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Putting the O(SHA) back in OMG…

I’m sure you were right there with me last week pondering the potential impact of the Emergency Temporary Standard issued by our friends at the Big O (see the news release) in efforts to get ahead (and stay ahead) of COVID. As I travel, I’m not sure that this is going to be as successful as they’d like it to be. I still observe folks in airports, on public transportation, etc., who are surprised when they are reminded that masks are mandated in a lot of confined public environments. As somewhat of an editorial aside, I “get” that someone might forget to slide their mask back up after they’ve eaten, etc., but I don’t get the mindset that has masks buried at the bottom of their handbag, etc. I freely admit that my OCD slides to the fore when it comes down to mask wearing; when I’m traveling, the mask goes on in the car and doesn’t come off again until I get to my hotel room. I figure it’s worked well so far, so I’m going to stay the course for a while longer—maybe once we have a solid 12 months of vaccinations (and who knows when that might be…).

At any rate, under the ETS, covered employers must develop, implement, and enforce a mandatory COVID-19 vaccination policy, unless they adopt a policy requiring employees to choose to either be vaccinated or undergo regular COVID-19 testing and wear a face covering at work.

The ETS also requires employers to do the following:

  • Determine the vaccination status of each employee, obtain acceptable proof of vaccination status from vaccinated employees, and maintain records and a roster of each employee’s vaccination status.
  • Require employees to provide prompt notice when they test positive for COVID-19 or receive a COVID-19 diagnosis. Employers must then remove the employee from the workplace, regardless of vaccination status; employers must not allow them to return to work until they meet required criteria.
  • Ensure each worker who is not fully vaccinated is tested for COVID-19 at least weekly (if the worker is in the workplace at least once a week) or within seven days before returning to work (if the worker is away from the workplace for a week or longer).
  • Ensure that, in most circumstances, each employee who has not been fully vaccinated wears a face covering when indoors or when occupying a vehicle with another person for work purposes.

But in looking at all this stuff, I’m thinking healthcare (for the most part) has already embarked on this journey and when I started poking around the FAQs, FAQ 2J speaks very specifically to whether, in light of the existing Healthcare Emergency Temporary Standard (29 CFR 1910.502), and the answer (at the moment; more on that in a bit) is no, the protection of healthcare workers is already in play based on the existing ETS. But the potential “twist” is that if the Healthcare ETS were to expire/no longer be in effect, etc., before the expiration of this latest ETS, then the protection of healthcare workers would shift over. I don’t know that anything is jumping out at me from a practical standpoint that might represent a gap of protection if that shift were to occur, but if someone has different take on this, I’d be pleased as punch if you’d share it with us.

Sooooo…I think we’re OK for the moment, at least in terms of regulatory expectations, but keep an eye on things as they shift in and out of view/focus. If I sense a sea-change, I will do my best to keep you informed.

At the risk of “dating” this post, I’d like to conclude this week’s offering with a shout out to the veterans of our Armed Services. Not that they don’t deserve a shout out every week, but it just seems important to “push” Veterans’ Day a little bit this year. We are all the better for your service and I thank each and every one of you!

Night time in the switching yard: Listen to the train(ing) whistle whine…

I suspect that, amongst all the other things that have been pounding on the metaphorical rooftops, you saw the updated guidance from OSHA relating to the Emergency Temporary Standard. I don’t know that there’s a great deal in play that would be particularly problematic, but I think the training requirements might be worth a little bit of work to ensure that the required elements are readily discernible to a regulatory surveyor. That said, I wouldn’t necessarily consider these “new” requirements, as with so many of the post-pandemic “requirements,” it’s all kind of based on what you would do if you were facing whatever event was coming down the pike. I really don’t think this is anything about which you should be concerned, but I figure it can’t hurt to get the list out and make sure that your program speaks eloquently to the individual components.

Here they are:

1910.502(n)

Training.

1910.502(n)(1)

The employer must ensure that each employee receives training, in a language and at a literacy level the employee understands, and so that the employee comprehends at least the following:

1910.502(n)(1)(i)

COVID–19, including how the disease is transmitted (including pre-symptomatic and asymptomatic transmission), the importance of hand hygiene to reduce the risk of spreading COVID–19 infections, ways to reduce the risk of spreading COVID–19 through the proper covering of the nose and mouth, the signs and symptoms of the disease, risk factors for severe illness, and when to seek medical attention;

1910.502(n)(1)(ii)

Employer-specific policies and procedures on patient screening and management;

1910.502(n)(1)(iii)

Tasks and situations in the workplace that could result in COVID–19 infection;

1910.502(n)(1)(iv)

Workplace-specific policies and procedures to prevent the spread of COVID–19 that are applicable to the employee’s duties (e.g., policies on Standard and Transmission-Based Precautions, physical distancing, physical barriers, ventilation, aerosol generating procedures);

1910.502(n)(1)(v)

Employer-specific multi-employer workplace agreements related to infection control policies and procedures, the use of common areas, and the use of shared equipment that affect employees at the workplace;

1910.502(n)(1)(vi)

Employer-specific policies and procedures for PPE worn to comply with this section, including:

1910.502(n)(1)(vi)(A)

When PPE is required for protection against COVID–19;

1910.502(n)(1)(vi)(B)

Limitations of PPE for protection against COVID–19;

1910.502(n)(1)(vi)(C)

How to properly put on, wear, and take off PPE;

1910.502(n)(1)(vi)(D)

How to properly care for, store, clean, maintain, and dispose of PPE; and

1910.502(n)(1)(vi)(E)

Any modifications to donning, doffing, cleaning, storage, maintenance, and disposal procedures needed to address COVID–19 when PPE is worn to address workplace hazards other than COVID–19;

1910.502(n)(1)(vii)

Workplace-specific policies and procedures for cleaning and disinfection;

1910.502(n)(1)(viii)

Employer-specific policies and procedures on health screening and medical management;

1910.502(n)(1)(ix)

Available sick leave policies, any COVID–19-related benefits to which the employee may be entitled under applicable federal, state, or local laws, and other supportive policies and practices (e.g., telework, flexible hours);

1910.502(n)(1)(x)

The identity of the safety coordinator(s) specified in the COVID–19 plan;

1910.502(n)(1)(xi)

The requirements of this section; and

1910.502(n)(1)(xii)

How the employee can obtain copies of this section and any employer specific policies and procedures developed under this section, including the employer’s written COVID–19 plan, if required.

Note to paragraph (n)(1). Employers may rely on training completed prior to the effective date of this section to the extent that it meets the relevant training requirements under this paragraph.

1910.502(n)(2)

The employer must ensure that each employee receives additional training whenever:

1910.502(n)(2)(i)

Changes occur that affect the employee’s risk of contracting COVID–19 at work (e.g., new job tasks);

1910.502(n)(2)(ii)

Policies or procedures are changed; or

1910.502(n)(2)(iii)

There is an indication that the employee has not retained the necessary understanding or skill.

1910.502(n)(3)

The employer must ensure that the training is overseen or conducted by a person knowledgeable in the covered subject matter as it relates to the employee’s job duties.

1910.502(n)(4)

The employer must ensure that the training provides an opportunity for interactive questions and answers with a person knowledgeable in the covered subject matter as it relates to the employee’s job duties.

Again, I feel pretty confident that these elements have been in place in most instances (PPE, risks associated with COVID, health screening, any changes to procedures, etc.) and (presumably) the effectiveness of the education process supported by data of COVID-related illnesses amongst the workforce. But it might be a good idea to “pull” these elements out as a syllabus (if that makes sense) to be able to walk a surveyor through the elements.

It’s these little things, they can pull you under…

I guess this week’s entry (as it appears that Spring is actually going to spring) falls into the “a little bit of this, a little bit of that” category; nothing monumentally earth-shattering, but (hopefully) useful.

First up, a recent post from the American Society of Health Care Engineering’s (ASHE) YouTube channel (somehow, it escaped me that such a thing existed—shame on me!) popped up on some feed somewhere (it may have been LinkedIn, but I can’t say for sure) and I found it a very interesting topic of conversation: “The Cost of No.” Given the givens, I suspect there are not too many in the audience who haven’t been at the receiving end of a “no” response (as opposed to no response, which is equally frustrating), and this video may give you some food for thought in how best to manage that impregnable wall. It’s not often that we get what we want, when we want, but I think the video offers some insight into how to plead a better case—to the point that it might increase the chances for a positive response “next time.” The video is pretty short (you can spare 158 seconds, can’t you?) and there are a number of other short videos that are worth checking out, so don’t forget to subscribe. You can start with “No” right here, but please check out the other stuff as well.

Moving on, in a designation that doesn’t seem to have been influenced by Hallmark, March is National Ladder Safety Month (I would have sent a card, but couldn’t even find a birthday card with a ladder that could have been repurposed) and I think we can all agree that ladders are an important part of the compliance picture. I’ll let you find your own “ladder unsafety” images—there are more than I can count, but I think we can also agree that the safe use of ladders could be more thoroughly hardwired into a lot of folks’ practice, including inspecting the ladders before use.

At any rate, I encourage you to set up a ladder safety session for your folks, particularly if you haven’t done so in a while – and what better month to do so. Here are some resources to help ensure folks embrace the heights of safety:

Until next week, hope you are well and staying safe. We’ve made it this far and I am confident we can make it through this together!

From the sky, the highway’s straight as it could be!

But other things, maybe not so much…

In the continuing odyssey of “what goes around, comes around,” I had to cast some tea leaves to recall the last time we chatted about eyewash stations (for those of you keeping track, it was October 2019) as I reviewed the current (March 2021) edition of Joint Commission Perspectives, particularly what I view to be the most interesting aspect (and if you want to interpret that as the only interesting aspect, I would not argue the point) of the publication, the Consistent Interpretation column (I think it’s fair to call it a column, though perhaps not always a load-bearing one). The March Interpretation article deals generally with the minimizing the risks associated with managing hazardous chemicals (for which about 50% of the hospitals surveyed in the last year of the 20-teens were cited). I would encourage you to check out the details. It may save you some future heartache, especially if you have dental clinics in the mix—dental amalgam would seem to be the “pet rock” of some surveyors.

One very useful interpretation is that “simple storage” of corrosive chemicals is (more or less—we’ll see how the play on the field reflects this) off the table in terms of having to have an eyewash station (fortunately for all of us, containers of corrosive chemicals tend not to explode on their own…). Where you do need to provide access (or at least consider) are locations where corrosive chemicals are used/mixed/ dispensed. And this is where it is of critical importance to do your due diligence when it comes to the risk assessment; corrosive (and caustic) chemicals that are injurious to the eye (and other parts) are where you cross the line into eyewash stations. And given the recent funkiness regarding disinfectant cleaners and a return to bleach as a frequently used disinfectant agent, I suspect that there’s going to be a lot of attention to where bleach is being, well, used, mixed and/or dispensed. This is going to present more than its share of challenges in the field, I suspect…

Interesting point in the explanatory section of the piece; there’s a link to an OSHA interpretation that is instructive, but could be confusing as it deals specifically with electric battery storage charging and maintenance areas. Clearly, the focus is (and should be) on managing those most hazardous chemicals, etc. that we might use in the workplace, so it will be interesting to see how this unfolds over the next survey cycle.

As a closing thought (and this it definitely out of left field), I’m not sure how many EVS folks are out there in the audience, but one condition I’ve been encountering with a fair amount of frequency (and not just in hospitals—I look at this stuff wherever I go) are baby changing tables for which the safety belts have either gone missing or been damaged, etc. I know it’s not a big thing (unless you’re a parent with a squirmy infant), but (if you look at it wearing your ugly surveyor hat) you could make the case that if it’s something provided by the manufacturer, then the expectation is for the equipment, etc., to be maintained in accordance with the manufacturer’s Instructions For Use. It’s not something you have to do all the time (unless somebody is swiping them), but it might be worth scheduling a “sweep” of your changing tables from time to time.

Until next time: Be well and stay safe!

Masking Tape/Taping Masks: Essential PPE is still in the mix…

As 2020 continues to roll along with no apparent respite from dealing with COVID on the horizon, it’s probably not a bad idea to share some PPE-related resources with folks. I suspect that pretty much no one out there in the studio audience has the time to bolt down the rabbit holes of the interweb, but here are a few links to some (hopefully) useful resources:

When it comes to PPE, it’s always important to keep an eye on the folks at the Occupational Safety & Health Administration, who have provided some guidance relative to the use of PAPRs for personal protection. It has the appearances of being somewhat flexible in certain instances, but enforcement is still enforcement, so if you’ve got PAPRs in the mix, worth checking out.

Next up, the good folks at ECRI have pulled together a number of PPE-related resources to ensure that we’re providing appropriate/effective PPE to those folks on the front lines who are at the greatest risks of occupational exposure. If you think all this stuff kind of sounds like a risk assessment opportunity, I would be inclined to agree. At some point (hopefully sooner rather than later), when move on to the new “new” normal, our regulatory friends are going to be curious to find out how we “knew” that we were adequately protecting folks and, since they’ve been rather reluctant to accept performance data without some sort of assessment framework, these should work well within the confines of the documented risk assessment process.

Here they are:

While shoe covers don’t really fall under the PPE category in general (though sometimes they can), for anyone who has ever struggled with putting on shoe covers before “bunnying up” to go in the OR, I thought this might be a good for the end-of-the-year holiday wish list (I know it’s on mine—as soon as they make one that’s portable), check out the Bootie Butler. I’ve only seen this item in a pharmacy clean ante room, but I found it intriguing.

As always, I hope this finds you well and staying safe. I figure every day brings us closer to the end of this (and I suppose there’s a certain inescapable logic to that). I hope…

We advance, masked!

In the topsy turvy world of Personal Protective Equipment (aka PPE), there are some developments on the decontamination/reprocessing of masks that I wanted to bring to your attention, if you’ve not already scoped them out.

First up, a little more information from our friends at the Occupational Safety & Health Administration, where we find that the guidance issues to surveyors is to be somewhat judicious in how they chase issues relating to PPE, but the basic expectations of employers look like this:

  • Make a good-faith effort to provide and ensure workers use the most appropriate respiratory protection available for the hazards against which workers need to be protected. Efforts should be consistent with flexibilities outlined in OSHA’s previous COVID-19 enforcement memoranda.
  • When respirators must be decontaminated to facilitate their reuse in ways consistent with OSHA’s previous COVID-19 enforcement memoranda and the U.S. Centers for Disease Control and Prevention (CDC) Strategies for Optimizing the Supply of N95 Respirators, ensure that decontamination is accomplished according to the methods described above and detailed in CDC’s Decontamination and Reuse of Filtering Facepiece Respirators using Contingency and Crisis Capacity Strategies.
  • Ensure users perform a user seal check each time they don a respirator. Employers should not permit use of a respirator on which the user cannot perform a successful user seal check. See 29 CFR § 1910.134, Appendix B-1, User Seal Check Procedures.[11]
  • Train employees to follow appropriate precautionary measures prior to using a decontaminated filtering facepiece respirator (FFR). See cdc.gov/coronavirus/2019-ncov/hcp/ppe-strategy/decontamination-reuse-respirators.html.
  • Train employees using decontaminated respirators to understand that if the structural and functional integrity of any part of the respirator is compromised, it should not be used by that individual as respiratory protection. The inability to achieve a successful user seal check could be an indicator that the integrity of the respirator is compromised.
  • Visually inspect, or ensure that workers visually inspect, the FFRs to determine if the structural and functional integrity of the respirator has been compromised. Over time or as a result of the decontamination process, components such as the straps, nose bridge, and nose foam material may degrade, which can affect the quality of the fit and seal.
  • Train employees on the procedures for the sequence of donning/doffing to prevent self-contamination. See cdc.gov/niosh/npptl/pdfs/PPE-Sequence-508.pdf.
  • If no manufacturer or third-party guidance or procedures are available to support the specific decontamination method(s) employed, avoid the use of decontaminated FFRs when healthcare personnel perform surgical procedures on patients infected with, or potentially infected with, SARS-CoV-2 or perform or are present for procedures expected to generate aerosols or procedures where respiratory secretions are likely to be poorly controlled (e.g., cardiopulmonary resuscitation, intubation, extubation, bronchoscopy, nebulizer therapy, sputum induction). If decontamination methods degrade FFR performance, including filtration and fit, or otherwise affect structural integrity, the decontaminated FFR may not provide the level of protection needed or expected during aerosol-generating procedures.

I suspect that, in general, folks are being sufficiently attentive to their PPE (perhaps more than has ever been the case) that they are checking for integrity (though they may not be as familiar with the User Seal Check Procedure—could be a teachable moment). And the missive covers some decontamination methodologies that may be of interest, particularly in light of the FDA’s altered stance on decontamination and reprocessing of masks.

I guess the questions become those related to available supplies of PPE. I get the sense that some folks are still relying to a fair degree on the use of masks that are not NIOSH-approved and so this latest development could potentially mean that, in the absence of being able to decontaminate and reprocess, the supply chain is going to have to be considerably more robust in either providing more non-NIOSH masks or more NIOSH masks that can be appropriately decontaminated, etc. I’d be curious to hear of any experiences (good or not so) that you’ve had in this regard. It seems likely that, even as we try to get to the “new normal,” we’re going to be dealing with this for a while, so we might as well share the good, the bad, and the ugly.

Speaking of which (sort of), as a closing thought for this week, now that I am hanging out in airports again, one thing that I’ve noticed is the phenomenon of the smile that doesn’t reach someone’s eyes. Pre-mask, I don’t know that I analyzed transient interactions with folks, but I find myself responding to folks based on their “eye language” and I’ve found that it can turn what would typically be a (more or less) neutral transaction into a positive or negative. I suspect that most customer service training involves reminding folks to smile, but now that our smiles have been temporarily removed from the occasion, the eyes are all we have for first impressions. Don’t know if that’s useful to you, but something to ponder.

Be well and stay safe ’til next time!

A little mo’ from the Mighty O (ccupational Safety & Health Administration)

As they are wont to do, the folks at OSHA periodically issue safety alerts and it would seem that the ongoing challenges of managing the ongoing occupational health and safety aspects of COVID-19 is ripe for alerting. You can find the complete list of alerts on OSHA’s COVID-19 homepage.

Interestingly enough, OSHA has not (as of this writing) issued an alert specific to hospitals, but they did recently issue an alert aimed at nursing homes and long-term care facilities, the elements of which are, at the very least, instructive for other folks in the healthcare demographic; you can find the alert in its entirety here. I just wanted to plant a seed relative to a few of these:

  • Maintain at least 6 feet between workers, residents, and visitors, to the extent possible, including while workers perform their duties and during breaks.
  • Stagger break periods to avoid crowding in breakrooms.
  • Always follow good infection prevention and control practices. Consult OSHA’s COVID-19 guidance for healthcare workers and employers.
  • Provide handwashing facilities and alcohol-based hand sanitizer with at least 60% alcohol throughout facilities.
  • Regularly clean and disinfect shared equipment and frequently touched surfaces in resident rooms, staff work stations, and common areas.
  • Use hospital-grade cleaning chemicals approved by the Environmental Protection Agency (EPA) from List N or EPA-approved, hospital grade cleaning chemicals that have label claims against the coronavirus.
  • Ensure workers have and use any personal protective equipment (PPE) they need to perform their jobs safely.
  • Continually monitor PPE stocks, burn rate, and supply chains. Develop a process for decontamination and reuse of PPE, such as face shields and goggles, as appropriate. Follow CDC recommendations for optimization of PPE supplies.
  • Train workers about how to protect themselves and residents during the pandemic.
  • Encourage workers to report any safety and health concerns.

I don’t know that there’s anything on the list that doesn’t make sense, but I do think it might be useful/beneficial to keep an eye on these (and the other elements) to ensure you and your folks are not at elevated risk for exposure. Admittedly, there is still a lot we don’t know about the epidemiological aspects of COVID-19 and it may result in additional levels of guidance and/or protection (remember those halcyon days when masks were not required—seems like only months ago—oh, wait, I guess it was…). I also think it’s important to hear folks out if they voice frustrations with process, etc. A fair amount of this stuff is learning as we go—and making the best decisions we can based on the available information—in full recognition that being a leader in healthcare can mean having to put up with some unpleasant feedback. I think some folks in the field remain super concerned and super attentive to the decisions others are making on their behalf, so it’s important to keep things on an even keel.

Until next time, continue to stay safe—and keep rocking it!

Will it go ’round in circles? A couple more pieces of the COVID-19 pie

As I try to embrace brevity as the soul of wit (which is likely to be as close to Shakespearean as this space is ever likely to venture), I have just a couple of resources to share with you folks this week. I do hope this finds you settling in (at least somewhat) to the current reality and the “new” stressors have subsided a bit.

Clearly, there’s been a lot of discussion regarding the protection of healthcare workers, mostly as a function of providing essential personal protective equipment (and the struggles that folks have faced in procuring said PPE). What is somewhat sketchier at the moment it to how organizations/employers are going to be held accountable for worker protection in the aftermath of the pandemic condition. But you might be able to gain some sense of things by consulting our friends at the federal Occupational Safety & Health Administration. While the OSHA website does speak of “discretion” in enforcement activities when considering an employer’s “good faith” efforts, I think it will be of critical importance that we be able to speak to a risk assessment to determine where folks jobs/tasks fall on the exposure continuum. OSHA indicates a spread of low, medium, high, and very high as risk categories with the enjoinder “(u)ntil more is known about how COVID-19 spreads, OSHA recommends using a combination of standard precautions, contact precautions, airborne precautions, and eye protection (e.g., goggles, face shields) to protect healthcare workers with exposure to the virus.” They also encourage the use of the Centers for Disease Control & Prevention as the primary source of current strategies, etc., so we can all work from the same source.

One of the other common threads of discussion relates to the disinfection of surfaces, etc., for which I would encourage you to check out the Environmental Protection Agency’s list of approved disinfectants (hopefully whatever your organization is using is on the list; not necessarily a deal-breaker if it isn’t, but there are always risks when one goes off-list). I keep reflecting on the reality that, in all likelihood, we won’t know what worked/didn’t work, etc., until this is long past it’s point of criticality, so it’s important to make sure that we can evidence a thoughtful process in identifying strategies. As of this writing (April 21), there does seem to be a growing unrest to get things back to normal, with some states opting to employ less restrictive strategies for distancing (in all its many permutations—who knew?). I am hopeful that we won’t be having this same discussion a month (or two months) from now if there is a resurgence, but it does seem inopportune to try and short-circuit a process before we have enough data to support easing up on things. I guess it all goes back to what they say about time—it will tell!

Stay safe!

I sit at my table and wage war on myself—and earn an OSHA citation!

While I have a sneaking suspicion that this Top 10 list doesn’t change a whole lot from year to year (other than position in the hierarchy), I thought it would be of interest to trot out which occupational safety considerations are manifesting themselves across industries. I can certainly see where any of these might crop up in healthcare.

And so, to the list:

10: Personal Protective and Lifesaving Equipment – Eye and Face Protection

9: Machine Guarding

8: Fall Protection – Training Requirements

7: Powered Industrial Trucks

6: Ladders

5: Respiratory Protection

4: Lockout/Tagout

3: Scaffolding

2: Hazard Communication

1: Fall Protection

Again, no big surprises, but I guess it does point out some areas for future consideration, mostly as a function of initial and ongoing safety education. These are the types of things, especially when dealing with contractors, that can result in a very uncomfortable situation if something goes sideways on your campus—even if it’s not your staff. Once the Big O gets through the door, it’s tough to contain their interest in all things safety.

Closing out this week, one of the questions that seems to be coming up with greater frequency during Joint Commission surveys relates to how your organization determines that the individual(s) tasked with doing your rated door inspections are knowledgeable/competent (we know from our intense scrutiny of NFPA 80 that these folks do not need to be certified; it is a handy way to demonstrate that an individual is knowledgeable, but you can certainly evaluate/validate competency in other ways). And pondering that equation made me a little more interested in the following news story than might normally have been the case (there isn’t a time when I wouldn’t have been interested, but this was an especially telling confluence). It seems that an individual has been accused of defrauding some VA hospitals by billing them for work that had not been performed; a little more detail can be found here. I know a lot of folks have struggled over the years with vendors who prefer to “come and go as they please,” which typically results in less control over the process, including timely notifications of discrepancies. I’m curious as to how this ends up when it makes its way through the courts, but I can see a time when those pesky surveyors might start to ask about how one knows that the service for which they have documentation actually occurred. Hopefully this case is all a big misunderstanding and there were no real gaps in oversight…

Eat, drink, and be safe: Some guidance on the care and feeding of staff

One of the more universal conditions I find is the whole issue of where staff can grab something to eat or drink in the midst of busy periods, particularly when staffing levels don’t necessarily dovetail with leaving the work space to go to the cafeteria, etc. And there’s always the specter of someone, somewhere having invoked the “You can’t eat there, it’s against TJC regulations” or “You can’t drink there, it’s against regulations” and so forth and so on. And what better strategy than to use a regulatory presence from outside the organization to be the heavy.

Many’s the time I’ve tried to convince folks that, from a regulatory perspective (with some fairly well-defined exceptions, like laboratories), there is nothing that approaches a general prohibition when it comes to the how, when, and where of eating and drinking in the workplace (and yes, I absolutely understand that prohibition is the easiest thing to “police,” but I think prohibitions also tend to “drive” more creative workarounds). And in the March 2019 edition of Perspectives, our friends in Chicago provide a couple of clarifications for folks, and if you think that there’s a risk assessment involved, then you would be correct.

So, the clarifications are two in number:

  • There are no TJC standards that specifically address where staff can have food or drink in the work areas.
  • You can identify safe spaces for food and drink as long as those locations  comply with the evaluation (read: risk assessment) of the space and your exposure control plan as far as risks of contamination from chemicals, blood, or body fluids, etc.

The guiding light in all of this, if you will, are the regulations provided by the Occupational Safety & Health Administration, and while they have a lot to say about such things (Bloodborne Pathogens and Sanitation), a careful analysis should yield a means of designating some spaces. I have seen a lot of designated “hydration stations,” particularly in clinical areas, to help keep folks hydrated over the course of the working day, so clearly some folks are working towards providing some flexibility based on a risk assessment. This is a good thing both in terms of staff support, but also in not drawing a line in the sand that they don’t have to. Prohibitions can bring about some of your toughest compliance challenges, so if you can work with folks to build in some flexibility, it could mean fewer headaches during rounding activities.