No plans for quick sand, meteors, or coffee running out

I have become rather reluctant, over time, to recommend that organizations develop too many event-specific disaster plans.

My best consultative advice is to focus on adoption and integration of an all-hazards approach to incident command (most folks seem to be going the HICS IV route). An adequately functional incident command process for your organization will serve you much better in the long run, as it is applicable regardless of the type of event.

Remember, the purpose, if you will, of an incident command structure is that you can respond appropriately to whatever emergency comes down the pike, regardless of its nature.

What are your thoughts about the costs of annual TB fit-testing?

So I see that OSHA–thanks to President Bush signing off on the federal budget–now has the ability to enforce its annual fit-testing requirements for tuberculosis (TB).

This one is going to have some hidden costs. The fact of the matter is, compliance even with initial fit-testing is certainly (based on my observations) inconsistent at best, so some folks are going to have to come at annual fit-testing basically from ground zero.

At any rate, it seems to me that somewhere in the regulatory language (maybe in the post-TB standard stuff) there was some sort of cost estimate that was fairly minimal. And, as I think about it, this isn’t even getting into the issue of fit-testing staff members who are going to be using PAPRs in the event of a decon event.

It’ll be interesting to see if OSHA actually goes after this with any gusto–could get ugly.

What do you think? Is this a big deal? You can click on the comment links below to post your thoughts.

EPA has issued ethylene oxide sterilizer rule

I’ve been seeing a fair amount of discussion about the EPA’s final rule on ethylene oxide sterilizers. I don’t have a chance right now to delve into thoughts about it, but wanted to post something just for your FYI.

The final rule applies to any existing or new hospital ethylene oxide sterilization facility that qualifies as an area source of hazardous air pollutant, according to the EPA.

To read the full rule, click here.

I know the folks at Briefings on Hospital Safety are working on a story about this development, so stay tuned.

Getting locked in the bathroom: A risk assessment awaits

I was discussing recently the idea of staff members’ ability to rescue patients who lock themselves in a bathroom. Ultimately, your plan in this regard revolves around a risk assessment.

Such an evaluation should be based on the configuration of the patient bathroom locks in your facility.

I can tell you that there are still surveyors that like to do the “I’m locked in the bathroom and having chest pains, how fast can you get me out” scenarios during visits to patient care areas.

From a strictly risk management perspective–as getting locked into a bathroom is an event that could be expected with some degree of certainty–it is incumbent upon the organization to ensure an appropriate response (including availability of whatever means is necessary to achieve emergent access).

Ban on TB fit-testing is now officially over

Hi everyone, it’s Scott Wallask checking in from HCPro.

It appears the dissolution of the annual tuberculosis fit-testing prohibition is now official, as President Bush signed the fiscal year 2008 budget for labor and health and human services in late December. A record of the bill–numbered H.R. 2764–indicates it is now public law.

OSHA’s budget falls under this bill. In prior years, it was within this area of the budget that you’d find the prohibition of OSHA enforcing annual TB fit-testing. But that prohibition isn’t in the current budget’s wording, which brings to an end a several-year ban on such fit-tests.

Let us know what you think by clicking the comments link below.

Thanks,

Scott Wallask

swallask@hcpro.com

Emergency prep–it’s more than just compliance

When thinking about recovery efforts from disasters, you should consider Joint Commission (formerly JCAHO) standards EC.4.13 through EC.4.18, aka the six “critical areas” of emergency management:

• Communication
• Resources and assets
• Safety and security
• Staff responsibilities
• Utilities management
• Patient clinical and support activities

A key component of this whole process is coming up with a prioritized approach based on your organization’s real-life challenges. Once you’ve established the priorities, then it’s just a question (OK, with a whole heck of a lot of grunt work) to come up with the plan for each event.

But remember, there may be events for which you’re not going to have to address each of the critical areas, so if you don’t have to do it, don’t feel like there’s some sort of obligation to do so. Your responsibility is to prepare your organization in an appropriate fashion–no more, no less.

And so, when it comes to survey time, take an organized, logical approach to whatever the issue at hand might be.

Ultimately, the acid test is whether you are comfortable that you have prepared the organization to the extent necessary. If you can look yourself in the mirror and say, “We’re in good shape”–knowing full well that perfection in this area is nothing but elusive–then your comfort and confidence will carry the day during survey.

Compliance during survey is way down the list of objectives for this process. Adequate preparation for emergencies is everything, and Joint Commission compliance is a happy byproduct.

A Joint Commission reference raises EC questions

There is a footnote in the proposed life safety standards relative to the manual transmission of alarms that references an issue of Environment of Care News, which is a Joint Commission newsletter.

Does this somehow introduce EC News into the realm of “enforceable” information sources? Or is it merely mentioned in the context of the draft and the mention will be removed when the chapter is finalized?

I find it curious that the reference cites the Joint Commission’s “policy on the manual transmission of fire alarm signals.” I can’t say that I’ve ever run across their “policy.” Is it in the Comprehensive Accreditation Manual for Hospitals? Has it been in Perspectives?

What the heck are they talking about?

Is the hole opening up for life safety citations?

You know, it occurred to me the other evening in the wee small hours that the separation of the Life Safety Code into its own accreditation chapter could have devastating results when it comes to counting RFIs towards conditional and preliminary denial.

Prior to this, life safety citations all rolled under EC.5.20 (with maybe slight diversions into EC.5.10). Now we’re looking at nine life safety standards to score.

Can you imagine if surveyors find stuff in a couple of different directions? You could be dead in the water at the end of day one–ouch, ouch, ouch!

Thumbs tacks, bulletin boards, and risk

I was corresponding with a plant operations manager recently about using thumb tacks on bulletin boards in patient care corridors.

Because there are no standards-based requirements for bulletin boards, you can pretty much do whatever you feel is a safe practice–which, of course, invokes the mighty risk assessment.

There are one or two concerns you might want to consider along the way:

• The likelihood that a person could use thumb tacks as weapons
• The possibility that someone could ingest the thumb tacks

Don’t just think of this in terms of suicidal patients–you might want to extend consideration beyond that patient population and include visitors. And how about pediatric patients? They might be an “at risk” population for mischief.

The other possible issue relates more to the amount of postings on the bulletin boards. Some surveyors have been known to pick on generously configured bulletin boards for increasing the combustible load. In fact, I’ve witnessed George Mills of The Joint Commission (formerly JCAHO) push the issue a little bit during a survey.

You may end up deciding that the best way to manage the whole thing is to have enclosed bulletin boards with some sort of security hardware. That way the tacks are out of harm’s way and the combustible load aspect becomes a non-issue.

A Crocs link many of you will want to see

Hi everyone -

It’s Scott Wallask checking in. I saw a posting on the listserv run by the Association for Professionals in Infection Control and Epidemiology, in which someone was kind enough to post a link to OSHA’s 2006 informal opinion about Crocs in healthcare settings.

As many of you know, few fashion concerns bring up a good ol’ fashioned debate as well as Crocs do. I actually saw a Crocs store in downtown Boston a few weekends ago.

Anyway, the OSHA posting isn’t official, nor is it a letter of interpretation, so take it for what it’s worth.

Happy holidays,

Scott W.

swallask@hcpro.com