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You might find this week’s post somewhat shocking!

One of the survey findings that I’ve noted as trending towards a standard “gotcha” (primarily during state surveys) relates to the topic of arc flash safety and, most particularly, to the labeling of your electrical panels. Generally speaking, much of this stuff is covered by NFPA 70E-2012 Standard for Electrical Safety in the Workplace, with the labeling requirements (section 130.5 (C)) being: “electrical equipment such as switchboards, panelboards, industrial control panels, meter socket enclosures, and motor control centers that are in other than dwelling units, and are likely to require examination, adjustment, servicing, or maintenance while energized” to be field marked with a label containing all the following information: (1) at least one of the following: a. Available incident energy and the corresponding working distance; b. minimum arc rating of clothing; c. required level of PPE; d. highest hazard/risk category (HRC) for the equipment; (2) nominal system voltage; (3) Arc flash boundary. NFPA 70E also requires the method of calculating and data to support the information on the label to be documented.

I know we tend to focus on hospital-specific safety concerns in this forum, but findings relating to the absence of arc flash safety labeling have surfaced enough (at least to my mind) to make it worth a mention. Part of my concern in this regard is that I see a fair number of electrical panels, etc., for which there is no arc flash safety labeling and, as near as I can tell, there appear to be no provisions for “grandfathering” existing non-compliant conditions. So you may want to take a look at your electrical panels and any other energized equipment that are “likely to require examination, adjustment, servicing, or maintenance while energized.”

And, while we’re on the subject, EC & M has a very nicely crafted presentation on arc flash safety and compliance; you’ll probably have to pony up an e-mail contact in exchange for a viewing, but I found the content to be fairly illuminating (and yes, that was a pretty gosh-darn hideous pun). Visit their site to find this info (and some other stuff as well).

The place of working dangerously: The importance of kitchen safety

Recently, I fielded a question regarding fire response plans for food services and got me to thinking about the importance (and challenges) of good safety practices in the kitchen.

My firm belief has always been that,  for all intents and purposes, the kitchen is among the most “dangerous” locations in the hospital (when you think of pretty much all the classic safety “risks”, the kitchen has them—fire, slips, trips, cuts, chemical exposures, etc.) and also possesses among the most (if not the most) transient work forces in healthcare. Add to that the frequency of the entry-level folks being new not only to healthcare, but sometimes the working world, success really rests on the effectiveness of education, from the point of onboarding through regular department education, including the conduction of fire drills.

In poking around on the web, I came across some information provided by the Lafayette (Indiana) Fire Department relative to commercial kitchen fire safety that I think is well worth checking out for some cues in how to work with the Food & Nutrition folks to ensure the education process is all that it can be. I have noticed over the years (my wife is a big fan of cooking shows) that the celebrity chefs don’t focus as much on fire safety as they do on food safety (though I suspect Gordon Ramsey might have a few choice words if one of his restaurants had a fire). And I also know that some of the key components of fire response in a kitchen is a little counter-intuitive relative to how folks are trained in general, particularly the activation of the suppression system before one tries to use an extinguisher. I think these folks deserve a fair amount of focused support and the information contained here. It really provides you with a good road map for ensuring that your kitchen areas are as safe as they can be.

2020 starts with a whimper…probably mine!

A fairly brief opening salvo for the New Year: I am hoping it will continue to be difficult to come up with material for this space because that will likely mean we’ve reached something of an equilibrium relative to funky compliance stuff. After the last decade, I think we can probably all use a bit of a rest from the madness…

For those of you keeping track of the goings on in Chicago, you’ve no doubt received any number of exhortations over the past couple of weeks to check out the “new” (the “improved” is somewhat implied, but if you order in the next five minutes, they’ll double your order!) Joint Commission website.  I will say that they have definitely spiffed up the look of the place—everything looks bigger and brighter. But (and isn’t there almost always one of them?), in retooling things, some of the less recent links to material are no longer working. To that point, I had saved a couple of links to share this week, and now that they don’t work, I can’t quite say what it was that I found of particular interest (shame on me for not leaving a better trail of bread crumbs, though perhaps those pesky birds…). So, if you do some archival digging in this space (and perhaps others as well), you may find yourself at the business end of an error message indicating a non-functioning link. Having said that, if you should follow a link from Mac’s Safety Space that dumps you somewhere in the ether, please let me know and I will either try to find the “current” whereabouts of the information you’re looking for or provide some level of analysis to assist you in your efforts.

As an almost completely unrelated item to finish this up for the week, I wanted to bring to your attention a recent finding relating to space heaters that might prove timely given this age of polar vortices (vortexes?) and all manner of cold weather. The finding relates to a portable space heater in a nurse station, with the enjoinder that, for the purposes of this performance element, nurse stations are considered patient treatment areas (looping back on the prohibition of portable space heaters in smoke compartments containing sleeping rooms and patient treatment areas). You can have them in offices that meet the definition of non-sleeping rooms, which are occupied by staff and separated from the corridor and are permitted to have portable space heaters (the heating elements must not exceed 212°F). I’m sure you know where the folks with the cold feet live, so make sure you keep a close eye on the heater situation.

Getting a word in edgewise: Take back the power!

We’re looking at a lot of cusps this week—the ending of one year and the beginning of another; the end of a decade and the beginning of the latest edition of the roaring ’20s, so I figured I’d do a quick kickoff post for your consideration.

I suspect that at some point in time over the years (or perhaps even over the minutes of each and every day), you have found yourself in a conversation that is more of a soliloquy (and not your soliloquy) as you attempt to “get a word in edgewise.” I find that engaging with a conversational steamroller is among the most frustrating occurrences (not the least being the steamroller’s seeming inability to “listen” and/or “hear” what anyone else is saying). So, as I was looking over various feeds last week, I came across an article about just this topic. Truth be told, while I found the information contained therein very thought-provoking, I haven’t been able to put these concepts to the test just yet so I can’t personally vouch for their efficacy. But I “see” the logic (and the simplicity) of the suggestions enough to definitely want to give it a try moving forward. I don’t know that I would call it a “New Year’s Resolution,” but anything that can increase the effectiveness of personal communications can’t be a bad thing.

On that note, please accept my fondest wishes for a 2020 full of personal and professional success and development and my thanks for sticking with me through the vagaries of my “head” space. I’m glad to have you all aboard!

I heard the bells! Or did I see three ships?

Yet another mixed bag of festive goodies for you this week: I know you’ve all been good (our profession doesn’t really leave a lot of room for anything other than good, so Santa Mac doesn’t even need to make a list and check it once or twice).

First up, a set of HazMat-related items for your consideration:

I’m not sure how many of you folks are still managing ethylene oxide sterilization systems, but it does appear that there’s a movement afoot (or a continuation of an existing movement) to really pare back on the use of ethylene oxide. At present, the proposed rule seems to be aimed at folks using larger quantities of ethylene oxide (more than 1 ton of ethylene oxide per year), but I suspect that the next pass may well start to push down through the smaller-scale users. To that end, the information on the EPA website is probably worth looking at to determine where your current processes and equipment might fall on that continuum. I don’t know any safety professional who is keen to have the stuff in their “house”, but there remains reusable medical equipment that can only be appropriately sterilized (per manufacturer Instructions For Use) with ethylene oxide, so hopefully things will catch up and we can move past this risk.

Next up, an interesting article on increasing climate friendliness in your surgical procedure rooms. I guess anything that can reduce energy costs is worth investigating, though it may work better for those of you planning renovations or new construction of surgical procedure rooms. At any rate, I find that it’s always kind of interesting to see what’s working for folks (recognizing the importance of knowing what doesn’t work as well), so a tale from the land of the New English.

Extending the renovation/construction thought, Becker’s Hospital Review recently published an article discussing healthcare facility construction trends to watch in 2020. I suspect that Becker’s is something that might be on the reading list of the folks in the C-Suite, so it might be worth working their take on construction into your pleas for resources. It certainly can’t hurt.

Finally (I haven’t decided if I’m going to have anything for you next week—I’d rather you enjoy your families), I wanted to share a link to a blog by Peter Martin of Gosselin-Martin Associates that shares some quotes and insights gathered over the last year (and a fitting jumping off point for the (hopefully) next roaring ’20s). If you’re not familiar with Peter and Gosselin-Martin, I would encourage you to do a little checking of the additional blog entries as well as the services they provide. I’ve corresponded fairly often with Peter over the years and I’ve found him to be a consummate professional and a very thoughtful guy—an excellent resource to be sure.

On that note, I will extend my best wishes to each and every one of you for a joyous holiday and that “roaring” start to the ’20s mentioned earlier. Be safe (not that you need me to tell you that) and I’ll be back in almost no time flat!

’Twas the week before Christmas and all through the…

Do you ever find yourself at the end of the year with a list of random items that you just never got to? It’s not that they weren’t (or, indeed, aren’t) important, but somehow…

At any rate, in looking at my box of blog ideas, I found a bunch of stuff relating to emergency power concerns and considerations, so figured an e-power bundle of bloggy goodness is in order. As always, when it comes to the topic of emergency power, I have to tip the safety hat to Dan Chisholm, Sr. and Danny Chisholm of the Motor & Generator Institute for doing such a great job of covering the world of emergency power. Particularly in a time where healthcare employees have been charged with manslaughter after the death of 14 patients during Hurricane Irma (story here), the degree of scrutiny accorded to emergency power inspection, testing and maintenance is likely to continue apace and the Motor & Generator Institute, at least in my mind, is a must-read.

Some of the topics you’ll find (check out MGI’s blog) if you hop over for some end of the year reading are:

  • Confusion on the part of surveyors relating to the interpretation of NFPA 110 and citations resulting from folks not properly “inspecting” their automatic transfer switches and Dan Chisholm Sr.’s proposal to the NFPA 110 technical committee to help reduce that confusion: Find more info here and here.
  • Remember all those findings relating to compliance with the whole emergency generator shutoff buttons outside of the generator space (which vanished from the Joint Commission standards as a specific, but lives on in the hearts of virtually no one)? If you don’t, there’s been some movement (including hope for a brighter future state of compliance) on that front. Check it out here.

Finally for this missive, there are few more critical times in the life of a facility than the period of recovery following natural disasters; and sometimes a checklist can be helpful.

I’ll have something for you next week, but on the off chance that your holiday includes minimal consideration of work-related stuff, please accept my best wishes to you and yours for a most joyous holiday of your choosing and a productive and prosperous 2020!

Do you still BBI? Also, how do you spell survey finding?


While I am not convinced it every truly went away, next month marks the official return of one of the most (in)famous acronyms in surveydom: BBI, which we all know stands for Basic Building Information (details can be found here). So, for those of you for whom survey is imminent, you might (if you have not already done so) want to hop on to your online Statement of Conditions portal to make sure that all your information is up to date, all required responses are in place, etc. Since this is nominally a “new” requirement, I think it best to presume that the Life Safety surveyors are going to be reviewing the contents, so you want to make sure you have a good read on your square footage numbers and all the rest of it. I don’t see this representing a particularly great risk of survey exposure, but I’d hate to see somebody out there in the audience to get tapped for something so simple.

In other news (and I would consider this more troubling in the long term), back in September, the updates to some of the Environment of Care performance elements for office-based surgery practices were published (details here). While the updates relate mostly to invocation of the 2012 edition of the Life Safety Code® and the applicable reference documents, it also (and this may me being a touch paranoid—’tis always the season) may be indicative of a shift in focus for what documentation might be requested for care locations that are nominally business occupancies. I have definitely seen this (though I wouldn’t yet call it a trend, though it’s getting there) in state surveys of larger healthcare organizations, so it may just be a matter of time before evidence of compliance is requested for all the various life safety systems in place at your offsite locations (remembering that this does not mandate the presence of fire alarm systems, sprinkler systems, etc.—it only requires you to appropriately maintain any existing systems).

On a final note for this week, it would seem that some folks are using their work order system to provide evidence of scheduled activities like monthly testing/inspections of battery-powered lights, exit signs, task lighting, etc., and I just wanted to let you know that in the absence of an inventory of devices by location, there are some surveyors (and perhaps even more than just some surveyors) that will not accept a completed/closed out work order as evidence of compliance for these activities. Recognizing that the standards-based requirement for the “inventory” (in all its glory) has not specifically been extended to utility systems equipment (though I have anticipated that extension for a while), I think it may be time to start including the same level of detail as required for life safety systems inspection, testing and maintenance activities:

  • Name of the activity
  • Date of the activity
  • Inventory of devices, equipment, or other items
  • 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

I suppose to a fair degree it makes sense for inspection, testing, and maintenance documentation to have a standard format and it certainly helps to establish compliance in a fashion that is recognizable to surveyors. I guess we’ll just have to keep a watchful eye on this one…

It appears that everything isn’t meant to be OK…

You may recall a few weeks back we were discussing some recent survey findings relative to the placement of eyewash stations once one has determined that one needs an eyewash station (or stations). At the time, my dream was to clarify those findings and have them vanish into the ether (which is pretty much where they belong). But alas, that dream crashed upon the rocks of an overreach—can’t say for sure if this signals a sea change or is based on a reluctance to overturn a judgement call in the field. The ruling from the home office read thusly (but not justly): “The organization must do a risk assessment to determine if substances that may be in the sink would not splash onto the person using the eyewash station and inadvertently be contaminated.”

And so, I guess we add an additional imponderable to the equation: How do we install the eyewash station close enough to the area of greatest risk without placing the eyewash in a location that could be adjudged to be too close to the risk area? I suppose the ultimate goal would be to try to remove the hazard entirely, but with all the focus on disinfection and the likelihood that whatever disinfectant in use is going to be firmly in the high-risk zone, that seems unlikely to win favor during survey. Is it possible to “sell” engineering controls to a surveyor that is looking to find things to cite? I think we can all agree that the use of PPE and other forms of engineering controls are probably never going to be the interventions we would hope for them to be, but it is often so difficult to protect folks from themselves.

That said, I suppose it wouldn’t be the worst idea to do a little global evaluation of your eyewash station locations (much like a conjunction function) and add yet another risk assessment to the mix. If you’ve got a survey coming up in the near future, it may save you some aggravation.


Thank you for being round pegs in a square world…

As this is a somewhat shortened week (in complete recognition that safety never takes a holiday), I just wanted to briefly touch base to thank you all for hanging out (and hanging through) the various twists and turns of the last decade or so. Sometimes being the safety “cop” can be a frustrating endeavor, but this week I’d like to (and I’d like you to do so as well) focus on the folks I encounter who “get it right” all day, every day. That’s not to say that I’ve run into any perfect organizations (and I will count myself among the imperfectionists), but there are those (and I count you all among that number) who understand that the process of improving the safety of an organization is not so much about yesterday as it is about tomorrow (and the next day) and the commitment to those tomorrows is what sets us apart from (and sometimes in opposition to) other folks. It takes a unique set of skills to embrace all that is safety in healthcare (and elsewhere) and I am proud to be able to provide some level of service to your cause.

At any rate, please accept my sincerest wishes to you and your families for a most joyous Thanksgiving—and an enormously safe Friday after for those of you about to shop—I salute you!

More safety goodness next week!

Well that stinks! Or maybe it doesn’t…

I guess we can file this under the “You never know what’s going to pique someone’s interest” category.

In last week’s Joint Commission E-Alert publication, there is a featured set of links to an updated FAQ regarding “Aromatherapy & Essential Oils” (for example, this one). When I first saw it, I was thinking that maybe it was going to discuss some of the intricacies of dealing with all this smelly stuff that seems to crop up in offices and other spaces (everywhere looks like a good place for a stick-up). But when I clicked through the link, I found the question revolved around whether or not aromatherapy and/or essential oils needed to be managed as medications. As usual, the response was “it depends” (admittedly, that is a very much shortened version of their response, but please feel free to click through to embrace the majesty of this FAQ), with the slightly more involved response being “it depends on how you’re using it.” I have to say that I am not typically a fan of a lot of these scents; some of the them just seem like iffy attempts at covering other odors and some of them just seem wrong, but I digress. I know there are (perhaps more than) a few organizations that have adopted a fragrance-neutral/fragrance-free environment (these days, you just don’t know how someone is going to react to various scent-sations—allergies abound), but I can definitely see some folks interpreting this as something of an endorsement of using scents as a strategic intervention.

In other news, TJC also announced the publication of a new book of safety lists, which (based on my past experiences with their book products), may or may not be the answer to your sticky challenges (I pretty much live in the “not” camp, but someone wants to try and convince me that we have a winner, I’m game). Alternatively, you might consider the 2019 edition of the HCPro Hospital Safety Trainer Toolbox, which promises so much more than a bunch of checklists. I personally kind of ebb and flow on the whole concept of checklists, primarily because I find they try to do too much (or perhaps promise too much is the more appropriate descriptor). I see those checklists that go on and on for pages and pages and I’m thinking how in (insert deity of choice)’s name do you operationalize something that big? To that point, I am often asked what I look for when I’m doing consultant survey work and my (admittedly somewhat glib) response is that I don’t look for anything in particular, but rather I look at everything. I suspect it goes back to my EVS days when I looked at things from top to bottom in a (more or less) circular fashion—pretty much looking for stuff that didn’t look right (it is very rare indeed that I find an instance of noncompliance that looks “right,” if you know what I mean). The corollary to that is that a surveyor (and I count myself among that august assemblage) is never more dangerous than when they are standing still—that’s when the little funky detail stuff comes into focus. All the divots, loaded sprinkler heads, dust animals (bunnies, dinosaurs, the lot), become more visible. A moving surveyor (unlike the moving finger…) is a very good thing!