually wearing ID badges seemed like a fantasy. And yet, as we speak, it is actually happening in a whole bunch of places (maybe not as much as we would like, but you’ve got to start somewhere). Now admittedly, a lot of the move towards the use of ID badges comes down to the proliferation of access control technology, the end result is that compliance became more convenient (in the ongoing battle between convenience and compliance, all too often convenience kicks compliance’s tailbone).
I would ask you to think about those stubborn deficiencies/behaviors that are perennially on your “needs attention” list and look at whether compliance is sufficiently convenient or has the operationalization of a compliance activity, say, the segregation of full and not full compressed gas cylinders, resulted in a process so complicated that it does not encourage compliance. In this case, I would say that more than 50% of the instances in which I find partially full or empty cylinders in the rack designated for full cylinders is because the racks for the “not full” cylinders were jammed with empties or partials and the only place left to safely store (remember, we’ve been nagging folks for about a decade on the proper storage of cylinders) the partial or empty cylinder is in the full rack. Perhaps the question that needs to be asked is whether there is enough space for the partial/empty cylinders; you can usually control the number of full cylinders being provided, but the number of partial/empties can ebb and flow over the course of a shift, a day, even over a week. I know it’s tough to get folks to own up to having put a cylinder in the wrong place (or damaged a wall, but that’s for another day), but I am fascinated by the action that results in someone doing something that they know they are not supposed to do. By the way, this is based on my firm belief that we’ve done enough education on this subject—and I would like to believe that the education that we’ve provided is sufficiently effective to at least get the message across. In looking at the misfiled cylinder as a failure mode—what happened in the process to result in the cylinder being in the wrong place. I can’t imagine that it’s being done purposely (it happens way too often—if it’s purposeful, we might just as well give up), but there has to be something we can discern from these instances/practices that we can use to encourage compliance—make it more convenient, as it were. So, don’t be afraid of a little friction as you pull these stubborn compliance issues apart. If things go too smoothly, there’s probably a workaround lurking somewhere in the background. Remember, it’s taking the path of “least resistance,” not “no resistance.”
The other random musing for the week is for those of you that may be in the middle of your post-survey process; be very judicious when you are creating your corrective actions plans. All too often, I see folks that have way overcommitted on their corrective action plans. Look very carefully at what the standard or performance element is actually requiring you to do and try to pick the route to compliance that work best operationally (meaning choose strategies that encourage compliance without overwhelming the participants—this is an analogue of the eternal question of how to eat an elephant). Don’t commit to daily activities if you can get where you need to be by doing it weekly; don’t commit to weekly if you can get where you need to be by doing it every other week; and so on. Also, I would advise trying to stay away from activities that don’t make sense—operationally, logically, etc. I tend to say that logic doesn’t always prevail, but I reserve that for direct dealings with regulatory surveyors. Once the surveyors are on their way, take the compliance results as data to make improvements—and focus on determining how you’ll measure those improvements. It puts you in a much better position to avoid those findings in the future (and at some point, the regulatory folks are no doubt going to get ugly when it comes to repeat offenses). As with so many things in the safety and compliance realm: this is a journey, not a destination. And on that quasi-Zen note, I bid you a safe week!
And so, the flying fickle finger of compliance finally points portally (via The Joint Commission’s Physical Environment Portal) in the direction of that most troublesome of standards, EC.02.03.05, and we return once again to the fireside of our intrepid duo, Messrs. George Mills of The Joint Commission and Dale Woodin of ASHE. There are two videos, one for the facilities audience and one for leadership (does anyone else find it fascinating that the duo dons neckwear for the leadership video?).
While I don’t want to engage in revealing any spoilers, in the video, EC.02.03.05 is described as being “most prescriptive” and “frustrating” and also notes that Mr. Mills has taken some pains to “tear apart” the standard in past “Clarifications and Expectations” columns in Joint Commission Perspectives. Yet, yet, yet, approximately 40% of hospitals continue to get cited for deficiencies relative to the myriad components represented in this standard. I personally would love to see how this actually breaks down in terms of which of the 20+ performance elements are the most problematic (I can’t imagine that there are some that “float” to the top more than any others), but the video does seem to indicate what the “problems” are:
- You have to have an inventory, by location, of each device class, meaning smoke detectors, heat detectors, pull stations, HVAC shutdown devices, water flows, tamper switches, fire extinguishers, etc. It seems to me that back in the day, there was a reluctance on the part of our Chicagoan friends to actually say the words that would indicate the need for an inventory. But it all comes down (or back—I think I’ve beaten this particular breathless equine once or twice in the past) to knowing that you inspected, tested, maintained, each device in the fire alarm system. So if you (or your vendor’s documentation) do not specifically indicate that each device was demonstrably inspected, tested, maintained, then (buzzer sound): you lose!
- The documentation has to be available “upon request”, so really, if you can’t produce the current documentation PDQ, then (buzzer sound): you lose! You can only get credit for those inspection, testing and maintenance activities for which you have available documentation—if you didn’t document it, you didn’t do it. Period. End of story.
Now I certainly recognize that a combination of findings under EC.02.03.05 would drive a finding under the Leadership standards (to be exact, LD.04.01.05 EP 4), based on past survey reports. But apparently there is indeed a magic number of EC.02.03.05 EP findings that will result in the Leadership finding—three or more EPs out of compliance, then (bell rings): you win a discussion with your boss as to how you allowed (and I’m using that term in its most pejorative sense) such a thing to happen. At that point, for example, it is way too late to admit that the fire alarm and sprinkler testing vendors have not given you very useful reports (and something tells me that that particular conversation is not as rare as it ought to be). From watching the video (and in providing a neckwear-enhanced video specifically for your organization’ s leaders and Mr. Mills indicates he had to edumacate his bosses too—we are not alone), there is a very clear expectation that you, the facility/safety professional, will make the effort to proactive communicate with your boss, particularly if you are experiencing service issues, etc., in getting these activities under control. You can certainly make the case that the protection of the entire organization can be compromised if your fire alarm and sprinkler systems are not appropriately maintained, so, really, any infrastructure concerns should be communicated in a timely fashion to the leadership of each organization to ensure that appropriate resources are allocated on an ongoing basis to make sure everything stays on an even keel.
At any rate, our duo takes great pains to point out that none of this stuff is new (the “seed” documents from NFPA 72, 25 and the like having been penned way back in the 20th century), but I do feel that the methodology for surveying has evolved/mutated over time. I mean, if it were really that simple, wouldn’t this go away? They also point out that ASHE has a fair amount of information to assist you in your compliance efforts (ASHE Focus on Compliance: you can be especially warm for their forms) and there’s even a PowerPoint presentation that The Joint Commission uses at the EC Base Camp presentations (you can link to the presentation on the left hand side of the portal page), which gives it the power of the Quadruple P—Portal PowerPoint Presentation! Ultimately, you’ve got to keep a really close eye on this stuff, aside from product expiration dates, the management of the various and sundry elements of EC.02.03.05 is among the most voluminous in sheer numbers—that’s a lot of spheres to keep up in the air—and you only have to drop a couple to earn that lovely chat with your boss. I am absolutely convinced we can make it happen, so let’s see what we can do to retire EC.02.03.05 from the top 10. (Or 20…wouldn’t that be a fine thing?)