Every once in a while (and I don’t think I abuse this privilege, but please feel free to disabuse me of that notion), I like to vent a little regarding those annoyances that can impact how the folks in the safety world carry out their duties. In this particular instance, I’d like to rant a bit about those members of the “safety committee” that seem only to attend meetings when there is an opportunity to stonewall/derail/obstruct, etc., the ongoing work of the committee.
Lately it seems a lot of folks are struggling to bring their active shooter response plans past the initial stages and move into the implementation phase. That struggle inevitably seems to revolve around those transient members that always seem to know when you’re committee is just about to “birth” a new policy or process and they glide into the action with reservations/objections/all manner of constipations to set things back, without having participated in the work leading up to that point.
In my heart of hearts, I know that this is not very collegial behavior, but the question I have for the community is: How are you managing these occasions? My philosophy (which can be sorely tested from time to time) is that you have to birth the policy before you can tell for sure how well it will (or won’t) work when you operationalize it. I guess the analog to that is that it is better to have a flawed policy that you can work to improve than it is to have no policy at all, particularly to manage critical functions or risks. It is very, very difficult (certainly bordering on impossible) to come up with perfection without doing some trialing in the real world (maybe it’s possible, but I can honestly say I’ve never encountered it). I suspect this has happened to many (if not most, and probably all) safety professionals. Anybody have any inventive solutions for organizational blockages? Please sing out—let the world in on your secret!
As you are all no doubt familiar, sometimes those educational topics surrounding safety can come across as a bit dry and that dryness all too frequently ends up being the focal point of safety presentations. Now, one of the fun little quirky things that you run into when flying is that every time you get on a plane, you have to go through orientation (if only we as healthcare safety professionals could “capture” an audience as frequently as the airlines do) and sometime those orientations are very much less than compelling. And so, I thought that you might find the following offerings from NPR and The Telegraph of some interest, entertainment, and perhaps some inspiration. As I like to say during my consulting visits, this stuff doesn’t have to be torture. At any rate, I hope you enjoy these, and maybe you’ve got some homegrown footage you’d want to share (or perhaps already have shared); there’s no reason we can’t all partake of such splendor.
We’re rounding the turn and headed for home – no squeeze play at the plate this time…I hope!
EC.02.05.09 – Inspection, testing and maintenance of medical gas and vacuum systems (#16, with 24% of hospitals having been cited)
It seems to me that we’ve discussed this in the past as well, but it appears that, in this survey year, everything bears repeating.
Anything that your medical gas and vacuum testing activities generate as deficiencies/recommendations/hints from Heloise/etc. needs to be accounted for somehow. Maybe your medical air intake is right next to an isolation exhaust, or it’s nothing more than a leaky outlet, or the issue is non-compliant construction (a favorite is the medical gas zone shutoff valve in the PACU with no intervening wall) that can wait until you do a remodel/renovation project. Whatever it is, you need to say, “This is what we’re doing about that, based on our assessment of the involved risks.” And don’t wait to get ahead of the curve on the fixes: As soon as the activity is completed you are on the hook for the fixes, so you need to know what’s on that list even before you get the pretty report. The clock starts ticking upon identification of the condition, so if you have to wait a month or 45 days for the report, you (and more importantly, your patients) are at some level of risk.
The other thing to do is make sure that your vendor is not using this process to drum up work; I can’t tell you how many times I look at multiple years of testing documentation and find the same “deficiency” over and over again – and then find out, well, it’s not really a deficiency at all. You will get slapped during a survey for this – if it’s a critical fix, then fix it, if it’s not a critical fix, then dot the “I’s” and cross the “t’s” and make sure they are accounted for.
Another component of this is obstructed access to zone shutoff valves, as well as making sure that the labeling of valves is accurate (areas served, contents of piping – labels have to be accurate, accurate, accurate). Also, make sure that what you are calling the area of coverage is in some sort of accordance with what the staff calls the area. I can’t tell you how many times that I’ve seen zone valves labeled in accordance with the architectural drawings and find out that front line staff really doesn’t know which areas are served by the valves. Knowledge is very powerful, and certain knowledge is an invaluable commodity during surveys.
EC.02.05.07 – Inspection, testing and maintenance of emergency power systems (#17, with 23% of hospitals having been cited)
Emergency generators and automatic transfer switches have to be tested in accordance with the requirements of EC.02.05.07 – if you need me to tell you what those are at this point, you may be in the wrong line of work. However, I am more than happy to answer any questions you might have regarding this most important subject. 30%, 30 minutes, no closer than 20, no greater than 40 between tests, run it for 4 hours at a minimum 30% load every 36 months – these are a few of my favorite things.
EC.02.03.01 – Management of fire risks (#20, with 19% of hospitals having been cited)
Breathing a sigh of relief, we’re near the end of our little journey through time and (interstitial) space.
This is another of those findings that it becomes a question of how far one must look before one can encounter enough deficiencies to drive an RFI (the answer in this case being 2). The question I have for you is this – how many junction boxes do you have in your facility. 100? 1,000? 10,000? So, the follow-up question is: How many would an individual (say, a Joint Commission Life Safety surveyor) have to look at before they found two that didn’t have a cover? There are so many opportunities to drop the ball on this one – mechanical spaces, comms closets (it’s very rare that I find an open j-box in an electrical closet – but not impossible). You know they’re going to look above the ceiling – and they’re not just looking for penetrations – and cabling on sprinkler piping – and, and…
You need to enlist the efforts of everyone who does work above the ceiling in your facility; they don’t necessarily have to fix it, but if you know where it is, then you have a shot at being able to address it before it gets ID’d during a survey. The proactive approach works unbelievably well for stuff like this.
And on the horizon looms the specter of a return to focus for the prevention of surgical fires – including the participation of physicians. Too many (and my stance is that one surgical fire is too many) surgical fires occur for my (or anyone’s) liking, so it’s time to kick this process into high gear. I know they’re busy, and may not always seem to be the most cooperative bunch on the planet, but this I see as a moral imperative (and it appears that TJC is similarly inclined – so if you won’t do it for me, do it for them). We can do a better job of educating folks about the risks of surgical fires – and so, we must do just that.
One other related thought is to make sure that you are appropriately managing amounts of compressed gas – don’t go over 12 e-cylinders in an unprotected area. And make sure that your gas storage rooms (for amounts greater than 300 cubic feet of gas) are appropriately fire-safe, etc.
This concludes our test of the emergency survey broadcasting system – this was only a test. We now return you to our regular programming, which is already in progress. If you have any questions or concerns about this or any other topic, you know where I am…
Just a thought relative to a finding from a recent survey – a quick show of hands, if you will. For those of you blessed (cursed?) with having a fire pump (or two, or three, or…), when your folks conduct the weekly churn test, are they documenting the pressures at the pump as required by NFPA 25-1998, 5-220.127.116.11?
It seems that there are some instances in which the run time for the test is all that is being documented, so if you think you might be among those who aren’t documenting the pump pressures, consider yourself informed. For those of you who don’t have fire pumps, well, one less thing to worry about, which leaves about 999,999 things to worry about. You take one down, pass it around…
Every once in a while, someone will “challenge” me relative to something I “know” is the real deal. Now, just so we’re clear on this, I absolutely encourage the respectful pursuit of knowledge, and it helps keep me on my toes, metaphorically speaking.
The issue in question during this recent survey was regarding the requirements for the placement of smoke detectors vis-à-vis the location. Or, in the vernacular, “Where does it say that it the code?” At this particular facility (as will happen from time to time), I noted that there were several smoke detectors that were located within three feet of air supply/return vents. I fully recognize that moving such devices around can represent a not-insignificant expense, so I was happy to respond to the “nobody’s ever said anything about that before” conversation, but had to admit that I was not certain as to the chapter and verse that governed this particular metric.
So, for the purposes of furthering the knowledge base, I give you NFPA 99 – 1999 edition, which is the edition of record referenced in the 2000 Life Safety Code®:
2-3.5.1*: In spaces served by air-handling systems, detectors shall not be located where airflow prevents operation of the detectors.
Now you may have noticed that there is no specific distance indicated, just a (not particularly useful) thou shalt not. So, how do we figure out where to go with this? Luckily, the little asterisk, points in a very useful direction. And so, to the Appendix!
A-2-3.5.1: Detectors should not be located in a direct airflow nor closer than 3 ft (1 m) from an air supply diffuser or return air opening. Supply or return sources larger than those commonly found in residential and small commercial establishments can require greater clearance to smoke detectors. Similarly, smoke detectors should be located farther away from high velocity air supplies.
Which provides us with a minimum distance of 3 feet (or 36 inches, for those of you inclined to such measures). While there is still a little wiggle room (not necessarily related to the little asterisk) relative to distance from larger and/or high velocity sources (in fact, you could make the interpretive case that supply and/or return sources in hospitals might indeed be larger than those commonly found in residential and small commercial establishments), this gives us the means of drawing a line in the sand beyond which we shouldn’t traverse. As a final thought, for those of you eagerly awaiting the opportunity to embrace the 2012 edition of The Life Safety Code®, the 2010 edition of NFPA 99 provides this little piece of the regulatory pie under 18.104.22.168.
While I was on vacation a few weeks back, I used some of my “leisure” time to read the daily paper, and I came upon an article regarding the sentencing of a woman who had abducted an infant back in 1987 and raised the infant as her own child. One of the things that struck me is how the abduction scenario (or as much as can be discerned from the news account) involved an infant that had been discharged following delivery and had then been readmitted to the hospital a couple of weeks later. I reflected on how “useful” this scenario could be in developing abduction exercises, and I wondered how often folks are testing response in areas other than the mother-baby unit.
So, I ask you dear readers – what “other” areas have you identified as being at risk for potential abductions – inpatient, outpatient, how about in the home when mother and baby have been discharged. How are we educating staff and patients to the very real risks that exist in way too many places (in my humble opinion)? What do you think? How “far” do you take your responsibilities in this regard?
In the August 2, 2012 edition of the fabulous HCPro e-newsletter Hospital Safety Connection, the weekly tip discussed the various merits (or not) of whether kitchens ought to be considered hazardous areas. This discussion apparently engendered much debate, though mostly as a function of what would be considered a hazardous area under the Life Safety Code® (LSC).
While I can understand the interpretive aspect of this from an LSC perspective, my opinion has always been that if you were to consider a mental list of the various and sundry safety risks and hazards that one might encounter as a healthcare worker, the kitchen area has the potential for just about all that would be included in that “mental” list (let’s see. Fire? Check. Sharps? Check. Burns? Yup. Slips, trips, falls? Check, check, check. Need I continue? I think not). And if you extend the kitchen environment to the food services folks who deal directly with patients, then there aren’t too many potential risks that would not be in the mix.
So, while the designation of kitchens as a hazardous area may be debatable from a Life Safety Code perspective, from a pure safety/risk management perspective, it would have to be considered a most (potentially) hazardous area. What say you?
I’m not sure if you folks follow my HCPro colleague David LaHoda’s OSHA Healthcare Advisor e-newsletter and blog, but there’s an item this week that I think bears bringing to your attention in case you didn’t see it.
I’m going to guess that you all out in the audience do not necessarily place The Joint Commission’s Perspectives periodical on your list of must-reads, but for the May and June 2012 issues (and who knows beyond that), you really owe it to yourself to grab a copy and prepare for some hard-hitting door and barrier conversation with our esteemed colleague, one Mr. George Mills, Director of the Engineering Department at The Joint Commission.
At any rate, I think we can point to an increasing level of frustration on the part of the various and sundry regulatory agencies (and us, don’t forget us) relative to the number of findings in the life safety (LS) chapter and the omnipresence of these issues in the most frequently cited standards during surveys. How do we make this go away? The answer to that question, interestingly enough, is adopting a risk-based strategy for the ongoing inspection and maintenance of whatever building component is in play – this month its doors. [more]
Earlier today, I was conducting an EC/EM interview session with a very participative group and I was complimenting them on their ability to speak to improvement efforts in areas that are not necessarily in their scope of practice. Now, my experience has been that the folks most familiar/expert with the EC function being discussed tend to dominate the conversation (sometimes in a good way, sometimes not) and I thought it was cool that these folks were so familiar with what others in the group felt was important. To my compliment, the observation was made (and I thought this was absolutely the grandest definition of what a high-performance team can achieve) that they mind each other’s business. In that simple turn of phrase (not an exact quote – sometimes paraphrase is the best I can do), the whole concept of what the EC team can embrace and accomplish was crystallized: It’s not about what may or may not be “somebody else’s job” (or “not my job”); it’s actually using the team concept to make and sustain improvements. In the old days we used to call that type of organizational behavior “silos,” which is OK if you’re storing grains and such, but when the goal is organizational improvement, we want to be more like a snack mix with all sorts of nuts and fibrous bits.
And please keep in mind, it’s not necessarily about never having any issues to correct. As long as there are human beings in the mix, there will be corrections to make – be assured of that. But if you can harness the power of a group of committed individuals who accept responsibility, hold each other accountable, and care enough to “mind each other’s business,” you can accomplish so much. There’ll always be stuff to do, but think about the power of getting stuff done.
Brings a smile to my face – how ‘bout you?