OSHA fined a Maine psychiatric hospital $11,700 last month for failing to provide its employees safe workplace conditions.
The investigation at Acadia Hospital in Bangor, was prompted by an employee complaint in July 2010 of an increase in patient assaults and injuries to staff because of the hospital’s no restraints policy, reported the Bangor Daily News. The report, released by OSHA on January 22, calls the violations serious, indicating 115 physical assaults on staff since January 2008.
Injuries included broken teeth, broken glasses, bites, and contusions, and the report found staff had been punched, kicked, and hit by violent patients. OSHA determined the injuries were the result of a workplace that wasn’t up to safety standards. The report demands specific means of decreasing violence toward employees, including better patient screenings, improved communication amongst hospital staff, and increased staff and security training.
How does your facility handle violent patients?
Q: It has long been understood that the EOC standards allowed for actual fire alarms to be counted for up to 50% of a facility’s required fire drills. Out of random curiosity, I tried looking up that standard today and was not able to find the information in EC.02.03.03. Does the standard no longer exist or am I looking in the wrong location?
Steve MacArthur: As information documented in The Joint Commission standards, there is no mention of this under EC.02.03.03. I suspect that the concept is derived from the allowance for an organization to use a “real” emergency toward compliance for the emergency exercise requirements; and the 50% figure is derived from the allowance (under EC.02.03.03 EP #3) which requires at least 50% of the quarterly fire drills to be unannounced.
Strictly speaking, you could use actual fire alarms as however many of the required drills so long as you can appropriately document an evaluation of fire safety equipment, fire safety building features, and staff response to fire, during that event.
Generally speaking, in my experience it is very tough to conduct the same level of evaluation for an unplanned event as you can for a planned drill, but that’s not to say that it’s not possible to do so. Ideally, you wouldn’t be having enough actual alarms to meet the minimum of 12 drills that sort out appropriately by shift—that could make for a very chaotic environment. But again, it really comes down to being able to honor the purpose of the drill, which is to evaluate the performance of people, systems and equipment— as long as you have that documented you should be just fine and dandy.
A 3,000-pound piece of equipment fell onto two men in an Illinois hospital on January 19 and has spurred an investigation by (OSHA).
The accident happened at Advocate Good Samaritan Hospital in Downers Grove, IL, where two hospital workers were injured in a narrow maintenance corridor, reported The Chicago Tribune. The investigation is still ongoing.
A hospital spokeswoman reported the organization is unsure of the cause of the accident and that it plans to execute all recommendations given by OSHA after the investigation.
Advocate Good Samaritan has been in the spotlight before with OSHA, in 2002 and in 1993. In 2002, OSHA inspectors found blocked doors and walkways, but the hospital was not fined. In 1993, OSHA found that workers were exposed to patients infected with tuberculosis, and were not given the appropriate number of respirators, reported The Chicago Tribune.
How does your facility help prevent accidents like this? Let us know in our comment section
Q: How often do you believe a safety committee should meet? I have always believed monthly, and have always thought the minimum should be every two months? I was recently asked whether quarterly was acceptable. I don’t think so. What do you think?
Steve MacArthur: First, a bit of history. Prior to the 2009 changes to the EC standards, (which included the establishment of the Emergency Management and Life Safety Chapters) the requirement for meeting frequency was indeed no less frequent than every other month.
However, beginning in 2009, the frequency requirement was removed (I believe it was most likely in response to smaller facilities for whom even the bi-monthly frequency was onerous) and replaced with the tacit expectation that each organization will, through a risk-assessment process, determine the appropriate frequency. That said, while there is certainly no regulatory requirement prohibiting quarterly meetings, my inclination would be to discuss the change as a function of the risk assessment process and then include an ongoing evaluation of that decision as a function of the annual evaluation process. That way they can’t cite you for not having made a “correct” determination.
I guess it all boils down to whether or not your committee can effectively manage risk in the physical environment meeting on a quarterly basis. It may be that you don’t really experience a lot of improvement opportunities, failure modes, etc. and that will work. There are certainly enough not-particularly-useful meetings in the mix as it is, so if you find that the meetings are not useful (and ensuring that this is because of the level of activity within the organization and not the level of interest on the part of participants), it is certainly worth looking at.
The gloves come off – wait a minute, there’s another glove underneath! As is my custom when embarking on the journey into the new year, when I get my new copy of the TJC accreditation manual, I like to compare and contrast last year’s tome to this year’s.
Generally speaking, there are not many big ticket changes (I think that 2012 is going to be the bigger, and maybe even a generally big, year for change), and we’ll discuss the removal of the performance elements that keyed on long-term care settings and a few items of what I would loosely term a relaxing of restrictions. However, as an old environmental services (EVS) hand (my first 17 years in healthcare!), I was intrigued to note that EC.02.06.01 EP 20 (Areas used by patients are clean and free of offensive odors) was elevated to a Direct Impact finding. Now, I will admit in all candor, that I had a very difficult time figuring out how that particular expectation could be considered anything but a direct impact on the patient experience, and so feel somehow vindicated that cleanliness is now, potentially, a little more prominent on the radar screen.
I recall the days when any regulatory survey involved a fair amount of the old white glove inspection, with frequent chastisements for less-than-ideal cleaning. As I used to tell folks in orientation, it is very difficult, if not impossible, to effectively prevent and/or control infections in a dirty environment. Even in my consulting practice, I am always aware of how well the EVS staff is taking care of business. It may not get a lot of press, but it is a very important part of the healthcare process.
And so, it remains to be seen whether this is nothing more than an accounting adjustment, so to speak. But it may be a harbinger of an increased focus on cleanliness. I, for one, can’t say that I’m unhappy about it–we should be providing a clean environment to our patients. We would expect nothing less–nor should they.
Keep it clean out there!
Calling all dust busters, feather dusters, and brooms: The University of Missouri Health Care needs you.
After a Centers for Medicare & Medicaid Services (CMS) five-day survey at the Columbia, MO, facility in November, 66 findings of dust were recorded in the 47-page survey report, according to Fierce Healthcare.
The report found dust collecting in a same-day surgery suite, a pre-op room, and on a portable ultrasound machine. In the same-day surgery suite, surveyors found 100 sticky spots on the floor and a dust layer on top of an anesthesia cart and a fluoroscopic camera located above the surgical table. In the pre-op room, sterile gloves and other supplies pulled from a storage bin had pieces of dust sticking to the packaging, reported Fierce Healthcare.
The hospital was visited by eight CMS surveyors after a past employee filed a complaint.
How does your facility manage dust? Let us know in our comment section.
Q: I work in a behavioral health facility and was hoping to get your input regarding patients’ used disposable razors. We are presently treating them as red bag materials. They are put into sharps containers like needles, and then stored in boxes until being sent out to our regulated medical waste hauler. In actuality approximately 85% of our red bag items are from these razors. We don’t use many needles and the company that we outsource our lab services to takes care of their own needles that are used by their phlebotomists.
Can you tell me what the regulations are for handling such items and/or what is being done at other hospitals? It seems like a waste of a lot of money to dispose of disposable razors in such a manner since the rest of the public, including hotels and private residences, treat these as regular waste.
Steve MacArthur: In some ways, this is a pretty straightforward decision as disposable razors, in and of themselves, do not meet the requirements for regulated medical waste. This is because they are not generally contaminated with blood or other potentially infectious materials, though it would probably be a useful strategy to enlist the opinion of your infection prevention practitioner. That said, ultimately the most important determination is that made by your non-regulated waste hauler, because they have the role of completing the disposal process (the responsibility, as you know, is yours from cradle to grave), so they would be the ones with whom to have the discussion. You are absolutely correct in your comment about the expense of disposing non-regulated waste through the regulated medical waste stream. I would think that you could contact your trash hauler and come up with a process that does not increase the risk to their folks and remove a substantial portion of your regulated medical waste stream. I think that as long as you are placing the razors in a safety container, and have the agreement of the waste hauler, there is no infection risk to speak of and the safety risk of someone getting sliced by a discarded razor is appropriately managed by the safety container–then we have an acceptable process for all concerned. Think of how many disposable razors are disposed of every day without a thought as to the safety of that process. If we go about this in a thoughtful, considered manner, we can come up with a process that works for everyone concerned.
I hope this helps answer your question; if you have further questions or need additional information, please let me know.
A list of safety improvements is scheduled to be fixed during 2011 at Phelps County Regional Medical Center (PCRMC) in Rolla, MO, in an effort to emphasize safety from workplace violence.
Since November 2010, PCRMC recorded 531 calls for threatening behavior or assaults. Due to this, the hospital has identified a list of improvements necessary for the hospital. According to the St. James (MO) Leader-Journal, the list of improvements consists mainly of the following security issues:
• No one watches the more than 160 cameras in the security system at all times
• Security isn’t informed quickly of violent situations
• Hospital staff members are not identifying potentially violent situations to Security
• Staff members don’t want to get involved
• There are no barriers between the hospital and the interstate
• The hospital has too many entrances; an official said there are 57 points of entry.
• The entrances cannot be locked at one time
• A generic code is used for the ambulance entrance
• All reception areas are open and lack security
• The obstetrics unit is not locked all the time
Hospital CEO John Denbo said the hospital needs improvement in security and safety.
“We’re just a microcosm of the town,” Denbo said. “We used to think the hospital was a sanctuary, but anything that could happen out there probably will happen in here.”
What kind of security improvements does your facility need?
The Scott & White Hospital-Llano (TX) replaced its outdated security system by purchasing a new one.
Along with a new security system for the hospital, Scott & White Hospital also purchased a cardiac monitoring system for Llano’s ambulances, reported The Llano County Journal.
The new $33,500 security system is being provided by McRoberts Security Technologies in New Jersey.
“We’re leap-frogging into the latest technology available,” Kevin Leeper, hospital CEO, said to The Llano County Journal.
What sort of security changes have you seen in hospitals? Let us know in our comment section.
Q: I was just wondering what your thoughts are on the expanding life safety surveyor. I am in a 42-bed hospital and on my last survey cycle I got my first Life Safety Surveyor. My next survey should be any time. My last surveyor spent about five to six hours with me and asked many different questions, went through the grid of questions on the fire equipment, and at the end of the day, I thought he could not possibly have any more questions. But now I will have a surveyor for two days. What will the surveyor look at?
Steve MacArthur: You pose an interesting question–one for which I have given a fair amount of consideration as my client work tends to be in smaller facilities–so I’ve had a number of conversations in this regard.
One thing (or I suppose a couple of things) I can say for sure is that the survey of the physical environment will be conducted primarily, if not exclusively, by the Life Safety Code® (LSC) surveyor, including the Emergency Management review and the Environment of Care document review, which historically has fallen on the other members of the survey team.
So, the management plans, EC minutes, annual evaluations, disaster critiques, etc. will all be reviewed by the LSC surveyor. I see this as an absolute plus for folks with well-organized programs as the review will be conducted by someone with rather more current expertise so the review will be conducted by someone who understands the practical/operational considerations, so I am hoping that this will result in less need for us to defend our rational decisions to “opinions” that are not germane, or even possible, in the current regulatory environment.
The LSC surveyors generally have regular jobs at hospitals, though I suspect with the broadening of the survey scope we may see more folks taking this on as a retirement job, but that may not be for a while. Conversely, folks with “squishy” programmatic elements are much more likely to have those vulnerabilities exposed during survey. I’m not sure if I’ve mentioned this previously in the blog, but there is a certain recognition that we do not exist in a perfect environment, so it is how we proactively manage those imperfections that will be the benchmark at the end of the day.
Another benefit is that we won’t have to “bond” with different folks during the survey, which, especially in smaller organizations with not a lot of bench strength, can be a challenge in a short survey. You’re getting pulled in a million different directions (I’m sure you know that feeling). The survey of your area of responsibility has become, in effect, a one-stop shop, which will allow you to exercise greater control over the process. Sure, there is a chance that they can dig a little deeper and find a few more things, but really, are they going to be able to find something about which you are unaware? I think not.
As a final “benefit”, if you will, is that the LSC surveyor will stick around long enough for you to discuss the findings and, ideally, make your case for compliance. Although the “marching orders” at the moment are for everything to go into the report, you can discuss the findings as a function of compliance with the standards, which will help you make full use of the clarification process. If you look at the standards that are being cited most frequently, there are lots of “C” performance elements in the mix, so lots of post-survey opportunities.
I suppose you could say that I’m looking at this whole change from a “glass half full” perspective, but it’s not going to go away any time soon, so we might as well look at this as a positive development.