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Temper Temper(ature)

In the continuing pursuit of every possible question that could ever be asked about eyewash stations, there’s been some chatter recently (as well as some field encounters) relative to what is involved with the weekly operational testing of emergency eyewash equipment, particularly whether or not you have to verify the temperature of the flushing fluid. The “good” news is that while there is a requirement to periodically verify the temperature of the flushing liquid, that period is one that is some 52 weeks in length, so we can put that down for an annual visitation. Having said that, I’m thinking this might be a fine opportunity to cover the basic goals of the weekly test (I find there is frequently a bit of a gap in terms of front-line staff’s understanding of the reasons behind the testing).

Let’s start with the ANSI standard. The intent of the weekly activation from the ANSI perspective is to ensure that there is a flushing fluid supply at the head of the device and to clear the supply line of any sediment buildup that could interfere with flow (that’s why you do the test with the caps on – if the pressure isn’t sufficient to “pop” the caps, then there may be some blockage). Running the water also helps to minimize any contamination due to stagnant water.

Another common question is, “How long should I run the water?” The answer is “It depends.” I think we’ve discussed this before, but once more unto the breach: You have to consider the amount of water contained in the eyewash itself, and the water which is in all the sections of piping that do not form part of a constant circulation (a “dead leg” in the plumbing, as it were). Since water tends to be stagnant in these sections until a flow is activated, you need to run the device long enough to flush out all the stagnant water. This may take a little bit of figuring, but once you’ve figured out the time period, you should be good to go.

You also want to make sure that the eyewash equipment is completely accessible, the protective caps are in place, and someone hasn’t installed a cabinet over the device close enough to result in a head injury if someone tries to use the eyewash (don’t laugh – I’ve whacked my head more than once trying to fit my noggin into a confined eyewash. Yes, I realize that head trauma probably explains a lot, but that is an entirely different topic of conversation). Ultimately, it’s about making sure that if someone gets some bad stuff in their eyes, they have an appropriate means of responding to that exposure. Hopefully, it’s not something we need to use very often, but if we have the eyewash stations, we have to properly maintain them.

And where it’s going, no one knows

Continuing on our recap of survey adventures, we finish out the Top 10:
EC.02.06.01 – Establishment and maintenance of a safe, functional environment (#9, with 32% of hospitals having been cited)
A couple of somewhat disparate conditions are coalescing under this particular standard:

  • Safety and suitability of interior spaces – this apparently is where the unsecured compressed gas cylinders are ending up when they are found during survey. Not necessarily the place I would have picked (I’d run with EC.02.01.01 EP #3 – minimization of safety risk in the environment), but I can see where it would fit;
  • Management of ventilation, temperature and humidity in the care environment – this is one that will cause you so much heartache, it’s not funny. Temperature and humidity logs? You better have ‘em (and yes, I know that they are not specifically required in the regulatory verbiage, but that doesn’t mean a (insert descriptor of your choice) thing. Trust me on this, if on nothing else, ever!) Make sure that you have extremely reliable pressure relationships in every spot where you’ve got clean/soiled environments cheek-to-jowl; clean/sterile; sterile/soiled, etc. The air has got to flow from the good to the bad (euphemistically speaking), if it flows from the bad to the good, you are going to get lit up like a Roman candle during survey, likely resulting in a CMS visit to boot – none of us want that, none of us at all.
  • Finally, and I don’t know that this got a whole lot of play in the official version, but there is a universal opportunity relative to cleanliness in the patient environment. There are some that I’ve seen who do a pretty good job, but I also know that I’ve not encountered anything close to perfect. If you have a surveyor with a mind to find dust, etc. somewhere in the patient environment, it will be found and it will be cited. Tell me the EVS folks aren’t shoveling against the tide sometimes…

EC.02.02.01 – Management of Hazardous Materials Risks (#10, with 29% of hospitals having been cited)
Lots of funky conditions can reside here, to name just a couple:

  • Management of eyewash stations – weekly checks, temperature, obstructions, where they are installed, etc.
  • Labeling secondary containers – if the chemical leaves its home vessel and is placed in another vessel, the second vessel (spray bottle, basin, sink) needs to have the hazard identified, unless the second vessel is absolutely attended until it is used/properly disposed – and even then, I’d do the label;
  • Access to the Hot Lab in Nuclear Medicine – you’ve got to have a policy that makes sense about access, particularly for couriers delivering the materials – and remember, they’re already driving around with the stuff – if they want to swipe the stuff, they’ll just keep driving – so keep an eye on your stuff (George Carlin would want you to). That said, you should track down the July 2012 edition of Perspectives – there’s a lovely article on just this subject – can you say risk assessment? Thought so.

OK, we’ll do one more for this week, breaking into the next 10
EC.02.05.01 – Managing risks associated with Utility Systems (#11, with 28% of hospitals having been cited)

For those of you with older buildings and/or older utility system components, this one may keep you up at night. The sort of overarching way this is popping up during surveys (other than temperature, humidity, and ventilation, about which we’ve already spoken and will, no doubt, speak of again) is the inability of the system (whichever system it might happen to be) to achieve required results. Now, the sticking point here relates very much to what constitutes a “required result”. In case you hadn’t noticed, CMS is pretty much calling the shots when it comes to enforcement and, with increasing frequency, the practice of grandfathering older, lesser-performing systems is going by the wayside. If you (or someone you love) has a utility system that is not performing up to modern standards, then you had best get going on a risk assessment and identify mitigation strategies for appropriately managing the risks associated with the current performance level of the systems (and, perhaps, a plan for how you’re going to get to where you need to be).

The other condition that has been popping up is the identification, in writing, of inspection and maintenance activities (and the appropriate intervals) for all operating components of utility systems on the utility management inventory (which is, of course, populated through an arduous risk assessment process). It’s my understanding that continuous monitoring through the good graces of a building automation system is an acceptable means of compliance with this requirement, but if you don’t have a building automation system, you’d best be prepared to produce, in writing, the activities and intervals as noted above (a computerized work order system might work – but it has to be a pretty robust platform).

And so we’ve reached the end of yet another batch of fun facts and figures – next week, we’ll wrap it all up – until next year!

I need to know – the re-rise of glutaraldehyde-based disinfectant

One of the developments of the last few years that pleased me most was the move away from glutaraldehyde-based disinfectants to safer alternatives. But now—and I am at a loss to understand what is prompting this—I am seeing a resurgence in the use of the glutaraldehyde-based disinfectants. As we are more or less familiar, glutaraldehyde is a fairly complicated environmental hazard to manage (not the most complicated, but up there on the list), with requirements regarding monitoring of conditions, ventilation, etc. For the big picture, the following link will do nicely: www.osha.gov/Publications/glutaraldehyde.pdf

So what is pushing us back toward a, oh I don’t know, certainly a more hazardous material? You’ll get absolutely no argument from me when it comes to the importance of properly disinfecting reusable medical devices; the rate of hospital-acquired infections is so much greater than we as safety professionals can live with. I had heard of some instances in which devices like endoscopes were stained following disinfection using OPA-like products, but my understanding was that any discoloring on the surface of devices was residue of proteinaceous materials that weren’t completely removed during the pre-disinfection process. (You can’t really call it staining as these devices are generally impermeable, so if it can’t sink in, it can’t stain.) So, I ask you: What up with this? I want to be able to help folks move in the right direction, and I’m not convinced that moving back toward glutaraldehyde is the right direction. If you folks are privy to something that allows this to make sense, please share. It is, after all, the time of the season. Hope to hear from you soon.

Not quite animal magnetism

Recently I fielded a question from someone who was reviewing an MRI safety plan and was curious about how the four-zone “defense” would work when the MRI is in a self-contained trailer that is not part of the building. Now my first thought on this was whether the MRI service is provided under contract (including staffing) or whether the service was staffed by hospital folks and the trailer under some kind of lease arrangement. My somewhat snotty response would have been to lean on the contract folks to work out how it all fits together, but then I was thinking: What if we had to work it out on our own, for whatever reason?

At first blush, I can see establishing three zones without too much difficulty. It may be necessary to combine Zones 2 and 3, but Zone 1 (i.e., general public) would be outside the trailer and Zone 4 (i.e., screened MRI patients under constant direct supervision of trained MRI personnel) would be in the magnet room, so that’s pretty reasonable. But again, what about Zones 2 (i.e., unscreened MRI patients) and Zone 3 (i.e., screened MRI patients and personnel)? I don’t think there would be enough room in the trailer for screened and unscreened folks, but maybe Zone 1 could be the ground level outside the trailer, Zone 2 could be the area just outside the trailer (on the lift and/or stairs—depends on the configuration of the trailer), which would leave Zone 3 in the control area.

Or I suppose you could do a risk assessment to demonstrate that the risks can be appropriately and reliably managed without adoption of the four-zone setup, but one would need to make sure that all staff in the area (and I do mean “all” staff) can speak to the protection measures in place. Querying of staff has been coming up in recent TJC surveys and if staff cannot speak to the zones and differing levels of safety/protection, it results in citations under the management of hazardous energy sources element of the Hazardous Materials and Waste Management standard. Probably not a bad thing to check on after lunch this afternoon.

Judge the need to lock up cleaning products with common sense

Regarding my prior post about MSDS exemptions for consumer products, someone asked me whether there are any requirements for cleaning products to be locked up when not in use.

Once again, the risk assessment rears its fiery plumage!

There is little specific guidance in this regard because [more]

Stick to required policies in your physical environment program

Sometimes you hear about Joint Commission surveyors requesting to see certain policies in your physical environment program.

Joint Commission standards are not very prescriptive when it comes to the identification of specific policies. The only required policies are [more]

Eyewash stations hinge on chemical use as opposed to a wholesale requirement

Eyewash stations are only required by OSHA in specific instances, and those instances are discerned through a review of the material safety data sheets (MSDS) for the chemicals being used.

If an MSDS indicates that first aid response to an eye exposure requires flushing for 15 or more minutes, then you are looking at an eyewash station. Anything less than 15 minutes, no eyewash is required.

If you remove the chemicals in question [more]

Problem areas within the hospital for chemical risks

When it comes to minimizing chemical risks in the environment of care, the lab and pharmacy are definitely areas that have experienced the greatest improvements over time.

To be fair, those areas should be evaluating [more]

Keep your safety manuals universal and to-the-point

A quick thought about safety manuals, taken from my book, The Hospital Safety Director’s Handbook, Fourth Edition:

To be considered useful, your safety manual needs to strike a balance between the availability of information and [more]

Regulatory gray areas around this series of less-than-best practices

I was asked about a clean utility room that is also an electrical storage closet, which contains electrical panels, many wires, and oxygen cylinder storage against the wires.

It sounds like the organization had to make use of the available space for its network cabling, and while this is not an optimal environment of care practice, there’s no real regulatory language that precludes it. That said, there are a couple of things I would cite as “other environmental concerns” to consider: [more]