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House, Scrubs, and sharps containers

I spent a fair amount of time over the holidays watching the continuing TV adventures of my favorite misanthrope, Dr. Gregory House.
 
One of the curious things that I've noticed (which is clearly a manifestation of my own obsessive compulsive disorder, as well as my consultative nature) is that the sharps disposal containers located in each of the care environments represented in the various episodes of House appear to be mounted at an aperture height of about 72 inches.
 
And lo and behold, I "bumped" into an episode of Scrubs and the sharps containers appear to be mounted at the same height (unless it's an optical illusion and everyone on each of the shows is really tiny).
 
Which makes me wonder--could they produce the risk assessment indicating that particular mounting height is appropriate? The Joint Commission talks of such a risk assessment in one of its official FAQs. Remember, the FAQs hold the same weight as the standards themselves.

Research contends PPE use may be vastly underestimated during a disaster

Hi everyone, it's Scott Wallask. Hope everyone enjoyed their New Year's celebrations, however loud or quiet they may have been.
 
One of HCPro's free e-newsletters, Infection Control Weekly Monitor, recently published information about a study that surprised me.
 
The research, published in the Journal of Infection Control, made some stark conclusions regarding personal protective equipment use during a disaster. The study involved a 24-hour flu pandemic exercise in a British hospital.
 
According to researchers, in the worst-case scenario during the height of a flu pandemic, a ward with patients experiencing the same symptoms could expect to use:
  • 5,250 plastic aprons per week (compared to normal use of 400)
  • 8,400 pairs of gloves per week(compared to normal use of 850)
  • 4,550 surgical masks per week(compared to normal use of less than 10)
  • 100 respirators equivalent to an N99 model per week, a higher protection than common N95 respirators (compared to a normal use of 0)
The surgical mask use represents a 450-fold increase. "This has significant implications not only for cost and procurement, but also for storage. Accommodating supplies on the ward for the 24 hours of the exercise was difficult," researches wrote in the Journal of Infection Control.
 
Why did this increase happen? One idea floated by researchers was that staff members lacked confidence in using personal protective equipment during a pandemic response and found the items uncomfortable to wear for long periods, which in turn dragged out the time needed to complete even basic duties.

Emergency management scoring grace period ends January 1

Hi folks, it's Scott Wallask checking in today. Steve Mac is on vacation this week (well deserved after I heard about the amount of miles he logged in the air in the last couple of months).

I wanted to remind you that a Joint Commission grace period--during which certain emergency management citations wouldn't count against your hospital's accreditation status--is ending as of January 1.

Because the new 2009 emergency management chapter renumbers the previous standards, double-check these provisions, all of which fell under the grace period in 2008:

  • EM.01.01.01, EP 8—Documenting an inventory of assets and resources
  • EM.02.02.03, EP 6—Monitoring quantities of assets and resources
  • EM.02.01.01, EP 3—Meeting the 96-hour provision
  • EM.02.02.01, EP 7—Communicating with vendors of essential supplies and services
  • EM.02.02.03, EP 5—Sharing of assets and resources with healthcare facilities outside of the community
  • EM.02.02.03, EP 9—Transporting patients, medications, equipment, and staff members to alternate care sites
  • EM.02.02.05, EP 3—Coordinating security activities with outside agencies
  • EM.02.02.05, EP 4—Managing hazardous materials and wastes
  • EM.02.02.07, EP 7—Training staff members about their roles in emergency response
  • EM.02.02.07, EP 8—Communicating with licensed independent practitioners about their roles in emergency response
  • EM.02.02.09, EP 5—Determining alternative supplies of fuel for building operations or essential transport activities
  • EM.02.02.11, EP 6—Managing mental health needs of patients
  • EM.02.02.11, EP 7—Managing mortuary services
  • EM.02.02.11, EP 8—Documenting and tracking clinical information

Emergency management will be a big part of our 3rd Annual Hospital Safety Center Symposium in May, so I encourage you to check out the full agenda.

A couple of thoughts about PFIs--they're only a matter of time (and resources, and . . .)

Among the many requirements that didn't change when the Life Safety Code leapt to its own chapter is the timely completion of PFIs (and that yawning chasm of shame if you miss the mark).
 
So, when it comes to planning your PFIs under your Statement of Conditions, you need to be very realistic when you identify how long it's going to take to repair or otherwise bring into compliance the individual items.
 
Ultimately, the timeframe for completion is dictated by how long it will take to resolve the condition (yeah, I know--big surprise). But two suggestions:
  • The first thing I’d look at is the severity of the repairs. For example, is the PFI a barrier wall in a patient care area?
  • Then look at what resources need to be brought to bear to manage the long-term items (e.g., time, materials, staffing, access, and whatever else comes into play in figuring out how the conditions will be resolved).
While you do have some flexibility when corrections are delayed due to unforeseen circumstances, the correction of PFIs looks so much better when you don't have to ask for an extension.
 
I suspect that this might be my last missive before Christmas, so please accept my best wishes to you for a joyous, happy, safe, sage, and prosperous existence.

OSHA doesn't require blood spill kits

Hi everyone, it's Scott Wallask logging on this morning.

Someone asked me last week about OSHA requirements for blood spill kits under the bloodborne pathogens standard, and my recollection was that there was no such mandate.

But I was curious and researched the standard, and it turns out my gut feeling was correct. Under paragraph (d)(4)(ii)(A) of the standard, OSHA requires the following:

Contaminated work surfaces shall be decontaminated with an appropriate disinfectant after completion of procedures; immediately or as soon as feasible when surfaces are overtly contaminated or after any spill of blood or other potentially infectious materials; and at the end of the work shift if the surface may have become contaminated since the last cleaning.

There is nothing in the standard that specifically notes the need for a blood spill kit, and if you search for the term "kit" in the standard's wording, nothing comes up.

I also double-checked OSHA's compliance directive for the bloodborne pathogens standard, which is basically guideline for inspectors. The directive confirms that OSHA's wording for (d)(4)(ii) represents minimum requirements and that there is no mandate for a kit.

That doesn't mean you can't have a spill kit ready to clean up blood, and in some cases it's probably a best practice. But OSHA leaves that decision up to you.

A brief thought about nurse calls

I generally try to discourage folks from having nurse call buttons in areas of public access because it can become a risk management nightmare. With a nurse call in a public spot, you've established an expectation that someone will respond when it's pushed, etc.

The same thinking applies for areas that are closed during portions of the day, but are not secured. In such cases, if someone wanders in, uses a restroom, has some sort of event which prompts them to activate the nurse call, and then no one responds, you're may be looking at a lovely lawsuit.

Curiously, the EC standards aren't mentioned in the new Sentinel Event Alert

I saw that The Joint Commission published a new Sentinel Event Alert about preventing technology-related errors.
 
In reviewing the Alert, The Joint Commission takes some pains to identify standards and performance elements that already exist in this regard, but they don’t mention EC.02.04.01, EP 1, which states the “hospital solicits input from individuals who operate and service equipment when it selects and acquires medical equipment.”
 
Now, in the Alert, one of the issues that could result in a threat to care and patient safety is when clinicians and other staff are not included in the planning process. To be honest, my first thought was that they were mostly going after medical equipment, though it does appear that this Alert is more aimed at information management and technology improvements.
 
That said, there is certainly a practical application to this Alert relative to the coordination of medical equipment and peripheral technologies, especially as devices and technology become more and more inextricably linked.
 
Not that you would ever encounter a surveyor that expanded upon the printed scope of a Sentinel Event Alert into unexpected waters, but if we consider the advice contained in the Alert as best practices, there may be a tacit obligation from the EC end to at least consider some of the identified risks.
 
After all, it's not about doing what someone tells us to do, it is about using any available resource to ensure that we are maintaining our care environments in a risk-free, or at least risk-neutral, manner. Can anyone say risk assessment? Sure you can! I suspect I’ll be talking about risk assessments during my session at our 3rd Annual Hospital Safety Center Symposium in May.

Today only: Save $200 on our Hospital Safety Center Symposium registration

Hi everyone, it's Scott Wallask checking in today.

Those of us here at HCPro have been working hard on the 3rd Annual Hospital Safety Center Symposium, which takes place May 14-15 at Caesars Palace in Las Vegas.

We've posted the show's full agenda here, and don't forget to also check out the bios of our faculty/speakers.

My boss just asked me to make an offer for those of you who like to be "early" early birds: If you write back to me today, I can knock off $200 from the listed $895 price tag to attend (so you'll pay $695 instead). This is a great offer for those of you who want to attend, as it's 100 bucks less than our listed early-bird rate.

So if you're interested in saving $200, e-mail me today...Scott W.

Get IC involved early with construction and renovation projects

When it comes to addressing infection control concerns during construction and renovations, my experience has been that while organizations usually do a pretty good job of managing large projects, when it comes to the IC/facilities collaboration on smaller projects, frequently the IC coordinator doesn't find out what's going on until the work is underway or, in some cases, completed.
 
EC.02.06.05 is specific about conducting preconstruction risk assessments. My personal philosophy has been that the assessment piece of this is the key, no matter how large or small the project, especially if there is any chance of impacting an immunocompromised patient population.
 
If you don't have a solid, proactive assessment process, then you're leaving yourself not only open to Joint Commission scrutiny (for not having reduced risk to the lowest potential), but also from CMS as a function of whether they'd be inclined to pay for patients that acquire an infection during their stay that could have been the result of dust migration, airborne contaminants, etc.

EC plans should reflect your risk management process

I was conversing with a colleague in the field recently about whether the “approach” of his EC management plans was on target.
 
Management plans are supposed to describe the risk management process of your organization; a management plan, by definition, is not supposed to address specific risks, because risks evolve, get managed appropriately, get managed inappropriately, etc.
Think, if you will, of the all-hazards model for emergency management--this general concept is absolutely applicable to the management of EC risk.
 
Ultimately, the EC management plans have to work for you, in your organization--and you know what works best in your house. The Joint Commission’s Standards Interpretation Group will tell you that there's no correct or incorrect methodology for constructing the management plans (beyond merely listing the EPs without any discussion of how those aspects of the program are managed--that doesn't play very well).
 
It goes back to Joint Commission Senior Engineer George Mills' comment a few months ago that you could even have a single management plan for all the EC functions, so long as the complexities and risks of the organization are appropriately represented.

Upcoming EPA deadline, from the latest Briefings on Hospital Safety

Hi everyone, it's Scott Wallask --

The EPA has an important deadline coming up December 29 regarding ethylene oxide sterilizer loads. That's our lead story in the current issue of Briefings on Hospital Safety, which is available online for all subscribers to the Hospital Safety Center.

Other articles include:

  • Some timely tips about the revised EC standards, which take effect January 1
  • How one hospital regained its ground after a document mishap during a Joint Commission survey
  • Ten ways to better prepare for a surge in pediatric patients

If you're not a subscriber to the Hospital Safety Center and want to learn more, click here.

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