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Roll over Beethoven!

As we mark the passing of yet another (couple of) pop culture icon(s), I’m feeling somewhat reflective as I place fingers to keyboard (but only somewhat). As I reflect on the potential import of Sentinel Event Alert #57 and the essential role of leadership, one of the common themes that I can conjure up in this regard has a lot to do with the willingness/freedom of the “generic” Environment of Care/Safety program to air the organization’s safety-related (for lack of a better term—if you have a better one that’s not really PC, send it on) dirty laundry (kick ’em when they’re up, kick ’em when they’re down). I’ve seen a spate of folks getting into difficulties with CMS because they were not able to demonstrate/document the management of safety shortfalls as a function of reporting those shortfalls up to the top of their organization in a truly meaningful way. As safety professionals, you really can’t shy away from those difficult conversations with leadership—leaky roofs that are literally putting patients and staff at risk (unless you are doing incredibly vigorous inspections above the ceiling—or even under those pesky sinks); HVAC systems that are being tasked with providing environmental conditions for which the equipment was never designed; charging folks with conducting risk assessments in their areas…perhaps the impact of reduced humidity on surgical equipment. There’s a lot of possibilities—and a lot of possibility for you to feel the jackboots of an unhappy surveyor. One of the responsibilities of leaders, particularly mid-level leaders—and ain’t that all of us—is to work things through to the extent possible and then to fearlessly (not recklessly) escalate whatever the issue might be, to the top of the organization.

I was recently having a conversation with my sister about an unrelated topic when we started discussing the subtle (OK, maybe not so subtle) differences between two of my favorite “C” words: commitment and convenience. My rule of thumb is that convenience can never enter the safety equation at the expense of commitment (I suppose compliance works as well for this) and all too often I see (and I suspect you do, too) instances in which somebody did something they shouldn’t have because to do the right thing was less convenient than doing the wrong (or incorrect) thing. Just last week, I was in an MRI suite in which there were three (count ’em: 1, 2, 3) unsecured oxygen cylinders standing (and I do mean standing) in the MRI control right across the (open) door from the MRI. There was nobody around at the moment and I thought if there was a tremor of any magnitude (and I will say that I was in a place that is no stranger to the gyrations of the earth’s crust) and those puppies hit the deck, well, let’s just say that there would have a pretty expensive equipment replacement process in the not-too-distant future. The question I keep coming back to is this: who thinks that that is a good idea? I know that recent times have been a struggle relative to segregation of full and not full cylinders, but I thought we had really turned a corner on properly securing cylinders. These are the times that try a person’s soul: tell Tchaikovsky the news! Compliance ≠ Convenience…most of the time.

A most mortal portal: Yes, Virginia, you need to have an inventory of your devices…all of ’em

And so, the flying fickle finger of compliance finally points portally (via The Joint Commission’s Physical Environment Portal) in the direction of that most troublesome of standards, EC.02.03.05, and we return once again to the fireside of our intrepid duo, Messrs. George Mills of The Joint Commission and Dale Woodin of ASHE. There are two videos, one for the facilities audience and one for leadership (does anyone else find it fascinating that the duo dons neckwear for the leadership video?).

While I don’t want to engage in revealing any spoilers, in the video, EC.02.03.05 is described as being “most prescriptive” and “frustrating” and also notes that Mr. Mills has taken some pains to “tear apart” the standard in past “Clarifications and Expectations” columns in Joint Commission Perspectives. Yet, yet, yet, approximately 40% of hospitals continue to get cited for deficiencies relative to the myriad components represented in this standard. I personally would love to see how this actually breaks down in terms of which of the 20+ performance elements are the most problematic (I can’t imagine that there are some that “float” to the top more than any others), but the video does seem to indicate what the “problems” are:

 

  1. You have to have an inventory, by location, of each device class, meaning smoke detectors, heat detectors, pull stations, HVAC shutdown devices, water flows, tamper switches, fire extinguishers, etc. It seems to me that back in the day, there was a reluctance on the part of our Chicagoan friends to actually say the words that would indicate the need for an inventory. But it all comes down (or back—I think I’ve beaten this particular breathless equine once or twice in the past) to knowing that you inspected, tested, maintained, each device in the fire alarm system. So if you (or your vendor’s documentation) do not specifically indicate that each device was demonstrably inspected, tested, maintained, then (buzzer sound): you lose!
  2. The documentation has to be available “upon request”, so really, if you can’t produce the current documentation PDQ, then (buzzer sound): you lose! You can only get credit for those inspection, testing and maintenance activities for which you have available documentation—if you didn’t document it, you didn’t do it. Period. End of story.

Now I certainly recognize that a combination of findings under EC.02.03.05 would drive a finding under the Leadership standards (to be exact, LD.04.01.05 EP 4), based on past survey reports. But apparently there is indeed a magic number of EC.02.03.05 EP findings that will result in the Leadership finding—three or more EPs out of compliance, then (bell rings): you win a discussion with your boss as to how you allowed (and I’m using that term in its most pejorative sense) such a thing to happen. At that point, for example, it is way too late to admit that the fire alarm and sprinkler testing vendors have not given you very useful reports (and something tells me that that particular conversation is not as rare as it ought to be). From watching the video (and in providing a neckwear-enhanced video specifically for your organization’ s leaders and Mr. Mills indicates he had to edumacate his bosses too—we are not alone), there is a very clear expectation that you, the facility/safety professional, will make the effort to proactive communicate with your boss, particularly if you are experiencing service issues, etc., in getting these activities under control. You can certainly make the case that the protection of the entire organization can be compromised if your fire alarm and sprinkler systems are not appropriately maintained, so, really, any infrastructure concerns should be communicated in a timely fashion to the leadership of each organization to ensure that appropriate resources are allocated on an ongoing basis to make sure everything stays on an even keel.

At any rate, our duo takes great pains to point out that none of this stuff is new (the “seed” documents from NFPA 72, 25 and the like having been penned way back in the 20th century), but I do feel that the methodology for surveying has evolved/mutated over time. I mean, if it were really that simple, wouldn’t this go away? They also point out that ASHE has a fair amount of information to assist you in your compliance efforts (ASHE Focus on Compliance: you can be especially warm for their forms) and there’s even a PowerPoint presentation that The Joint Commission uses at the EC Base Camp presentations (you can link to the presentation on the left hand side of the portal page), which gives it the power of the Quadruple P—Portal PowerPoint Presentation! Ultimately, you’ve got to keep a really close eye on this stuff, aside from product expiration dates, the management of the various and sundry elements of EC.02.03.05 is among the most voluminous in sheer numbers—that’s a lot of spheres to keep up in the air—and you only have to drop a couple to earn that lovely chat with your boss. I am absolutely convinced we can make it happen, so let’s see what we can do to retire EC.02.03.05 from the top 10. (Or 20…wouldn’t that be a fine thing?)

A cup of coffee, a sandwich, and…the boss!

If you’ve not yet procured a copy of the November 2011 issue of The Joint Commission Perspectives, I would encourage you to do so. There is a very interesting article that focuses on a strategy for establishing more effective communication between the folks charged with managing the physical environment (that would be you) and hospital leadership.  Now I think this is a pretty cool idea, but I couldn’t say with any degree of certainty how widespread a success it might be as there are a number of variables involved (and that’s not counting personalities). That said, it’s certainly a strategy worth pursuing, if it doesn’t pursue you first.

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