OSHA requires hospitals to have completed training by December 1, 2013 on its revised Hazard Communication Standard for all staff who come into contact with hazardous chemicals. On Wednesday, January 8, 2014, HCPro is presenting a webcast to help you understand the changes and train staff on the GHS updates. In this 90-minute program, expert speakers Marge McFarlane and Paul Penn will explain what staff need to know to be safe and to implement the GHS changes. In addition, McFarlane and Penn will participate in a live question-and-answer session.
You can find more information and register for the webcast here.
As you are all no doubt familiar, sometimes those educational topics surrounding safety can come across as a bit dry and that dryness all too frequently ends up being the focal point of safety presentations. Now, one of the fun little quirky things that you run into when flying is that every time you get on a plane, you have to go through orientation (if only we as healthcare safety professionals could “capture” an audience as frequently as the airlines do) and sometime those orientations are very much less than compelling. And so, I thought that you might find the following offerings from NPR and The Telegraph of some interest, entertainment, and perhaps some inspiration. As I like to say during my consulting visits, this stuff doesn’t have to be torture. At any rate, I hope you enjoy these, and maybe you’ve got some homegrown footage you’d want to share (or perhaps already have shared); there’s no reason we can’t all partake of such splendor.
Another email question asked whether there were any specific Joint Commission education requirements for the folks who conduct quarterly fire drills. The short answer to that question is no, TJC does not require any specific education for the folks conducting the fire drills. But you know that I rarely rest upon the short answer, so I would certainly think that from a practical standpoint, it might not be a bad idea to have a little education package gathered together for that purpose. Ultimately, there is a responsibility to ensure that folks are competent in whatever they’re doing and you would certainly want to make sure that any folks assessing the competencies of others (which is nominally what you’re doing when you conduct fire drills) are themselves competent in that process. Again, not a bad idea to have something, but it’s not specifically required. I would suggest including some accounting of the process in your Fire Safety Management annual evaluation. Is anybody else working on this type of thing? I suppose there are lots of points in which staff interactions are evaluated for compliance—how do you make sure the folks doing the oversight have got the goods? I, for one, would be interested to hear any stories about this.
I don’t hear too many stories like this anymore, but I can tell you, as a former manager of security services at a hospital, this is one that really gives me pause.
In September, at a hospital out in San Francisco, a patient disappeared from her room, after which a search ensued with no result. The awful thing is that the patient was found in a locked stairwell about two weeks later by an engineering staff member doing rounds. You can find the San Francisco Examiner story that caught my eye (as well as several related stories).
Now I’m sure the investigation will yield some indication of what happened, but I’m also thinking that the whole story may never be revealed. Was that stairwell inspected prior to the point when the engineering staff person made their rounds? How was the search conducted? Was there a conscious decision to limit the search to unsecured areas? At what point do you suspend the search?
I’m certainly not going to Monday-morning quarterback such an awful circumstance, but the question I ask myself is this: can you stop looking when you’ve not found the person you’re looking for? Again, it’s my understanding that the stairwell in question was secured, but how many times have you encountered a security system that was absolutely impregnable—my experience has been that the human element is all too frequently the means of defeating the certain security measure. So has this particular tragedy caused anyone to look at, or even rethink, their search protocols? Are there areas you might not consider as being accessible that might warrant at least inclusion in a comprehensive search grid? I’d be interested in what you all think about this one.
Reaching into the old e-mailbag, a question was raised regarding who “owns” the process for credentialing and what survey vulnerabilities might be lurking in the process. Now I can start by saying that there are no specific requirements as to a credentialing process for vendors; the overarching expectation is that vendors are like any other risk—something to be managed appropriately. Certainly, if you have equipment vendors scrubbing out and assisting in the OR, then that has a more far-reaching implication than a vendor who is responsible for managing copy machines. I suppose if you had to stretch things a bit, whoever is responsible in the organization for managing contracts would certainly be in a leadership position for stuff like this, but that responsibility can be more or less genericized as a function of “services will be provided in accordance with all applicable standards and regulations, including CMS, Joint Commission, state, etc. This would include consideration of such things as competence of the vendors (as an example, I will invoke Clinical Engineering relative to oversight of the contract services provided by external vendors—how do you make sure that contract equipment services personnel are adequately competent, etc.?). I don’t know that you could ever really trace it back to one or two folks in terms of ownership of the process—an organization of any complexity, etc. is going to have many, many contracts for various and sundry services, so there would almost have to be some division of responsibility (I say almost because I suppose you could maybe find the person with worst case of OCD in the organization and hand the responsibility to them—you’ll sleep at night—but he or she probably never will again) that ultimately ties back to senior leadership.
All that said, survey preparation comes down to knowing that the organization is effectively managing contract service vendors (and I’m using that term at its most expansive definition—everybody that provides services that is not directly employed by the hospital would have to be considered in the mix). You could certainly distill this group down to those which would be considered most critical (if that sounds like a risk assessment, you would be correct) and then identify a strategy for monitoring and periodic evaluation of performance. It’s all about having an effective process; generally speaking, TJC generally “leans” on this only when they’ve identified a clear and present failure mode; so if the vendors are adequately competent and behave themselves while under your roof, you should be okay—but you have to have some sense of whether than is indeed the case.
BTW: I had no intention of sexism in the headline; I was going to do the split Mr./Ms. Vendor Person, but, I don’t know, Mr. Vendor Man seems a little more rock and roll…
During a recent Joint Commission survey, a question was raised regarding the “length” of nurse call cords (it appears that the surveyor indicated that the end of the cord should be an inch above the finished floor). The Facility Guidelines Institute requires that the call be within reach of a patient on the floor, but there is no specific distance indicated. Now, my personal rule of thumb has always been to try and “hit” a point that is about 3 inches off the finished floor (about the height of your average piece of cove base); this allows access to someone who’s on the floor, but provides enough clearance for mopping the floor (and believe me, those cords can pick up a lot of built-up detergent if you don’t leave enough room). However, if your EVS folks are using microfiber mops, which are a little less poofy (that’s kind of a technical term), then you might be able to have the end of the cord a little closer to the floor. Ultimately this, like countless other topics of conversation we’ve featured here, becomes the function of appropriately managing the involved risks—fallen folks being able to summon help and not having to grab a fistful of sticky call cord to get that help. Of course, if staff are wrapping the cords around the grab bars in the bathroom, that, as they say, is a whole other thing…and not a good one. Oh, and by the way, don’t forget that the cords themselves also represent a cleaning/disinfection challenge—they ain’t so easy to clean—and they really should be done on a pretty regular basis.
Recently, ECRI unveiled its list of the Top 10 Healthcare Technology Hazards (here’s an article discussing this topic). And strangely enough, there is at least a couple that I think you will find oh-so-very familiar. Hopefully, you’re already working on the hazards that fall under your jurisdiction (which will vary from organization to organization), but I think it’s never a bad idea to take a look at what the think tanks are identifying (best believe that your favorite regulatory agency—insert name here—is keeping close tabs on groups like ECRI) and plan accordingly. I’m just going to list the hazards as indicated by ECRI, but if anyone out there in radio land has an interest in more in-depth discussion, please let me know and we can do just that. That said, I think these are pretty straightforward.
1) Alarm hazards
2) Infusion pump medication errors
3) CT radiation exposures in pediatric patients
4) Data integrity failures in EHRs and other health IT systems
5) Occupational radiation hazards in hybrid ORs
6) Inadequate reprocessing of endoscopes and surgical instruments
7) Neglecting change management for network devices and systems
8) Risks to pediatric patients from “adult” technologies
9) Robotic surgery complications due to insufficient training
10) Retained devices and unretrieved fragments
OSHA’s revised Hazard Communication standard requires hospitals and other healthcare facilities to have trained staff on the new Globally Harmonized System (GHS) by December 2013. The intent is to make the identification of hazardous chemicals much quicker and easier, and to make it faster to find recommended first aid procedures in the event of worker exposure.
HCPro will offer several staff training solutions to help facilities, including Hazard Communication Training: Implementing the GHS, a new DVD that will be available in December. This video will help you:
- Meet OSHA requirements for training employees on the Hazard Communication standard
- Train staff to understand the revised Hazard Communication standard
- Improve hazardous chemical safety in your facility
- Learn the new pictograms issued by OSHA
Chemical manufacturers aren’t required to comply with the new regulations until June 1, 2015. That means there will be close to a two-year gap during which employees will need to understand the traditional material safety data sheets (MSDS) as well as the new safety data sheets (SDS).
Visit the HCPro Marketplace for more information and to order.
One of the time-honored pursuits, mostly as a function of what you can and cannot manage through the plan for improvement (PFI) process, is what exactly constitutes a Life Safety Code® (LSC) deficiency. Just so you know, I used the “exactly” descriptor for a reason—because the definition, while pretty clear (at least to my mind—feel free to disagree) is a fair distance from exact, but read on and maybe it will become a little more clear.
The “secret” to all of this can be found on pp. 24-25 of the 2000 edition of the LSC. Contained on these two pages are the “documents or portions thereof” that “are referenced within this (Life Safety) Code as mandatory requirements and shall be considered part of the requirements of this (Life Safety) Code.” Thus, these requirements include some of the items you’d probably expect to be there: NFPA 10 Standard for Portable Fire Extinguishers, NFPA 13 Standard for the Installation of Sprinkler Systems, NFPA 70 National Electrical Code, NFPA 99 Standard for Health Care Facilities; and maybe some that you wouldn’t necessarily include in the mix, but make sense when you think about it: NFPA 30 Flammable and Combustible Liquids Code, NFPA 241 Standard for Safeguarding Construction, Alteration, and Demolition Operations. Not that I usually get into product endorsements, but I think even a casual glance at the list of required elements would point you towards having a subscription to all the NFPA codes—and that’s not getting into the other publications cited as required (ANSI, ASME, UL) because they all have a share in the mandated references. Oh yes, and the final “other” publication mentioned is Webster’s Third New International Dictionary of the English Language, Unabridged; you could probably get into a lot of trouble with that…
Therefore, an LSC deficiency is really any condition or practice that is not compliant with any of the referenced codes (is your head spinning yet?), so you can probably craft a PFI for just about any safety-related hazard. In this world of ever-shrinking operational budgets, the PFI process may become an everyday tool as opposed to the once in a blue moon process it has sometimes been in the past. Remember, if the deficiency can be resolved within 45 days, then you can use your work order system. But if you can’t resolve the deficiency within 45 days (and budget constraints are no doubt going to have a greater impact on that in the future), then the PFI could become your new BFF.
When it comes to the Life Safety document review, there is still a fair amount of survey risk exposure and (no surprise) a fair amount of survey findings. EC.02.03.05 is the 6th most frequently cited standard; 44% of the hospitals surveyed in the first six months of 2013 were cited under this standard!
Some of the findings have related to irregularities in the testing process. You have to make sure that your device inventory numbers match up; if you had 50 pull stations last year and 55 pull stations this year in the testing documentation, you had better know why and it better be because you added some pull stations, otherwise it could get ugly. But one thing I’ve seen in a couple of recent surveys (both TJC and in my own practice) is the documentation of fire alarm and sprinkler system testing and maintenance that is performed by in-house staff. A typical one is the weekly fire pump test—pretty much everyone does that one in house. Now, there’s nothing wrong with that, but you have to make sure that the documentation of in-house activities is in compliance with EP 25, which requires the inclusion of the following information:
- Name of the activity
- Date of the activity
- Required frequency of the activity
- Name and contact information, including affiliation, of the person who performed the activity
- NFPA standard(s) referenced for the activity
- Results of the activity
In my experience, most folks have the first three pretty well in hand, but sometimes those last three get lost a bit in the shuffle. It might be worth a review of your in-house documentation to make sure you have all the required elements in place.