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We know it will never be easy, but will it ever get easier?

It’s always interesting (and perhaps a bit thrilling) when an announcement comes flying over the transom from our friends in Chicago unveiling “modifications” to the Environment of Care (EC) survey process for healthcare occupancies (e.g., ASCs, hospitals, critical access hospitals), but this ended up being a little less breaking news and a little more of a good news/less-good news situation.

For quite some time now, I have mulled over the general thought that the EC interview session portion of the accreditation survey process really doesn’t yield a lot of findings. My sense of the session is that it’s more of an evaluation of group participation than anything else and it appears that others in a position to do something about it are in agreement, at least as a function of identifying survey vulnerabilities.

At any rate, The Joint Commission recently announced that the EC interview session is going away (good news) to provide more time for surveying in the field, including even more focus on EC stuff for the clinical surveyors during tracers (less-good news). I am certainly not worried about folks getting into “big” trouble during this extra hour of time, but it is another hour of wandering around that is likely to generate at least a few more “dings” in the physical environment.

As the Chicagoans continue to battle the forces of CMS in their pursuit of deemed status and reported shortfalls in the surveying of the physical environment, there is a certain inevitability at play here, so I guess we’ll have to wait and see. My immediate prediction is that there will be an increase in EC/Life Safety findings over the next little while (and perhaps a little while after that…).

Now, if they would only remove the requirements to maintain the safety, security, HazMat, fire, medical equipment, and utility systems management plans—I don’t think they generate very many findings and they really don’t serve any real operational purpose for healthcare organizations. Fire response plans and emergency response plans make sense to me, but the rest of it should be captured through the annual evaluation process. Is it really that big a “step” to go from evaluating effectiveness of the EC plans to evaluating the effectiveness of the EC programs in whole? Somehow I don’t think so…

Hope you are all well and staying safe!

You probably already know about this, but…the threats just keep on coming

Just when you thought 2020 couldn’t get any more dramatic (we even had an earthquake this morning in Southern New England—I don’t know that I had ever knowingly experienced one before), but a warning from the Feds regarding nefarious “actors” (I placed that in quotation marks as an homage to my friend, and former editor, Scott Wallask) attempting to target healthcare facilities, et al. I’m sure your IT folks are all over this, but I’m thinking that if you were looking for a non-COVID-related emergency response exercise scenario, evaluating your organization’s response to this latest threat might be worth a look-see. It will be interesting to see how this develops over time as a subtext to everything else that’s going on. If you’re looking for greater detail, I think you’ll find these links useful:

It seems unlikely that this will be the last time we hear about such attacks.

In other preparedness news, under the category of “other things that happen while you’re busy responding to a pandemic,” there was a “hard landing” of a helicopter on the roof of USC Keck Medical Center out in Los Angeles. Fortunately, no one was badly injured, but it just goes to show you that (and it seems particularly so this year) you never know what’s coming next.

Hope you all are well and staying safe!

Masking Tape/Taping Masks: Essential PPE is still in the mix…

As 2020 continues to roll along with no apparent respite from dealing with COVID on the horizon, it’s probably not a bad idea to share some PPE-related resources with folks. I suspect that pretty much no one out there in the studio audience has the time to bolt down the rabbit holes of the interweb, but here are a few links to some (hopefully) useful resources:

When it comes to PPE, it’s always important to keep an eye on the folks at the Occupational Safety & Health Administration, who have provided some guidance relative to the use of PAPRs for personal protection. It has the appearances of being somewhat flexible in certain instances, but enforcement is still enforcement, so if you’ve got PAPRs in the mix, worth checking out.

Next up, the good folks at ECRI have pulled together a number of PPE-related resources to ensure that we’re providing appropriate/effective PPE to those folks on the front lines who are at the greatest risks of occupational exposure. If you think all this stuff kind of sounds like a risk assessment opportunity, I would be inclined to agree. At some point (hopefully sooner rather than later), when move on to the new “new” normal, our regulatory friends are going to be curious to find out how we “knew” that we were adequately protecting folks and, since they’ve been rather reluctant to accept performance data without some sort of assessment framework, these should work well within the confines of the documented risk assessment process.

Here they are:

While shoe covers don’t really fall under the PPE category in general (though sometimes they can), for anyone who has ever struggled with putting on shoe covers before “bunnying up” to go in the OR, I thought this might be a good for the end-of-the-year holiday wish list (I know it’s on mine—as soon as they make one that’s portable), check out the Bootie Butler. I’ve only seen this item in a pharmacy clean ante room, but I found it intriguing.

As always, I hope this finds you well and staying safe. I figure every day brings us closer to the end of this (and I suppose there’s a certain inescapable logic to that). I hope…

Rollin’, rollin’, rollin’, keep those (fire) door-ies rollin’…

Just because I am fascinated by all sorts of stuff (and I suspect that, since you’re still with me on this, you might be interested in all sorts of stuff, too), I came across a blog post regarding the ins and outs (or perhaps the more appropriate description would be “ups and downs”) of rolling steel fire doors. To be honest, I had no real appreciation of the complexities of these devices, though I certainly l know that anything in their path once activated is likely get a pretty good bruising. That said, I think once you check out the components pieces, you will see that there’s much that can go astray from a mechanical standpoint and remains an important part of your fire door inspection, testing, and maintenance process.

As another example of interesting “stuff” is a product that can be used to protect sprinkled areas that do not have suspended ceilings. I don’t know that everyone is going to have a ton of use for such a product (I first encountered it at an airport terminal in which renovation activities had resulted in the removal of the suspended ceiling but they still needed to provide sprinkler protection), but since it is classified by UL to meet NFPA 13 (recognizing that even the tenets of NFPA 13 can be nudged in any directions by an AHJ), it might just make your life a little easier if you need it. At the very least, check out the short video to get a sense of the product—it’s pretty cool. And if anybody out there has used the product, I’d be keen to hear about your experiences, so please do.

Finally, since I’d hate to let a week go by without some regulatory folderol and hoo-hah, our friends in Chicago have announced some performance element changes for hospitals and other organizations having fluoroscopy services. The new requirements are supposed to be implemented starting January 1, 2021. In looking over the changes, I don’t know that this is of earth-shattering impact (no asteroid, this) but it’s probably worth checking out to ensure that you’re in compliance.

That’s it for this week. Hope you all are well and staying safe. On to November!

The Fountains of Youth and Water Management Programs

As a follow to last week’s item about water management programs, I know a lot of folks are not using their drinking fountains (or as we know them in the Boston areas, bubblers—pronounced “bubblahs”—I was hoping to find an audio link, but if you doubt the veracity of that pronunciation, this sort of backs it up). How are you managing those as a function of your water management program?  I’ve seen a lot of these devices sitting idle (and not just in healthcare) and looks like they may be sitting that way for a while. Are you periodically having someone go around to operate them or have you modified other practices to keep an eye on these? Not quite sure why it took me so long to think about this—perhaps it’s the ever-growing drinking fountains covered in plastic. The other question I had in this regard is whether any of you are using this as an opportunity to remove them completely? Depending on the design of your building, these are sometimes placed in a way that reduces the clear width of an egress pathway or two. This might be the best opportunity evah to get rid of them.

Of course, the other dynamic that comes into play (though perhaps less in healthcare than in other industries) is the whole notion of how to manage facilities that are experiencing reduced utilization. Perhaps you have a business office or the equivalent, and you have folks working remotely or some other variation on the theme of forced vacancy. If that’s the case (or could become the case if COVID persists), then you might find the following information worth checking. Fortunately, resources continue to provide guidance in this regard and I don’t think there’s anyone among us that would wish to endure a breakout of waterborne pathogens in the midst of the current climate.

Check out the following resources:

Hope all is well and you folks are staying safe. See you next time!

Madman Across the Water Management Program

This week brings us something of an unexpected development in the management of the physical environment as our friends in Chicago are seeking comments on a proposed standards revision that more clearly indicates the required elements for water management programs. I don’t know that I was expecting this change, though I suppose it falls under the “one outbreak is one too many” category, nor was I expecting the solicitation of commentary from the field (I look forward to seeing the results of the comment period). It would seem that the proposed performance element is based very closely on the CDC recommendations, which clearly take into consideration the guidance from ASHRAE 188 Legionellosis: Risk Management for Building Water Systems and ASHRAE 12 Managing the Risk of Legionellosis Associated with Building Water Systems, so it doesn’t appear that we’re breaking new ground here.

Additionally, we know from past discussions that CMS has been pretty focused on the risks associated with building water systems (most recently, here, but there are others), so this may be a case of ensuring that everyone is paying attention to the areas of (presumably) greatest risk. And, as near as I can tell, none of the existing COVID-related blanket waivers exempts folks from managing the risks associated with building water systems, so hopefully you’ve been staying with your identified frequencies for testing, etc. And if you haven’t, you probably should be identifying a game plan for ensuring that those risks are being appropriately managed.

Clearly, there’s a little time before these “changes” go into effect (the comment period ends November 16, 2020), but since this is pretty much what CMS has been looking for since 2017 or so, you want to have a solid foundation of compliance moving forward. I recognize with everything else going on at the moment, this might not be a priority, but this is one of those concerns in which proactivity will keep you out of compliance jail.

Until next time, hope you are all well and staying safe!

Is it really transparency if they have to catch you first?

A few months ago, I was working with a facility that, as it turns out, was experiencing challenges with managing temperature and humidity in some of their procedural areas. When I got to the space in question during the building tour, I took particular note of some portable dehumidifiers in a couple of the rooms (one of which hadn’t been emptied in enough time that water was pooling on the floor). In both rooms, the humidity level indicated on the monitoring devices in the rooms was in the 70+ range—a value most surveyors would consider a tad “moist” for a procedural area (my first thought was how high would the humidity be if they weren’t running additional dehumidifiers). At any rate, I asked to see the logs and found enough irregularities to ask to see the perioperative department director. I should mention that this was day four of a four-day consulting gig.

In meeting with the director, I was told that they were embracing full transparency in informing me that they had been experiencing environmental issues in this space for quite some time. My immediate response (which, I will admit, was a bit catty) was: “Is it really transparency if you only tell me after I’ve identified the issue?” I know that sometimes folks like to leave things to see if I can find them (or see if I remember something from the last time I was there) and I think I have a pretty good track record of identifying the various and sundry gaps that can make a good survey go bad in a hurry. But this one really caught me sideways (and continues to) relative to the transparency thing. As I’ve maintained is the case for managing garden variety deficiencies; if folks have to go look for things to fix that have already been identified, it doesn’t strike me as particularly efficient, but that may just be me…

In other news, our friends from Chicago recently published a piece penned by Herman McKenzie, the director of the engineering group at The Joint Commission (TJC); in the piece, Mr. McKenzie provides some insight into what FAQs have been updated, as well as some common concerns in the physical environment. I don’t know if we’ll be seeing Mr. McKenzie as a featured contributor to Perspectives, but hopefully this represents the re-commencement of regular information regarding TJC’s expectations in the physical environment. Generally, September/October is round about the time we hear about the most frequently cited standards during the first half of the year, but I guess that schedule (like pretty much everything else) has been knocked on its keister. At any rate, this link will take you to what’s current (I hesitate to say “new”, just because) in the management of the environment.

Until next time, please be well and stay safe!

Fall protection in all seasons

This week’s missive is something more of a “bite” than the usual multi-course jabbering, but I think you may find this of interest.

I’ve found that sometimes it’s difficult to explain to folks why we, as safety professionals, insist on certain things, like fall protection and appropriate storage of compressed gas cylinders. I think we all understand that the “right thing” to do is not always the most convenient and sometimes folks cut a corner or two. And a lot of times, we only find the (more or less) near misses in that we identify the noncompliant condition or practice after the deed has been done (so to speak) and the involved individual(s) have fled the scene, making a legitimate root cause analysis of the failure in process a very difficult thing to accomplish. The example that springs most quickly to mind is the improperly secured compressed gas cylinder—primarily the one standing in the corner of a utility room. Now, it is true that this doesn’t happen very often in hospitals (or if it is, nobody is talking about it), but I think it is helpful to “share” with those folks that seem more prone to leaving cylinders hanging around some footage of what can happen.

And, in recognition that it doesn’t take great heights (or wuthering heights, but that’s a whole ’nother kettle of fish) to provide the backdrop for some serious injury potential. When it’s time to remind folks of the dangers of working without appropriate fall protection, you might find this video useful. Much like the driver education videos of yore (and maybe still today), the results can be quite graphic. It’s not a short video, but there is a lot of good, potentially dissuasive, information about falls and the importance of protection.

That’s it for this week. I hope you all continue to be well and are staying safe!

At what point does an emergency response activation become the ‘new normal’?

As we approach the “end” of 2020 (and holding on to the hope that 2020 won’t find a way to persist into next year), I was pondering the question of how one might meet the requirement for a second emergency response activation if one did not have the extraordinary foresight to plan and conduct an exercise before the wheels fell off the world back in March. My thought was that the complexities of the current situation (and the onset of the “flu season”) might give you enough variation to parse the current response (certainly we are not in the same “place” as we were back in the spring) into two evaluations (making sure that we are accounting for an evaluation of the critical response elements: communications, resources and assets, staff roles and responsibilities, safety and security, utility systems, patient care). I suppose one could also “leverage” the update of your hazard vulnerability analysis (HVA)—if you have had a spare moment to do so. As I recall, everyone had pandemic on their HVA, with varying degrees of presumed preparedness. It will be interesting/instructive to see how well your previous analysis matched up with how your organization has fared thus far. It is certainly within the realm of improvement to evaluate current response activities in terms of lessons learned over the past few months (and extrapolating into the next few months).

One glimmer of hope for organizations that are accredited by The Joint Commission is a note attached to the drill requirements that indicates that organizations are exempt from engaging in their next full scale exercise following the onset of the emergency event. My “read” is that (and I believe that this applies for as long as the presidential declaration is in place) folks are allowed to focus their attentions on managing the emergency at hand as opposed to having to come with something else (new, different, etc.) to exercise. I hope to get some confirmation of this over the next little while, but I’d be interested to hear from anyone that has undergone recent survey—my hope is for some flexibility on this count—in full recognition that flexibility has not necessarily been the hallmark of the survey process of late.

At any rate, as this whole megillah had a beginning (and is certainly having a middle), hopefully it will have an end that results in a return to the “old normal.”

Hope you are all well and staying safe. Please stay in touch as you can!

The impossible year continues: Emergency response in 2020

Interestingly enough, I don’t believe that I have a great deal of yammering to do this week; not sure if it’s just a case of mental fatigue with all that continues to transpire (or I daresay, escalate) in terms of community emergencies of virtually every and any imaginable kind. Just between COVID-19 and a typical hurricane season, it would have been an adventure of epic proportions, but perhaps a wee bit more manageable than the various forces assailing the planet. But no, what in the past had tended to be rather transient in nature has now turned towards an aggregation of conditions that rivals…certainly nothing in recent memory and perhaps not ever (the Dark Ages, maybe).

One of the positive byproducts of such a year as this is the ongoing development and promulgation of resources – I have maintained, and will continue to do so, that hospitals are generally pretty well prepared to deal with “stuff.” As I see it, the whole point of preparedness is to be able to manage circumstances (be they singular or plural) without “breaking” (by breaking, I mean a catastrophic failure of response such that folks are actually placed in unprotected risk because of the break, as opposed to facing a situation in which hospital operations would need to be altered, moved, etc.). There are no perfect organizations when it comes to this, which is as it should be—but that doesn’t mean that folks are content to rest on past experiences, but rather to build on those experiences and make improvements. The magnitude of events this year has tested the healthcare industry in ways that would only have been predicted as a hyperbolic planning exercise (this year has been a whole lot of “and then this happens”). As has been the case any number of times in the past, hospitals and other healthcare organizations have had to manage things on their own and/or with community partners as the upper levels of the response infrastructure have been less effective than might have been desired (not pointing any fingers—this is not the first time, nor is it likely to be the last time that the most effective response happens at the local level).

At any rate, there are a few resources that I’ve noted over the past couple of weeks that I wanted to share. I somehow doubt that you’ll have a lot of spare time with which to review written materials, but I’m thinking that at least the links to these materials will be in a place you can “find” again. Lots of stuff here, a lot of it coming out of the response to wildfires in California, but as a primer for relocation, establishing alternative care sites, etc., there is much that is applicable to any untenable emergency condition:

As always, I hope this finds you safe and in reasonable sanity. I would like to think that we’ve got more of this behind us than in front of us, but the numbers are frowning at me, so I will just hold that hope…until next time!