RSSRecent Articles

If there weren’t challenges…

…it really wouldn’t be an event that requires emergency response.

Somehow over the last little while, the fundamental nature of what constitutes an emergency and, even more importantly, what an appropriate response looks like, appears to have morphed over time. Now we seem to embrace the expectation that whatever happens, hospitals are going to be right on top of things (in a way that, frankly, doesn’t seem to apply to them that would sit in judgment, but that might be something of an editorial comment). But really, can you imagine what would have happened a year ago when pretty much everybody else was working from home, suspending normal operations, etc. (in full recognition that healthcare facilities don’t have the option of opting out of such things)? Now a lot of folks (and no, I’m not going to name names—if you don’t know, then it’s probably just as well) are playing catch-up and generating a wee bit of chaos as they get back to it. Happy happy, joy joy!

At any rate, I do hope that all the surveyors out there kicking the EM tires are paying close attention to some of the information contained in the CMS updates to the emergency preparedness requirements, including:

  • It’s OK for your response process to be the same for multiple risks/hazards
  • Your HVA/program must address each type of hazard, but your policies and procedures can indeed be consolidated (can you imagine how many binders you would need?!?)
  • It is not the job of the surveyor to analyze the appropriateness of the identified risks; their job is to make sure that your program (including policies and procedures) align with your risk assessments (speaking of your risk assessments, they must be demonstrably facility-based/community-based and they must include staffing considerations; emerging infectious disease planning must be in the mix—no surprise there)
  • It is OK (and certainly much more effective) to have each organization’s EM person “show” the requested elements as opposed to surveyor “browsing” of the plan, etc. (the CMS guidance encourages the use of crosswalks to more quickly/readily identify where the component pieces “live”)
  • It is also OK to have your documentation in whatever format makes sense: hard copy, electronic, etc.

I think these are fairly representative of a common-sense approach to surveying compliance with the EM standards; I guess we’ll see how things unfold in the field…

Just a few odds and ends to wrap things up:

  • They encourage the use of the ASPR-TRACIE checklists; lots of good stuff there and well worth poking around and discovering.
  • Emergency power—you have to have what is required by the Life Safety Code® (LSC)/COP for your facility; but please remember that any additional emergency power considerations must be maintained in accordance with the LSC (and, by extension, NFPA 110 et al). I think some folks have this sense that anything not required by the LSC/110 combo can be maintained in whatever fashion they like. This seems to be drawing a line in the sand that they’re not buying it (again, I guess we’ll see what happens in the field—maybe anything that is not LSC-related isn’t offered up for scrutiny); also, they do not allow extension cords to directly connected to generators; generator must interface with facility through transfer system.
  • Functional exercises, mock disaster drills and workshops can be used to count towards the activation requirements (by the way, long-term care facilities are on the hook for annual education; everyone else can go with biannual).
  • Inpatient facilities need to have two years of documentation present; outpatient facilities have to have four years available.
  • Emergency plans are expected to evolve (mutate?) over the course of a long-term event (and I think we know a little something about that…), your plan should include provisions for monitoring guidance from public health.
  • Your plan must include provisions for tracking staff when electronic payroll systems, etc., not available—for example, power outages, etc. consider check-in procedures for on-duty and off-duty staff.
  • Your plan must include a process for communicating with the various AHJS (and, boy howdy, aren’t there an awful lot of those kicking around); as well as provisions for surge planning. As for staffing, while the use of volunteers is optional, there is an expectation that you will have a process for managing them. Over the years, I’ve run into any number of folks that were not at all inclined to deal with volunteer practitioners, but I think the days when that was a reasonable decision point are rapidly fading into the distance.
  • Your plan must also include a process for evacuating patients that refuse to do so; I figure there must be some empirical information that drove the inclusion of this in the guidance. I’m presuming that you have a process already for dealing with recalcitrant individuals, including patients, so I don’t know that this breaks any ground.

Now that I’ve finished typing this, I really don’t see a lot that I would considering troubling or, indeed, troublesome. I would imagine that a lot of this stuff has become rather more hard-wired than not over the past 15 months or so, if it were not already. I think there were a lot of common lessons learned, though the “equation” for “solving” the challenges is probably unique to every organization (unless you’re part of a system in which the facilities are virtually identical). From a compliance standpoint, I think you folks should be OK, but please reach out if you feel otherwise.

So, with June bearing down on us, I trust that you all continue to be well and are staying safe. See you next week!

Take me to your leaders…

I believe that we’ll be able to wrap up the emergency management stuff next week—though I have one or two ideas percolating that I might move to the front of the queue, but certainly before May gives way to June (unless something really interesting pops up out of nowhere…).

With our friends from Chicago returning to the playing field, there was some discussion of a modification to the session with organizational leadership, primarily involving moving the session to the opening of the survey and to have that session focus on leadership’s involvement with response to the pandemic over the last little while. The exact rationale for this strategy (which has since, more or less, gone away) kind of escapes me because I really don’t think the last 12-15 months could have been successfully navigated without some level of interest/action/participation, etc., on the part of hospital leadership teams pretty much everywhere on the globe. That said, I do suspect that the level of interest in all things emergency preparedness have probably not been as widely appreciated as they are right now (soon we will chat about making the most of this moment—but that’s for another day).

At any rate, with the unveiling of the new guidance (I don’t know that there’s necessarily anything “new” that’s going to come out of any of this, but I guess we’ll have to see, but this seems more like a recapitulation or codification than it does a significant change), there continues to be a concerted aim towards clarifying the necessity of organizational leadership participating in the emergency preparedness activities as a baseline expectation (an expectation I think we’ve all shared, yes?). Again, from a practical standpoint, your hospital, in all likelihood, would not have endured the last little while without the active participation/interest/whatever you care to call it from your leadership group. If someone managed to do so (and that doesn’t mean in spite of their participation), I’m keen to hear that story. But in the infinite wisdom of the regulatory monarchy, the following topics of conversation could be raised during any survey event in which leaders are queried about their EM roles:

  • How did the organization encourage collaborations with the available coalitions (local/regional/state: remembering that community partners are defined by each organization)?
  • How did the organization prepare for and manage staffing?
  • How did the organization prepare for and manage evacuation (including planning for the evacuation of patients that do not wish to be evacuated)?
  • How did the organization ensure that communications are collaborative and align with the methods/structures, etc., of the AHJs in the mix?
  • How did the organization promote participation in exercises and engage in the after action report process?
  • How did the organization ensure ongoing preparedness in the face of changes/shifts in community or other partners?
  • How did the organization identify what services would be provided under what circumstances?
  • How did the organization align continuity of operations and business continuity (we’ve had plenty of opportunity to look at this, I would think)?
  • How did the organization effectively manage the delegation of authority, including succession planning considerations?

In almost any other point in modern history, it might have proven to be somewhat burdensome to bring leaders up to speed in advance of a survey, but I can’t imagine that there are too many leadership groups out there that wouldn’t have more than enough practical experience (even if they never completed IS-100 and IS-200). Going forward, I think it’s going to be really helpful to keep the last year in everyone’s heads as a function of how we manage preparedness. It’s not just about regulatory compliance—it’s ensuring that providing care in a safe setting continues to be the number one priority of emergency response.

Hope you all are healthy and staying safe. Somehow I get the sense that we’re not quite done with this (though I would be more than happy to be proven incorrect in that sense), but we will prevail! See you next week!

You better? You bet!

It would seem that while the rest of the world has been busy responding to a pandemic, the folks behind the scenes have been working on identifying the lessons learned and memorializing them in an update to Appendix Z. At first glance, it seemed that this was more a codification of past updates, but as a I looked through the thing in its entirety, it does seem like the changes are more significant/substantive than I thought. That said, I do think that much of the updated material is aimed at helping surveyors to understand what is (and what is not) actually required and that, as with everything in our world, customization of approaches, etc., is not only desirable, but is really the only way to “roll” when it comes to appropriately preparing to respond to an(y) emergency. I suppose one could make the case that, after all of this hoo-hah of the past year-plus, if we’ve not managed to improve our preparedness, then what exactly have we been doing?

Part of the dynamic I keep coming back to with all this is if it were “business as usual,” then it wouldn’t be an emergency. And one of the defining aspects of an emergency is that it tends to push the normal limits of an organization. I remember the hue and cry that went out immediately following Superstorm Sandy’s trek up the East Coast regarding the level of hospital preparedness—because people struggled at the outset. But when the final report from CMS was issued, it turned out that hospitals generally did what they had to do to keep patients and staff safe.

As we look back at the past 18 months or so, I suspect that each organization within the sound of my voice is better prepared than previously for managing the impact of a long-term pandemic event. I also suspect that there have been any number of improvement opportunities identified and I am hopeful that, among other things, your organizational leadership has gained a greater appreciation for emergency preparedness as a proactive undertaking (recognizing that response is typically characterized by reactivity). The truth of the matter is this: while emergency preparedness does not, in and of itself, generate revenue. Effective emergency preparedness allows an organization to continue generating revenue while the feces is striking the rapidly rotating blades—and that makes all the difference in the world.

I suspect that this is going to take a couple of sessions to work through some of the subtleties of the updates, so I would encourage you to start chipping away at this as wander through the very merry month of May. There is a lot of material to digest and while I don’t see anything that’s making me crazy from a survey prep standpoint, I’ll let you be the judge of how that shakes out—at least for the moment.

Before I close out this week’s chat, I did want to tip you to one resource that I think will be really helpful. One of the more painful aspects of the Emergency Preparedness Final Rule has been that the official document that is Appendix Z is designed to include the requirements for all provider types, which makes an already complex set of rules that much more confusing. But someone (bless them, whoever they are) worked to peel out the requirements for each provider type, so if you’re not a “regular” hospital or you have operational responsibilities for more than one provider type, you can find the specifics for each here. There are other resources as well, but just having the requirements by provider type is (at least to me) crazy wonderful—and I hope you think so too.

Next week, we’ll chat about some of the ways in which organizational leaders are going to be looped into this on an ongoing basis—if that doesn’t sound like fun…

Risk assessments: Don’t leave home without one!

An interesting phenomenon I’ve been encountering of late relates to the whole notion of having to do environmental risk assessments in locations that are not specifically designated for the management of behavioral health patients. At this point, I don’t know of any healthcare organizations that would be able to say that they would not be managing behavioral health patients, even if they don’t have inpatient bed capacity, though I suppose you might be able to set up a transfer policy with another local organization that does have inpatient capacity. But those beds are typically in fairly sort supply and might well end up with having to “hold” a behavioral health patient for a prolonged period of time. Maybe you can manage that continuum in your ED, but what if you had a surge of, hmmm, let’s say infectious patients. Is there a possibility that a behavioral health patient could end up on an inpatient unit? And could you say absolutely in either direction without having a risk assessment in your back pocket?

So you could make the case that moving the environmental concerns relating to behavioral health patients from the Environment of Care standards to the National Patient Safety Goals section of the accreditation program has clarified (to a degree) the expectations relative to the management of at-risk patients, but that clarity brings with it some mandates. The mandate comes in three pieces (so to speak): a thoughtful evaluation of the environment; a plan; and available resources to guide staff when you have to put at-risk patients in an environment that is not designated for managing that type of patient.

To my eyes and ears, a thoughtful evaluation of the environment sounds an awful lot like a risk assessment; the FAQ goes on to describe some examples of resources that could be provided to staff, including the use of an on-site psych professional to complete the environmental risk assessment if staff are not sufficiently competent to do so. Which means that, if you do use in-house staff, you might be pushed to identify how you know that the folks doing the evaluation of the space immediately before a patient is placed are competent to do so. Though I suppose that also means you might have to demonstrate how you evaluated the on-site psych person… ah, it never really ends, does it?

At any rate, if you have not done a quick (but thoughtful—gotta be thoughtful!) risk assessment of your non-BH patient spaces, it’s almost certainly worth your time to do so. To my mind, the best risk assessment of all is the one they don’t ask for because the effectiveness of the process is in evidence. But sometimes we don’t get credit for “doing the math in your head,” so the possession of the risk assessment is your best bet.

Thanks for tuning in. Please be well and continue to stay safe. Until next time…

Will meeting in person ever come back?

And perhaps more importantly: Does it make a difference?

As I’ve been working with folks over the past few months, it’s been kind of interesting to see how much impact social distancing and its component elements have had on the management of the care environment, at least from an oversight standpoint. Folks have been able to keep their eye on the prize for the most part, but it’s tough to figure out how effective meetings are when participation and other more traditional metrics are almost impossible to determine, never mind measure. For you folks out there reading this: Has this been something discussed during meetings, included in annual evaluations, or have you kept your head down and plowed through the past year (I suspect there’s a fair amount of plowing)? COVID has been such an attention-seeker in so many ways and remains the center of attention for so many folks—it seems impossible to think that we won’t be unraveling things for quite some time to come.

Turning to the May edition of Perspectives, it’s interesting to note that our friends from Chicago say they managed to conduct over 1,100 surveys in hospitals during 2021 (Does that means 1,100 hospitals were surveyed? Somehow, I’m thinking not). What is also interesting is that the presentation of the survey findings data has taken something of a turn in that the focus is not only on specific performance elements, but also on those findings that generate the findings of greatest survey criticality (read: adverse survey decisions). From looking at the hospital data, it appears that only a couple of findings of immediate threat to health/life were in the mix (mostly relating to the management of patients with suicidal ideation, though there was on related to infection control), but it would seem that there are a whole bunch of findings in the “red” (the highest risk category in the matrix). By my reckoning, now that the physical environment is not occupying all the top spots, the hot spots for high risk in the care environment are ventilation, safe, clean areas for patients, and the management of chemical risks (hmmm, could that be a euphemism for eyewash stations?), with a side order of whatever relates to infection control concerns like high-level disinfection and the management of patient care equipment.

I don’t know that there’s anything that is particularly shocking about the slate of focus areas; that said, it will be interesting to see how findings shift (or not) now that the onsite surveys are back on line with the intent of poking around more in the outpatient settings. As an indicator, can we intuit anything from the Ambulatory Care Top 10? Indeed, I think there is—and that “anything” is anything in the environment that has an impact on infection control—disinfection, ventilation, cleanliness, ITM of sterilizing equipment. The common themes do emerge without too much scrutiny.

I think we know what we have and I think we know where they are going with all of this, though it makes me sad that loaded sprinkler heads won’t be at the top of the list. Although I suspect that it will remain among the most frequently cited single conditions; how could it not?

So, that’s this week’s missive. I hope you all continue to be well and are working to stay safe. If you’re finally thinking about embracing travel, please take measures to protect yourself. I’m seeing a lot of variation when it comes to masking, but I can’t tell who has been vaccinated and who hasn’t (unless everyone starts wearing a t-shirt…).

Be well and I’ll be back at you next week, which, if my calendar is correct, will be May. Who’d a thunk it?

Water is wet: How about your ORs?

Howdy folks, as our friends from Chicago return to the field, a couple of items have come to my attention that I felt were worth sharing. There’s also an updated resource that we’ve mentioned in the past (though it seems that there are always many things that we’ve mentioned in the past—go figure).

First up, as we know from our diligent perusal of the intricacies of NFPA 99, Section 6.3.2.2.8.4 indicates that “(o)perating rooms shall be considered to be a wet procedure location, unless a risk assessment conducted by the health care governing body determines otherwise.” Consequently, the Life Safety surveyors are asking to see the risk assessment that determined otherwise or validation that your ORs are appropriately protected in accordance with the requirements for wet locations (isolated power, etc.). In previous discussions, I did note that “health care governing body” would seem to indicate that the assessment needs to include, at least to some degree—it doesn’t specify—hospital leadership. My general thought is that if your ORs aren’t considered wet locations and weren’t designed that way, you should be able to use the initial design/build aspect of the ORs to represent an assessment of those risks and, nominally, as construction activity, would have involved hospital leadership. I guess that then begs the question of how often you would need to revisit the assessment. It might be a(nother) good use of the annual evaluation process; I’m a big fan of using that process to “plant” things where you know they are likely to be viewed during survey. Much as the comments section of the eSOC is a good place to memorialize waivers, equivalencies, and the like, the annual evaluation is a good place to revisit important historical decisions. At any rate, it appears that wet locations are high on the “ask list,” so be prepared.

Another consideration that appears to be on the table is a risk assessment regarding what type(s) of fire extinguishers are in your ORs (could surgical fire management be a theme?). Our friends from the Windy City have something to say about this, and it appears that there was a recent update (though what got updated is not immediately apparent) to the FAQ, so probably worth a visit. I don’t doubt that these elements came into play when extinguishers were first chosen, but (again!) it never hurts to review…

Lastly this week, while this hasn’t necessarily been a survey hot topic, somehow it feels like water management programs are going to start to become more heavily surveyed. I think we can agree that this is a significant risk to be managed and while there is minimal evidence that these risks are not being appropriately managed in U.S. hospitals, any time something “new” comes along, it tends to represent a shift in survey focus. In the past, I’ve recommended checking out Matt Freije’s work at HC Info for really useful information on water management concerns. He does a great job of keeping an eye on water management across the globe, but also keeps an eye on our friends. If you’ve not settled into a water management program yet (and you really do need to get on it), it is definitely worth checking out the HC Info website.

On that note, I will bid you adieu for now; hope you all are doing well and staying safe. See you next week!

The trouble with normal?

It always gets worse!

While I can’t say with absolute certainty, it seems likely that I’ll be employing relatively brief missives over the next couple of weeks as we do seem to be shifting gears a bit as far as the “return to normal.” As I write this, it’s been a couple of weeks since my last air travel and (based solely on my own observations) I have every reason to think that the COVID surge being reported is going to be a disruptive factor—I am hoping that this is the last wave before we reach safe harbor, but I’m not just seeing noses in enclosed public spaces, I’m seeing lots of full faces. I received my second dose of the vaccine about 10 days ago, but I’m going to keep masking up for the foreseeable future when I’m traveling. I will be happy to be proven that it was more than I needed to do, but I’m still waiting on the data…

So, just a couple of resource items for moving into the next phase of normalcy. First up, I was always (OK, since last June) surprised by the variability of screening practices and that surprise continues today. But if you want to get a sense of what I’m seeing in the field, this would be a good starting point. I don’t know that there’s a whole lot of data regarding how effectively screening helped stem the tide of COVID or even how often cases were identified through that process, but maybe someday there will be some sense.

Another element for consideration is visiting folks in nursing homes and other care facilities. I don’t think there’s anyone who would argue that there has been a significant emotional toll since the onset of COVID, which, I suppose has given the powers that be a fair amount of time to come up with how to transition safely on the visitation front. In September 2020, CMS issued some guidance in that regard and, a few weeks ago, updated that guidance in light of vaccinations, etc. Again, if we get another spike, this might be the best we get for a while, but at least it’s something…

And that, as they say, is that—at least for this week. Who knows what might come flying out of nowhere to create havoc, so stay tuned.

Be well and stay safe. Every day brings us a little closer to the end of this thing!

Forever in debt to your priceless advice…

Continuing on with our discussions of the unusually revelatory April issue of Perspectives, we shall now turn to the life safety-related items, starting with the sweetness of suites (though this may result in some tart-y findings).

One of the most anticipated elements related to the adoption of the 2012 edition of NFPA 101 Life Safety Code® was the full-on acknowledgement of suites. One of things I still find curious/amusing about the whole suite designation thing is there have classically been any number of patient (and other) spaces in healthcare that were clearly designed within the suite concept—even going back to design elements present in the ’70s (yes, I am that old—the ED in the first hospital in which I worked was an area of open patient “positions” with, I think, a trauma room that had a door). The postanesthesia care units (PACU) is the example that springs most quickly to mind—I don’t know that there was ever a time when PACUs were subdivided into individual rooms. From an operational standpoint, the design of a suite makes perfect sense for such care locations. Another area that was frequently “suite-ified” was the critical care unit, though those often had doors, but not necessarily doors that positively latched.

At any rate, one of the primary clear benefits of the suite design is the subtle shifting of “corridors” into “communicating spaces” (and now, as indicated in the April Perspectives, “aisles”), allowing for a fair amount of operational flexibility when it comes to the management of equipment, supplies, etc.  I guess there is something of a quandary when it comes to how much of this information is shared with staff at point of care/point of service—mostly based on the “if you give them an inch…” logical fallacy (more info on that sequence can be found with a web search; I wouldn’t advise it, though, as it is rather a rabbit hole). At any rate, the latest issue of Perspectives is (more or less) throwing down the survey gauntlet when it comes to clear width of spaces within a suite, invoking NFPA 101-2012 7.3.4.1(2), which sets a minimum width of egress at 36 inches in all facilities or portions of facilities classified as a healthcare occupancy. Soooooo, any spaces in which there are fewer than 36 inches of clear width are probably going to be cited; my gut instinct tells me that this will be most relevant to emergency department spaces, where the activities of the day tend to lean towards more blurry lines when it comes to egress paths. The other thought that popped into my head, based on the “portions of facilities classified as a health care occupancy,” is that there may be some patient rooms that might not make the 36 inches between the foot of the bed and the adjacent wall. That may not be an issue, but in my mind’s eye, I can see some tight squeezes…

The other life safety-related item in the April Perspectives deals with the (perhaps final) curtain call for the Building Maintenance Program (BMP) strategy for maintaining certain life safety components. While I can’t necessarily refer to the BMP as an anachronism, it’s been more than a decade since there was an particular survey benefit, though I believe—at least it was the last time I was able to look—the electronic Basic Building Information does include a question asking if the organization is using a BMP. Is anybody willing to hop on their TJC portal to see if the question is still there? That said, I don’t think CMS ever really accepted the concept of the BMP as an alternative means for managing life safety deficiencies (much as the PFI process was eventually kicked to the curb). I just checked the JCR portal for the standards manuals, and the BMP entry is still there, so I guess it’s taking a couple of bows before the curtain comes down for good.

As always, I trust that you all are well and staying safe. I just received my second dose of the vaccine the other day, so hopefully this will make traveling a simpler proposition. I guess every day brings us another day closer, so let’s keep the party going!

You gotta keep one eye looking over your shoulder…

And so with the onset of Spring, our friends in Chicago are laying out some more fun stuff to deal with over the next 12-18 months. In looking at the April edition of Perspectives, I don’t know that there’s anything I would call a surprise, though I suppose one of the announcements (pronouncements?) might prove to be problematic over the long haul (the “free pass” one sometimes receives for questionable practices in areas designated as suites might be harder to come by, but I think we’ll chat about that next week). But then again, if you have an effective survey management strategy, perhaps not; at worst, probably something to practice…

First up, effective January 2022, we have something of a shift in the requirements for water management programs—a shift to the extent that they done birthed a new standard just for water management. We’ve chatted about this topic in the past will take you to everything from last October back to the very beginning of time (or so it seems), so anyone who has been paying attention, particularly to the CMS stand on such matters, should be in reasonable shape. Here’s what you need:

  • A program/plan for managing waterborne pathogens, including Legionella
  • The identity of the individual or team charged with the responsibility for the program/plan
  • A basic diagram of your water system, including all water supply sources, treatment systems, processing steps, control measures, and end-use points (that will be a lengthy list for most folks—hope you’ve started that)
  • Documentation of testing/monitoring activities; corrective actions and procedures when your testing/monitoring results are outside of acceptable limits; documentation of corrective actions when control limits are not maintained
  • Review of the program at least annually, including any time there’s a modification to the water system than could add risk, including new equipment or systems

To my eye (and mind), I don’t see anything here that has not already been in the mix and, to be honest, if you haven’t been working through this process, you may be running the risk of bad survey mojo, particularly if the survey is the result of a waterborne pathogen outbreak at your facility. Again, this one isn’t giving me any fits as I look at the details, but we can probably intuit that they’ll be kicking the water management tires a little more frequently (and perhaps with greater vigor).

As we close out this week’s epistle, I wanted to share with you a resource aimed at assisting folks in hospitals with creating programs for sustainable energy use. As we edge ever closer to whatever the “new normal” is going to represent, I have no reason to think that managing energy costs/expenses will fall by the wayside. If you’re starting to look at energy sustainability, this might be right up your alley.

Next week, we’ll talk about communicating spaces in suites and bid adieu (yet again) to the Building Maintenance Program, so until next time, I hope you continue to be well and stay safe!

It’s these little things, they can pull you under…

I guess this week’s entry (as it appears that Spring is actually going to spring) falls into the “a little bit of this, a little bit of that” category; nothing monumentally earth-shattering, but (hopefully) useful.

First up, a recent post from the American Society of Health Care Engineering’s (ASHE) YouTube channel (somehow, it escaped me that such a thing existed—shame on me!) popped up on some feed somewhere (it may have been LinkedIn, but I can’t say for sure) and I found it a very interesting topic of conversation: “The Cost of No.” Given the givens, I suspect there are not too many in the audience who haven’t been at the receiving end of a “no” response (as opposed to no response, which is equally frustrating), and this video may give you some food for thought in how best to manage that impregnable wall. It’s not often that we get what we want, when we want, but I think the video offers some insight into how to plead a better case—to the point that it might increase the chances for a positive response “next time.” The video is pretty short (you can spare 158 seconds, can’t you?) and there are a number of other short videos that are worth checking out, so don’t forget to subscribe. You can start with “No” right here, but please check out the other stuff as well.

Moving on, in a designation that doesn’t seem to have been influenced by Hallmark, March is National Ladder Safety Month (I would have sent a card, but couldn’t even find a birthday card with a ladder that could have been repurposed) and I think we can all agree that ladders are an important part of the compliance picture. I’ll let you find your own “ladder unsafety” images—there are more than I can count, but I think we can also agree that the safe use of ladders could be more thoroughly hardwired into a lot of folks’ practice, including inspecting the ladders before use.

At any rate, I encourage you to set up a ladder safety session for your folks, particularly if you haven’t done so in a while – and what better month to do so. Here are some resources to help ensure folks embrace the heights of safety:

Until next week, hope you are well and staying safe. We’ve made it this far and I am confident we can make it through this together!