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A clear case of compliance interruptus

Greetings one and all from high above the 2012 Life Safety Code® (LSC) compliance track with a quick update on CMS plans for administering surveys, etc., in the wake of official adoption of the 2012 LSC. I’m climbing out on a limb just a little bit as the latest missive in this regard from The Joint Commission indicates that it will begin surveying to the requirements of the 2012 LSC on July 5 (Happy freakin’ Independence Day), but it appears that CMS has other ideas. In a member alert disseminated late last week, our friends at the American Society for Healthcare Engineering (ASHE) are reporting that a memorandum was issued by CMS to the various and sundry accreditation agencies (TJC, DNV, HFAP, M-O-U-S-E) indicating that hospitals have until November 7, 2016 before this new shiny hammer is wielded during accreditation surveys. Now, I think it was likely that there would be some sort of transition period for this process (the accreditors would have to update their standards manuals, etc., and I don’t think that happens overnight, but maybe there are manual elves that come in under cover of darkness), so I guess that has come to pass and the end date for that transition is November 7 (I guess they didn’t want to wait until the following month’s day of infamy).

As I’ve noted in this space recently, a lot of the basic tenets of compliance are going to pretty much stay the course. We will continue to manage rated barriers (walls, decks, doors); we will continue to manage egress (perhaps a little more simply, but clutter will still be clutter) and so on. There may be some efficiencies to be gained in the practical application of the various fire alarm and fire suppression system inspection, testing, and maintenance processes (I’ll have to do some edumacation on those), but I really think that the devil in all these details is going to come from how the requirements of NFPA 99 Standard for Health Care Facilities are administered and/or otherwise enforced. NFPA 99 has always kind of hovered in the background, but I think is going to be very much a coming out party. At any rate, ASHE has made available a fair number of resources (some readily accessible, some for members) and I would encourage you to do a little digging if you have not already done so. I still think the physical environment is going to figure quite strongly in the survey process, but maybe this is where we get to share the most frequently cited standards lists with the clinical folks.

On a closing, and most somber note, in the wake of events in Orlando this weekend (thoughts and prayers to all the victims, their families, the community at large, and pretty much everybody else), I can’t help but think that there’s got to be a better way. I know the circumstances that can lead up to events like these are extraordinarily polarizing—and I’ve noted that the polarization didn’t waste any time manifesting itself in the halls of social media. I wish that I had some sage bit of advice or encouragement, but nothing is coming right now beyond this old cliché (doesn’t make it any less useful or true)—cherish your loved ones…right now! We will all be better for it.

AAMI: What you gonna do?

By necessity, this is going to be somewhat of a hodgepodge of stuff as there are no new postings to The Joint Commission’s PEP site. Looks like we’ll have to wait for July to see what they have to say about the intricacies of LS.02.01.30, though I suspect that we can anticipate some coverage of hazardous locations (Can’t they come up with a better descriptor? While I absolutely understand that the requirements are driven by the point at which the level of stored combustibles in a space is considered “hazardous,” I find that it can be rather challenging when communicating to the clinical folks as to why they shouldn’t randomly convert patient rooms to storage rooms. The refrain is typically “We don’t have anything hazardous in the room, we just have paper supplies, etc.” to which I respond, “Well, you’ve got an amount of paper supplies, etc., that is considered hazardous by the Authority Having Jurisdiction,” to which I tend to receive a blank look and an “oh.” Told you this was going to be a hodgepodge…

Getting back to our PEPpy discussion; I think we’ll find out a bit about smoke barriers, corridor walls, corridor doors, etc. But then again, with the adoption of the 2012 Life Safety Code®, the scheduled PEP modules may be deferred and perhaps they’ll post something relating to whatever changes will be occurring to the Life Safety chapter of the accreditation manual. I think that’s enough blathering about something that didn’t happen, so let’s talk about something that did happen.

At this point, you (or your organization—why I would think that you would have been involved in this is beyond me…) should be well-ensconced in the practical applications of the National Patient Safety Goal regarding the management of risk associated with clinical alarm systems as a function of the Joint Commission requirements thereof:

  • Leadership establishment of alarm system safety as an organizational priority
  • Identification of the most important alarm signals to manage
  • Establishment of policies and procedures for managing those most important alarm signals
  • Education of staff and licensed independent practitioners about the purpose and proper operation of alarms systems for which they are responsible

Hopefully you’ve got that all going in the right direction. But if you’re falling a little short or if, indeed, you’re not sure about progress, the good folks at the Association for the Advancement of Medical Instrumentation (AAMI) have a webpage devoted to information regarding clinical alarms. Those resources include a downloadable Clinical Alarm Management Compendium (maybe CLAMCOMP would be a good acronym) to assist you in these endeavors. If you haven’t yet checked out the AAMI materials, I would very much encourage you to do so (or encourage you to encourage whoever is managing this process in your organization) is because reference to this webpage is included in the rationale statement for this particular safety goal and the stuff that ends up in the accreditation manual has a tendency to take on an elevated criticality in the hands of some surveyors. We could certainly talk about what is and what isn’t “surveyable” as a function of its appearance in any of the manuals, but if you haven’t referenced the AAMI stuff, you are in a position to have defend why you haven’t used such an august reference in your pursuit of alarm safety. To add a bit of heft to this advice, you might also consider the May 18, 2016 edition of Joint Commission Online, in which there is a link to an article published by the AAMI Foundation entitled “Framework for Alarm Management Maturity.”

This may be much ado about nothing, or more likely, folks are already “down” with this. But on the off chance that somebody out there actually uses this space for information and hasn’t run across this, I think it’s worth a mention. You certainly want to make sure that your alarm management process is maturing in proper fashion.

Before you a-Q’s me, take a look for yourself…

As we await new content on the PEP (aka the newly-popular Joint Commission offering, the Physical Environment Portal), I want to draw your attention to an interesting development on another part of the Joint Commission’s website: the ever-popular (such popularity and minimal polarity…) Frequently Asked Questions page (now re-imagined as Standards Interpretations—really, check it out). And let me tell you, there is a ton of newly configured information to be found. If I were really attentive to such things (I usually am, but in this case I wasn’t expecting such a sweeping re-imagination of this part of the TJC website), I would be able to tell you how much more information there is to be had, but I think I can safely say that, at least in terms of the numbers of entries, the amount has easily doubled in relation to the “old” FAQ page. Some of the material appears to be derived from information that had been previously shared through George Mills’ Clarifications and Expectations column in Joint Commission Perspectives; other bits and pieces seem to be derived from information shared on the PEP. There also seems to be some stuff that hinges on the practical application of the now-expiring CMS categorical waivers (which I guess means there will be some updating of content in the not-too-distant future) and some other stuff that appears to have been developed specifically for this new page. (Dare we call it the Standards Interpretation Portal? We’ll be able to engage in regular SIP-ing!)

At any rate, I’m going to be poring over these entries with great interest and I would recommend that you keep a close eye on the SIP as well. Remember, the interpretations published on the SIP (I really do like that!) are “enforceable” as standards, and there’s no reason to think that TJC surveyors aren’t going to be checking out these materials as well. One interesting note: I don’t recall seeing any official announcement regarding the re-birthing of the FAQs (I won’t claim that I track every utterance from the folks in Chicago), so I may be pre-empting the grand unveiling (if you have a standards question, don’t forget to SIP!).

One item that really caught my fancy (and this was in response to a client question) was the entry regarding oxygen storage, which I know has plagued a number of organizations, particularly as a function of the segregation requirements. My thoughts on this have been that the simplest means of separation is to focus on full and not-full as the segregation metric; most folks do not have sufficient space to be able to reasonably pull off the full/in use/empty trifecta and NFPA 99 really only requires that the full cylinders be separated from everything else. So, if you use the full/not full designations, it’s not only a simpler decision-making process in the moment, it appears to be in keeping with the information shared on the SIP.

I’ll let you be the judge of what’s going to work in your organization, but I do believe that the fewer complications in the mix, the greater the likelihood of compliance.

I recommend you starting SIP-ing right away and maintain your compliance hydration throughout the hot summer months!


The answer, my friends, is blowing in your facility

As I think everyone is aware, there has been a lot (okay, perhaps quite a lot) of focus during our pas de deux with the regulatory survey groups running around our hospitals on the various and sundry environmental conditions (temperature, humidity, air pressure relationships) for which there are various and sundry requirements (we’ve discussed those general considerations in the past, but if you need a refresher, feel free to dig through the archives at Hospital Safety Center). But a recent issuance from the CDC really starts to point to some of the ways in which the whole air pressure thing can actually influence the effectiveness of the management of immunocompromised patients as a function of air pressure relationships. There’s also an interesting study done by the folks at Johns Hopkins that speaks to the amount of time the doors to surgical procedural rooms are open during cases. I think we can all agree that keeping the doors shut during cases should probably be on the list of good ideas, but I suppose there can be a lot of coming and going—enough to de-pressurize the room. I’ve always felt that it is important to have some sense of how long it takes to de-pressurize and re-pressurize some of these critical areas; you want to make sure that folks are checking the pressure relationships when you have your greatest chance of success, recognizing that these rooms all “breathe” to one extent or another (and some of them come very close to wheezing…).

At any rate, information like this will likely only increase the attention paid to these areas during our survey encounters, with the added dynamic of this information being representative of the time-honored “smoking gun.” So, certainly acting on the CDC’s recommendation that immunocompromised patients not be placed in negative-pressure environments is something we can implement right away, but you’re probably going to want to come up with some sort of methodology for identifying those patients that rule in for that demographic (I’m thinking that our patients would tend more towards the immunocompromised side of the coin than not). We certainly don’t want to inadvertently put patients at elevated risk for infection, etc., by placing them in an inappropriate environment, so I think my immediate advice would be to look really closely at the information from the University of Pittsburgh Medical Center cases. If the end result looks an awful lot like a risk assessment, then I think you’re in the right place—and your patients will be, too!


Everybody here comes from somewhere else…

First off, just wanted to wrap up on the missives coming forth from our compadres at The Joint Commission and ASHE relative to the adoption of the 2012 Life Safety Code® (LSC) by CMS. The word on the street would seem to be rather more positive than not, which is generally a good thing. Check out the statements from TJC and ASHE; also, it is useful to note that the ASHE page includes links to additional materials, including a comparison of the 2000 and 2012 editions of the LSC, so worth checking out.

At this point, it’s tough to say how much fodder there will for future fireside chats. It does appear that the adoption of the 2012, while making things somewhat simpler in terms of the practical designation of sleeping and non-sleeping suites (Don’t you wish they had “bumped” up the allowable square footage of the non-sleeping suites? Wouldn’t that have been nice.), combustible decorations and some of the other areas covered by the previously issued CMS categorical waivers (If you need a refresher, these should do you pretty well: ASHE waiver chart and Joint Commission), isn’t necessarily going to result in a significant change in the numbers and types of findings being generated during Joint Commission surveys. From my careful observation of all the data I can lay hands on, the stuff that they’re finding is still going to be the stuff that they are likely to continue to find as they are the “deficiencies” most likely to occur (going back to the “no perfect buildings” concept—a lovely goal, but pretty much as unattainable as Neverland). I’m not entirely certain what will have to occur to actually bring about a change in EC/LS concerns predominance on the Top 10 list; it’s the stuff I can pretty much always find (and folks usually know when I’m coming, so I’ve pretty much lost the element of surprise on the consulting trail). Now, it may be that the new matrix scoring methodology will reduce the amount of trouble you can get into as the result of existing deficiencies—that’s the piece of this whole thing that interests me the most—but I see no reason to think that those vulnerabilities will somehow eradicate themselves. I suppose there is an analogy relative to the annual review of our hazard vulnerability analysis (HVA)—the vulnerabilities will always exist—what changes (or should change) is our preparedness to appropriately manager those vulnerabilities. Makes me wonder if it would be worth doing an EC/LS HVA kind of thing—perhaps some sage individual has already tackled that—sing out if you have. At any rate, I’ll be keeping a close eye on developments and will share anything I encounter, so please stay tuned.

Hopping over to the bully pulpit for a moment, I just want to rant a bit on what I think should be on the endangered species list—that most uncommon of beasties—the kind and decent person. I know that everyone is nice to folks they know (more or less), but there seems to be a run on a certain indifference to politeness, etc., that, to be honest, makes me see a little read from time to time. But then I think to myself that it is probably just as rude to overreact to someone else’s rudeness, so take some deep cleansing breaths and let it go. Now I would love to hear from folks that they haven’t noticed this shift and that their encounters with folks are graced with tolerance, kindness, etc.; it would do my heart good. Maybe it’s just me…but somehow I’m thinking maybe not.

Please enjoy your week responsibly and we’ll see what mischief we can get into next week.

You better start swimming or you’ll sink like a stone…

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…

The end of hordes of portal exhortals: Getting hep to the PEP!

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…

News flash: Vacuum cleaner sucks up budgie! Is you is or is you ain’t my baby?

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: 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?

Musings from Rantopolis

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…

Sometimes you have to ignore what your parents told you

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!