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Using alcohol-based hand sanitizers in psychiatric areas

Someone on HCPro’s Patient Safety Talk listserv recently asked about using alcohol-based hand sanitizers in psych units.
 
The key here is whether the results of your organization's risk assessment indicate that you can safely place the dispensers in that particular care environment. A psych patient population is absolutely unique to a given organization, and when it comes to matters of safety as a function of medical condition/diagnosis, you really need to use that uniqueness (uniquity?) as the basis of the evaluation.
 
Also, consider these concerns:
  • What product do you use? Foam-based products might be a little safer in a psych application than a liquid.
  • How is the psych environment configured? Is there a safer way to install the dispensers?
Particularly with the likely scrutiny of this type of a thing as a function of The Joint Commission’s National Patient Safety Goals, there will be any number of folks who will take issue with whatever you end up doing. The psych safety zealots will condemn you for using the alcohol-based hand rubs and the infection control zealots will chastise you for not using the product.
 
I'd work the process through and base the decision on what will work for your patient population.

New Joint Commission FAQs posted

Hi everyone, it's Scott Wallask. Just wanted to give you a quick heads-up that The Joint Commission has updated it's FAQs page.

Many of the existing FAQs have simply been updated to stay current, but there are also new ones on the following topics:

  • Labeling of medical gas cylinders
  • Locking electrical panels
  • Locking soiled utility rooms
  • Mounting of sharps containers
  • Patient-owned equipment
  • Placement of alcohol-based hand rub dispensers
  • Smoke-free campuses
  • Computers-on-wheels in corridors
  • Sprinkler protection for wardrobe cabinets

FAQs--along with the actual standards and Perspectives newsletter--are the only "official" venues for Joint Commission changes and interpretations, so they're worth checking out.

A quick rundown of certified safety programs

Here are some good resources for certified safety officer training:
Has anyone out there gone through other useful certification programs? Post a comment if you have. 

Joint Commission and DNV to speak at our Vegas program

Hi everyone, it’s Scott Wallask --
 
I just wanted to give you all an exciting update about of 3rd Annual Hospital Safety Center Symposium.
 
My colleagues at HCPro's Association for Healthcare Accreditation Professionals, who are holding a conference at the same time as the Hospital Safety Center Symposium, have confirmed that speakers from The Joint Commission, DNV Healthcare, and the AOA’s Healthcare Facilities Accreditation Program will all speak at the show. All attendees to the Hospital Safety Center Symposium will be invited to the accreditation session.
 
The symposium takes place May 14-15 in Las Vegas at Caesars Palace, and early-bird registration is available now. Please join us if you haven't already signed up.

The murky origins of CMS and OSHA provisions for fire drill participation

I have heard of inspectors from the Centers for Medicare & Medicaid Services (CMS), as well as some OSHA inspectors, who not only look for attendance records of fire drills, but also look for some sort of accounting on an annual basis of how many staff members actually participated in fire drills.
 
That said, I'm not exactly sure where the genesis of that particular notion might be.
 
Some time back, The Joint Commission "relaxed" its requirements for participation in drills to indicate it should be "to the extent called for in the facility's fire plan” (see EC.5.30). Similar language will be retained in EC.5.30’s successor, EC.02.03.03.
 
The Life Safety Code doesn't really get too far into the specifics of drill participation, and CMS’ Conditions of Participation are absolutely mum on the subject of fire drills, never mind participation in them.
 
Finally, I also checked the applicable OSHA standards and could find no mention of specific documentation or participation requirements.
 
My best advice would be to really look at who needs to participate in the drills, based on your plan, and develop strategies to get to as many of those folks as possible (I can’t imagine that weekends wouldn’t be in the mix for that).

Daily crash cart checks aren't required, but it's a slippery slope

The Joint Commission does not mandate any particular frequency for checking crash carts, so there would be no mention of it any of the accreditation manuals.
 
I think that the primary reason for this is that there is no standardized outfitting (if you will) of crash carts, so the frequency of necessary checks could be quite variable.
 
The other piece of the puzzle is making the determination of frequency based upon appropriate management of the inherent risks. For instance, some organizations have defibrillators on the crash carts, which (by manufacturers’ recommendations) require daily testing, so the frequency is based upon that. However, some have automated external defibrillators, which can have a different set of testing requirements.
 
In other cases, the reason for checking the carts is to make sure that there's been no tampering with the contents or unauthorized access because of where the carts are located. Organizations that have the carts in relatively secure areas use less frequent checks.
 
Ultimately, the decision-making process comes down to the appropriate management of the assessed risk.
 
The general trend is that daily checks of crash carts are a best practice (and that's the likely opinion of Joint Commission surveyors on this). If an organization chooses to check the carts less frequently than daily, there must be a clear (and, for all intents and purposes, indisputable) sense that whatever frequency chosen results in an equivalent level of safety. Ultimately, that means documenting the decision-making process.

Emergency drills can help with more mundane events, too

Hi everyone, it’s Scott Wallask checking in. You have to give a “thumbs up” to fire officials in Islamorada, FL, (in the Florida Keys) for taking a realistic view of a recent mass casualty exercise.
 
The fire department worked with Mariners Hospital in neighboring Tavernier testing community response to a scenario of a boat explosion.
 
A fire captain told The Reporter newspaper that while true mass casualty events don’t happen often in his community, the exercise still let authorities train for dealing with a surge of people. Each year, a large convention of bartenders arrives in the area, and sometimes the fire department has multiple trucks on the road at the same time.
 
The disaster drill helped fire officials better determine how a surge taxes their resources and what their responses would be to events in different sites, the fire captain told The Reporter.
 
At least from my view, it sounds like the fire department saw the “bigger picture” when it comes to drills.

Life safety management plans could connect to EC.01.01.01

Strictly speaking, with the transfer of Life Safety Code compliance into The Joint Commission’s life safety standards in 2009, there is no specific requirement for a related written management plan.
 
The way I plan on covering this programmatic aspect will be to include it in the fire safety management plan, which will still be required as a written document under EC.01.01.01.
 
The only document required under the life safety standards is a written policy for interim life safety measures.

Preview of this month's Briefings on Hospital Safety

Hi everyone, it's Scott Wallask logging on today.

I just wanted to remind all Hospital Safety Center subscribers that the latest issue of Briefings on Hospital Safety is available online.

You can check out the following articles:

  • An overview of the challenges coming in The Joint Commission's new life safety chapter
  • Why one hospital endured a tough CMS review following two patient suicides
  • How moving patients to new buildings offered two hospitals chances to fine-tune their evacuation plans

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

Document all your ILSM assessments--even if you don't implement an ILSM

When it comes to interim life safety measures (ILSMs), which will fall under standard LS.01.02.01 in 2009, remember this: It is not enough to only document those times when ILSM implementation was required. It is of critical importance (as a demonstration of the effectiveness of your process) to also record the assessment elements that resulted in a determination of no need to implement an ILSM.
 
Remember, Joint Commission surveyors will be able to glean info about past projects from committee minutes--you have to assume that everything is discoverable.
Also, keep an open mind when it comes to ILSM assessments (and, for that matter, infection control risk assessments). My practice relative to ILSMs is that we always document an assessment and implement only when it is appropriate to do so.
 
Surveyors have had a tendency to really jump on this concern--and not just the life safety surveyors. There are a bunch of administrator surveyors who will go after this stuff if you give them enough of a space to get their pry bar in.
 
Think about things like paving work in the surrounding neighborhood, especially if you're in the bucket for a survey. One of the ILSMs refers to ensuring free and unobstructed access to emergency services and for fire, police, and other emergency forces. It may be that there is no significant impact for this particular scenario, but if you don't document the assessment, you could be staring down the barrel of a conditional accreditation finding--and you surely don't want that to happen.
 
The “always assess and implement only when appropriate” approach will follow along as a happy byproduct of your solid process.
 
By the way, platinum subscribers to our Web site can check out a workstation that deals heavily with ILSM compliance.

Eyewash station use should tie into a risk assessment

When it comes to eyewash stations, the starting point really should be:
  1. An assessment of where you currently have eyewash stations, and
  2. A determination of whether the exposure risks warrant the continued presence of the eyewash stations
For instance, from an OSHA perspective, if there is a risk of exposure to caustic or corrosive materials (e.g., glutaraldehyde, acetic acid, etc.), then the use of an eyewash station as part of the first aid sequence is generally indicated.
 
A good place to check is on the MSDS of a material or substance. If the first aid section indicates flushing the eyes for 15-20 minutes, then that means you need an eyewash station. 
 
On the other hand, with appropriate use of personal protective equipment (PPE) and engineering controls, exposures to bloodborne pathogens should be manageable without the need for eyewash stations.
 
In a broader sense, I recommend you focus your attention on the stuff that happens before you'd ever need an eyewash station: using less hazardous chemicals, enforcing the use of PPE, etc.

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