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Blame it on Cain…

We’ll see how long this particular screed goes on when we get to the end…

In my mind (okay, what’s left of it), the “marketing” of safety and the management of the physical environment is an important component of your program. I have also learned over time that it is very rare indeed when one can “force” compliance onto an organization. Rather, I think you have to coax them into seeing things your way. At this point, I think we can all agree that compliance comes in many shapes, colors, sizes, etc., with the ideal “state” of compliance representing what it is easiest (or most convenient) for staff to do. If we make compliance too difficult (both from a practical standpoint, as well as the conceptual), we tend to lose folks right out of the gate—and believe you me—we need everybody on board for the duration of the compliance ride.

For instance, I believe one of the cornerstone processes/undertakings on the compliance ride is the effectiveness of the reporting of imperfections in the physical environment (ideally, that report is generated in the same moment—or just after—the imperfection “occurs”). There are few things that frustrate me more than a wall that was absolutely pristine the day before, and is suddenly in possession of a 2- to 3-inch hole! There’s no evidence that something bored out of the wall (no debris on the floor under the hole), so the source of the hole must have been something external to the hole (imagine that!). So you go to check and see if some sort of notification had occurred and you find out, not so much. Somebody had to be there when it happened and who knows how many folks had walked by since its “creation,” but it’s almost like the hole is invisible to the naked eye or perhaps there’s some sort of temporal/spatial disruption going on—but I’m thinking probably not.

I’m reasonably certain that one can (and does) develop an eye/sense for some of the more esoteric elements of compliance (e.g., the surveyor who opens a cabinet drawer, reaches in, and pulls out the one expired item in the drawer), but do we need to educate folks to recognize holes in the wall as something that might need a wee bit of fixing? It would seem so…

At any rate, in trying to come up with some sort of catch phrase/mantra, etc., to promote safety, I came up with something that I wanted to share with the studio audience. I’d appreciate any feedback you’d be inclined to share:

WE MUST BE ABLE:

CAPABLE

RELIABLE

ACCOUNTABLE

SUSTAINABLE

I’m a great believer in the power of the silly/hokey concept when you’re trying to inspire folks; when you think of the most memorable TV ads, the ones that are funny tend to be the most memorable in terms of concept and product (the truly weird ads are definitely memorable, but more often than not I couldn’t tell you what product was being advertised). I think that as a four-part vision, the above might be pretty workable. What do you think?

Sometimes you have to ignore what your parents told you

Well, maybe ignore is a bit strong…

One of the recurring themes from my childhood was the not-infrequent exhortation from my mother: Don’t go looking for trouble (probably not an uncommon theme for everyone out there in the studio audience). But one of the more common themes that I’ve been running into are those instances in which trouble was lurking in the weeds, but folks weren’t necessarily successful in identifying/locating trouble spots. As near as I can tell, the worst thing that can happen during a survey (from a safety perspective) is when a surveyor identifies a condition or a practice about which you had no clue. It doesn’t happen a lot, but it does happen (usually followed by “Wow, I didn’t know that”).

There are a number of reasons for such a happenstance—sometimes folks really don’t know about something (though, dear reader, you are probably not in that number as we discuss a whole bunch of esoteric stuff). For instance, I still get a lot of folks who (and I have to believe that they are being completely candid) don’t know that hand sanitizer expires (or medicated lotion soap…or disinfectant wipes) or they are supremely confident that that is someone else’s concern (usually EVS when it comes to the many soaps, sanitizers, and disinfectants that populate the healthcare landscape). To my mind, it all goes back to the role of point of care/point of service folks (and I give the caregivers equal billing/accountability with the service-givers on this count) in being able to identify and report or otherwise manage risks in the physical environment.

But we as safety professionals have to be wicked diligent (as I pen this, it’s the day after the Boston Marathon, so that’s my gratuitous reference to Boston cultchah) in really working to ferret out all these little foibles, imperfections, etc. I think I’ve said this before in this forum (and no doubt will again), but whichever regulatory survey team shows up at your front/back/side door, they are going to find “stuff”—the human condition does not easily attain perfection, which leaves us vulnerable, vulnerable, vulnerable.

I recognize that everyone is stretched for time—too many meetings, too many spreadsheets, too many “too manys” to count—which only serves to “push” the maximization of the not-enough’s (not enough time, not enough resources, not enough support) in this adventure. Think of it as a challenge—there are folks out there doing stuff you would rather they not do—sometimes you only see the result (damaged walls and doors, unsealed penetrations, spills, thrills, chills) and we all have to be more effective in keeping on top of things.

Past lessons learned are a wonderful thing, but sometimes you have to go at things a little differently, so go out there and find some trouble spots. You’ll be glad you did!

 

This American Hospital: HAIs resulting from exposure to lead

As I think I’ve mentioned in the past, I listen to a fair amount of public radio when I’m in the car, and this past Saturday, I stumbled (I’ve found that my errands don’t always coincide with the start and end of programs—thank the gods of radio for podcasts and other forms of re-broadcast) into the middle of a story that I found quite compelling. The program itself is called This American Life and emanates from WBEZ in Chicago; the nominal purpose of the program is to provide a forum for the airing of stories about (natch!) This American Life, which allows it to cover a lot of ground. I always find the stories pretty interesting/compelling, etc., but this past weekend’s episode really got me thinking about the ongoing struggles faced by hospitals as they try to balance security, workplace violence management, the management of behavioral health patients, education of staff in being able to effectively manage crisis situations, etc. Basically, the whole gamut of issues relating to the continuing disenfranchisement of the behavioral health patient community. There are some places that do pretty well with this, but I think the opportunities to do better far outweigh the improvements made so far (that’s as close to editorializing as I’m going to do for the moment).

As I think about it, while Joint Commission compliance is probably THE hot button item when it comes to the management of risks and conditions in the physical environment, I truly believe that, at least for the folks who are typically responsible for managing the physical environment, this topic is by far the more complicated—very much in line with the prevention of healthcare-acquired infections—and, interestingly enough, there can be a crossover, but more on that in a moment.

The story deals with a “delusional” (my quotes) patient who, in the course of his stay in a hospital (you can find out a lot of the details by listening to the episode, which can be found here) encountered a situation in which he did indeed contract an HAI because of an exposure to lead, namely a bullet fired by a police officer in this patient’s hospital room. Now (trying not to sound too old), back in my days of operational responsibility, I have overseen dealings with behavioral health patients, on-duty police officers discharging their weapons in the ED, folks injured as a result of physical encounters with patients, etc. But I have to tell you (and at least some of this is the power of the storytelling in conjunction with the story being told), the sequence outlined in the episode is about as harrowing as you could imagine: not very good decisions are made and sustained; family members are perhaps not embraced as a source of useful information (I’m trying to avoid more editorializing—but tell me the story doesn’t ring some bells with you, particularly  if you’ve had operational responsibility for security), staff are perhaps not as well-prepared as they might otherwise be—a real cluster of ugliness.

I know things are never as cut and dried as they seem to be in the aftermath; you might find the “official” response from the hospital a little curious (I did as well, but I understood the forces in play—sounds like there might still be some lingering litigation), but this type of confluence of events is all too easy to imagine. I think it’s definitely in the best interests for the safety/security community to advocate for the management of these types of patients based on the underlying causes (mental illness, behavioral health issues) and not just a panicked response to the symptoms. Yes, we will always have that quotient of patients who are just [insert epithet of your choice here]. But safe care can’t be sacrificed in the rush—safe for the patients, safe for the staff.

Fear is not sustainable

A Welshman of some repute once noted that “fear is a man’s best friend” and while that may have been the case in a Darwinian sense, I don’t know that the safety community can rely as much on it as a means of sustainable improvement. I’ve worked in healthcare for a long time and I have definitely encountered organizational leaders that traded in the threat of reprisal, etc., if imperfections were encountered in the workplace (and trust me when I say that “back in the day” something as simple as a match behind a door—left by a prickly VP to see how long it stayed there—could result in all sorts of holy heck), it typically resulted in various recriminations, fingerpointing, etc., none of which ended up meaning much in the way of sustained improvement. What happened was (to quote another popular bard—one from this side of the pond), folks tended to “end up like a dog that’s been beat too much,” so when the wicked witch goes away, the fear goes too, and with it the driving force to stay one step ahead of the sheriff (mixing a ton of metaphors here—hopefully I haven’t tipped the obfuscation scales).

At any rate, this all ties back to the manner in which the accreditation surveys are being performed, which is based on a couple of “truisms”:

 

  1. There is no such thing as a perfect building/environment/process, etc.
  2. Buildings are never more perfect than the moment before you put people in them.
  3. You know that.
  4. The regulators know that.
  5. The regulators can no longer visit your facility and return a verdict of no findings, because there are always things to find.
  6. See #1.

Again, looking at the survey process, the clinical surveyors may look at, I don’t know, maybe a couple of dozen patients at the most, during a survey. But when it comes to the physical environment, there are hundreds of thousands of square feet (and if you want to talk cubic feet, the numbers get quite large, quite quickly) that are surveyed—and not just the Life Safety (LS) surveyor. Every member of the survey team is looking at the physical environment (with varying degrees of competency—that’s an editorial aside), so scrutiny of the physical environment has basically evolved (mutated?) since 2007 from a couple hours of poking around by an administrative surveyor to upwards of 30 hours (based on a three-day survey; the LS surveyor accounts for 16 hours, and then you will have the other team members doing tracers that accounts for at least another 16 hours or so) of looking around your building. So the question really becomes how long and how hard will they have to look to find something that doesn’t “smell” right to them. And I think we all know the answer to that…

It all comes back (at least in my mind’s eye) to how effectively we can manage the imperfections that we know are out there. People bump stuff, people break stuff, people do all kinds of things that result in “wear and tear” and while I do recognize that the infamous “non-intact surface” makes is more difficult to clean and/or maintain, is there a hospital anywhere that has absolutely pristine horizontal and vertical surfaces, etc.? I tend to think not, but the follow-up question is: to what extent do these imperfections contribute to a physical environment that does not safely support patient care? This is certainly a question for which we need to have some sense of where we stand—I’m guessing there’s nobody out there with a 0% rate for healthcare-acquired infections, so to what degree can we say that all these little dings and scrapes do not put patients at risk to the extent that we cannot manage that level of risk? My gut says that the environment (or at least the environmental conditions that I’m seeing cited during surveys) is not the culprit, but I don’t know. As you all know by now (if you’ve been keeping tabs on me for any length of time), I am a big proponent of the risk assessment process, but has it come to the point where we have to conduct a risk assessment for, say, a damaged head wall in a patient room? Yes, I know we want to try and fix these types of conditions, but there are certain things that you can’t do while a patient is in the room and I really don’t think that it enhances patient care to be moving patients hither and yon to get in and fix surfaces, etc. But if we don’t do that, we run the risk of getting socked during a survey.

The appropriate management of the physical environment is a critical component of the safe delivery of healthcare and the key dynamic in that effort is a robust process for reporting imperfections as soon as possible (the “if you see something, say something” mantra—maybe we could push on “if you do something, say something”) so resources can be allocated for corrective actions. And somehow, I don’t think fear is going to get us to that point. We have to establish a truly collaborative, non-knee-jerk punitive relationship with the folks at the point of care, point of service. We have to find out when and where there are imperfections to be perfected as soon as humanly possible, otherwise, the prevalence of EC/LS survey findings will continue in perpetuity (or something really close to that). And while there may be some employment security pour moi in that perpetual scrutiny, I would much rather have a survey process that focuses on how well we manage the environment and not so much on the slings and arrows of day-to-day wear and tear. What say you?

If you set things up correctly…they will still find stuff!

Those of you who are frequent readers of this little space are probably getting tired of me harping on this subject. And while I will admit that I find the whole thing a tad disconcerting, I guess this gives me something to write about (the toughest thing about doing the blog is coming up with stuff I think you folks would find of interest). And so, there is an extraordinary likelihood that you will have multiple EC/LS findings during your next triennial Joint Commission visit—and I’m not entirely convinced that there’s a whole lot you can do to prevent that from happening (you are not powerless in the process, but more in that in a moment).

Look at this way: Do you really think that you can have a regulatory surveyor run through your place for two or three days and at the end “admit” that they couldn’t find any deficiencies? I’ve worked in healthcare long enough to remember when a “no finding” survey was possible, but the odds are definitely stacked against the healthcare professionals when it comes to this “game.” And what amazes me even more than that is when folks are surprised when it happens! Think about, CMS has been taking free kicks on TJC’s noggin for almost 10 years at this point—because they weren’t finding enough issues during the triennial survey process. BTW, I’m not saying that there’s a quota system in place; although there are certainly instances in which surveyors over-interpret standards and performance elements, I can honestly say that I don’t find too many findings that were not (more or less) legitimate. But we’re really and truly not talking about big-ticket scary, immediate jeopardy kind of conditions. We are definitely talking mostly about the minutiae of the safety world—the imperfections, if you will—the slings and arrows of outrageous fortune that one must endure when one allows humans to enter one’s hallowed halls. People mess stuff up. They usually don’t mean to (though there are some mistakes, and I think you can probably think of some examples in your own halls), but as one is wont to say, feces occurs. And there’s a whole segment of each healthcare organization charged with cleaning up that feces—wherever and however it occurs.

So what it all comes down to is this: you have to know what’s going on in your building and you have to know where you stand as a function of compliance, with the subset of that being that you have to have a robust process for identifying conditions soon enough and far enough “upstream” to be able to manage them appropriately. We’ve discussed the finder/fixer dynamic in the past (here’s a refresher), so I won’t belabor that point, but we need to use that process to generate compliance data. Strictly speaking, you really, really, really need to acquaint yourselves with the “C” Elements of Performance; compliance is determined as a rate and if you can demonstrate that your historical compliance rate is 90% or better, then you are in compliance with that standard/EP. But if you’re not using the surveillance process, the finder/fixer process, the tracer process, the work order process, the above the ceiling permitting process, ad nauseum, to generate data that can be used to determine compliance, then you are potentially looking at a very long survey process. Again, it goes back to my opening salvo; they are going to find “stuff” and if you are paying good attention to what goes on in your organization, then they shouldn’t be able to find anything that you don’t already know about.

The management of the physical environment is, at its heart, a performance improvement undertaking. As a support process for hardwiring ongoing sustained improvement, a process for the proactive risk assessment of conditions in the physical environment is essential. As an example, the next assessment would use the slate of findings from your most recent surveillance rounds to extrapolate the identification of additional risks in the physical environment. For all intents and purposes, it is impossible to provide a physical environment that is completely risk free, so the key focus becomes one of identification of risks, prioritizing the resolution of those risks that can be resolved (immediate and long-term), and to develop strategies for managing those risks that are going to require resource planning and allocation over an extended period of time. The goal of the process is to ensure that the organization can articulate the appropriate management of these risks and to be able to provide data (occurrence reporting, etc.) to support the determination of that level of safety. By establishing a feedback loop for the management of risk, it allows the organization to fully integrate past actions into the improvement continuum. If you think of the improvement continuum as a football field (it is, after all, the season for such metaphors) or indeed any game “environment,” you need to know where you are in order to figure out where you need to go/be. The scrutiny of the physical environment has never been greater and there’s no reason to think that that is going to change any time soon. Your “power” is in preparing for the survey by being prepared to make full use of the post-survey clarification process—yup, they found a couple of doors that didn’t close and latch, a fire extinguisher that missed a monthly inspection or two, and on and on. Anticipate what they’ll find based on what you see every time you “look” (again, it’s nothing “new” to you—or shouldn’t be) and start figuring out where you are on the grid. That way, they can find what they want (which they will; no point in fighting it anymore) and you can say, thanks for pointing that out, but I know that my compliance rate for doors/fire extinguishers/etc. is 90%, 91%, 92%, etc. We want them to work very hard to find stuff, but find stuff they will (that’s a little Yoda-esque). We just have to know what do “aftah.”

The final countdown

One of the things I’ve noticed in my journey through the highways and byways of healthcare is that we do an awful lot of education. The one compelling example that springs to mind is the challenges we’ve had over the last decade involves the appropriate storage/management of compressed gas cylinders. For years we struggled with getting folks to place the cylinders in an appropriate stand or rack; in some instances, we had to share folks some of those lovely videos of what can happen when an unrestrained cylinders becomes violently “active” (something like this one).

Now, I am happy to report that  it appears that we eventually got folks to come to grips with this (though I still periodically run into pockets of resistance), but now we have a new “foe” in the management of compressed gas cylinders—segregating full and not full cylinders. Now I know that we’ve discussed this in the past, but the thought that I have circling what’s left of my brain is this: recognizing how long it took to get folks to play nice, (so to speak) with appropriately securing those pesky e-cylinders, is there a way we can gain compliance in a more accelerated fashion?

To that end, I would ask you to think about how we did the cylinder restraint education and to come up with a way (or perhaps you already have, in which case, please share) to evaluate the education process. Again, we do a ton of education and yet we still have staff (and others; can’t forget some of those lovely contractors) who do stuff that we don’t want them to do. I harbor no illusion that we can completely eliminate undesirable behaviors, but I think we should be able to improve our “situation” to the point that perhaps only five of the most frequently cited standards reside in the physical environment. Do I hear four? Three? Two? One? What do you think?

Cue the drum roll: Ladies and gentlemen, I give you the Portal of Perception!

Not so very long ago, The Joint Commission and ASHE announced the creation of an information resource to assist with all those pesky EC/LS findings that have been reproducing like proverbial rabbits (here’s coverage of that announcement  and coverage of those rapidly reproducing findings).

Well, since that announcement, the elves have been very busy cobbling together bits and pieces of this and that, with the end result being a rather interesting blend of stuff (please note that I did not employ the more severe descriptor—stuff and nonsense), with titles like “Is Your Hospital’s Air Ventilation System Putting Your Patients At Risk?” (this one’s in the Leadership module, so I guess they’re asking the question of organizational leadership). I truly hope that your response to that particular query would be “absolutely not,” but I’ve also been working this part of the street long enough to know (absolutely, if you will allow me a brief moment of hyperbole) that there are few absolutes when it comes to the management of the physical environment.

Which leads me to the follow-up thought: Recognizing that there is always the potential for the performance of air ventilation systems to drift a little out of expected ranges, at what point does the performance of air ventilation systems actually put patients at risk? And perhaps most importantly, have you identified those “points” in the performance “curve” that result in conditions that could legitimately cause harm to our patients? And please know that I understand (in perhaps a very basic sense, but I think I can call it an understanding) how properly designed and maintained HVAC systems contribute to the reduction of HAIs, etc. But with any fluid situation, there is an ebb and a flow to conditions, etc., that, again, may veer into the “red” zone from a compliance standpoint. But let me ask you—particularly those of you who have experienced out-of-range conditions/values—have those conditions resulted in a discernible impact on your infection control rates, especially those relating to surgical site infections?

BTW, I’m asking because I really don’t know what you folks are experiencing. And, for those of you that have identified shortcomings on the mechanical side of things, are your Infection Control folks keeping a close (or closer) eye on where those shortcomings might manifest themselves as a function of impact to patients? From the information posted in the Portal (I think I’m going to capitalize), remedying compliance issues in this regard is a simple four-step process (You can find the example of improved compliance there). Who knew it would be so easy? (I could have had a V8!) I don’t think anyone in the field is looking at this as a simple, or easy, task.

At any rate, despite the best efforts of the Portal, until we have buildings (and staff) that are a little closer to perfect, I think we’re going to continue to see a lot of EC/LS findings during survey. Ohboyohboyohboyohboyohboy!

Also, as I think about it, please be sure to check out the Clarifications and Expectations column in the September issue of Joint Commission Perspectives; there are some interesting points to be gleaned, the particulars of which we will cover in a wee bit, so watch this space!

I’m-a gonna raise a fuss and I’m-a gonna raise a holler!

Sometimes, particularly during the summer, it can be a challenge to come up with compelling—hopefully your definition of compelling and my definition of compelling match up pretty well—material for the blog, so I will periodically go back through e-mails I’ve received, etc. to see if there’s anything worth sharing with folks. I was trolling through my inbox for missives from our friends in Chicago that I might have missed when they originally arrived (so, I guess this would be a review of missed missives) and I noticed an item from back in June that I had not previously brought to your attention that highlighted some of the resources available in the area of emergency management. Strangely enough, the resources are available as part of the The Joint Commission’s (TJC) portal program, thus the Emergency Management Portal.

There’s a fair amount of interesting information (and I think we all recognize the value of being familiar with any information TJC sees fit to present to the world at large), with click-through links for topics such as air disaster, violence/security/active shooter, hurricane, tornado, water crisis (industrial incident), and winter storm. The June notice deals with some topics relating to crisis management guidance and senior leadership (if you’ve noticed a trend towards elevating accountability/involvement of senior leadership in the physical environment/emergency management realm, I wouldn’t disabuse you of that notion) will take you to those details. Other than the leadership stuff, it doesn’t appear that there’s been a ton of updating since the beginning of 2014, but one item highlighted on the portal home page is a link to a blog on John Maurer’s (he’s one of the folks in TJC’s Engineering Department) Q & A during the November 2013 JCR Annual Ambulatory Care Conference. While the content is “aimed” at ambulatory care, there is a certain “timeless” quality to the questions and even if you are not currently responsible for any ambulatory sites, if you intend to stay in healthcare, it is more than likely that you’ll be getting in to the care and feeding of some ambulatory sites before too long. At any rate, I always enjoy Mr. Maurer’s work and if you’ve not encountered him, I think you will too. If you want to bypass the portal, you can link directly to the Q & A. It shouldn’t take too long to go through the blog, but I think you’ll find it to have been time well spent.

Oh no, Mr. Bill!

I always view with great interest the weekly missives coming from The Joint Commission’s various house organs, particularly when there’s stuff regarding the management of the physical environment. And one of the more potentially curious/scary “relationships” is that between the good folks in Chicago and the (I shan’t editorialize) folks at the Occupational Safety & Health Administration. They’ve had a nodding acquaintance over the years, but there is evidence in some quarters (I’ve seen a decided uptick in survey findings relating to hazardous materials and waste inventories—as we’ve noted before, a list of your Safety Data Sheets is not going to be enough on its own to satisfy a finding of compliance with the Hazard Communications standard), that concerns relative to occupational health and safety are becoming a target area during Joint Commission surveys.

At any rate, last week, buried in last Wednesday’s action-packed edition of Joint Commission Online, there was an item highlighting the OSHA updates of key hazards for investigators to focus on during healthcare inspections.

Now I can’t imagine that the list of key hazards would come as a surprise to anyone in the field (in case you were wondering, they are: musculoskeletal disorders (MSD) related to patient or resident handling; bloodborne pathogens; workplace violence; tuberculosis; and slips, trips and falls—surprise!), as these are pretty typically the most frequently experienced occupational risks in our industry. What remains to be seen, and what I suspect we need to be keeping in mind as the wars for accreditation supremacy continue, is whether this OSHA guidance translates across to TJC survey methods and practices (I don’t think TJC is as “beholden” to OSHA as they are to CMS, but who knows what the future may hold). That said, I don’t think it would be unwise or in any way inappropriate to shine as much “light” as possible on your organization’s efforts to manage these occupational risks. I’m guessing your most frequently experienced occupational illness and injury tallies are going to include at least two or three of the big five (I suspect that TB may be the least frequent for hospitals, though if you count unprotected/unanticipated exposures, the numbers might be a little higher). Perhaps (if you have not already done so) some performance indicators relating to the management of these risks (successful or unsuccessful) might be a worthwhile consideration as we continue through the EC/safety evaluation cycle (I know some of you are doing your evaluations based on the fiscal year cycle, of which many are wrapping as we speak). And remember, there’s no rule that says you can’t develop and implement new indicators mid-cycle. Take a good look at the numbers you have and figure out whether your organization is where it needs to be from a performance standpoint. If the numbers are good—it might behoove you to ask the question or whether that level of performance is the result of good design or good fortune (there’s nothing wrong with good fortune, though it does tend to be less reliable than good design). As with so many of our critical processes, the more we can hardwire compliance/good practice, the easier our jobs can be. Perhaps that’s an overly optimistic thought, but as I gaze out over Boston Harbor this morning, optimism doesn’t seem to be misplaced—optimism is good to have when flying!

Where there’s smoke…

Last week, I had the opportunity to make a presentation to some members of the Colorado Hospital Association (Many thanks to everyone who attended. It was a great pleasure having the opportunity. You guys rocked!) regarding the whole Physical Environment/Environment of Care focus during regulatory surveys of late. One of the items we discussed was the issue of The Joint Commission’s exhortation of folks to review/revise their smoking policy(s) in light of recent technological innovations in the realm of nicotine delivery systems and how to account for the risks associated therewith.

What I hadn’t planned on was a turn in the conversation towards the legalization of marijuana in Colorado and having to deal with that set of risks (I’m thinking snack sales in the hospital gift shops may get a wee bit of a boost) from a smoking policy perspective. Upon further thought (as I tend to do), while I was bicycling this morning the thought occurred to me that there’s potentially a whole host of risks associated with occupational safety, particularly as a function of impaired employees. We didn’t really talk about this piece of the puzzle last week, but I would assume (and yes, I know exactly what happens when one assumes) that you have to “run” with a general prohibition on consumption during work hours, much akin to a general prohibition of alcohol consumption during work hours. At any rate, I was wondering if any folks out there in radioland had given this much thought and whether anyone is prepared to share any nifty thoughts or plans they might have. I have a sneaking suspicion that as the movement to legalize cannabis gains momentum, this may figure in the future (maybe not so prominently—could be no big deal). Is anybody trying to get out in front on this?

Thanks again to the Colorado Hospital Association for last week’s presentation and for planting the seed for this blog entry (small pun intended).