|
|
When it comes to fire safety in the 2009 EC standards, one troubling aspect for me is EC.02.03.01, EP 4, which requires the maintenance of “free and unobstructed access to all exits” in business occupancies (e.g., a medical office building).
The maintenance of free and unobstructed access to all exits in healthcare occupancies is addressed in the new life safety standards.
My concern: Business occupancies are most likely not going to be visited by The Joint Commission’s life safety specialists; instead, “regular” surveyors will visit them. How will these surveyors define “free and unobstructed access to all exits,” given they may not have the same in-depth code knowledge of their life safety specialists?
This is one of those situations where you are going to have to take the surveyors by the horns (metaphorical, though sometimes you have to wonder) and educate them to what compliance with this EP means for your organization.
“Free and unobstructed” can be a very fine line, so start enforcement now. Otherwise you'll be running from the survey bulls.
Here’s a thought for you regarding emergency plan drills in 2009 and what The Joint Commission expects of you. Let’s look at EM.03.01.03, element of performance 16 (and I will quote it in its entirety):
The hospital modifies its emergency operations plan based on its evaluations of emergency response exercises and responses to actual emergencies.
So far, so good. But now we have this little dangling note:
Note: When modifications requiring substantive resources cannot be accomplished by the next emergency response exercise, interim measures are put into place until final modifications can be made.
Now I have to say that every time I see that lovely, little 15-letter phrase--"interim measures”--I start to get hives. I advise organizations to be succinct in identifying those interim measures.
One of the important points raised by our presenters was that despite The Joint Commission’s (formerly JCAHO) new life safety chapter, certain aspects of fire safety will remain in the EC standards in 2009.
For example, fire protection equipment inspections (currently under EC.5.40) will become EC.02.03.05 next year. Some of the elements of performance under the standard have been clarified, such as for monthly fire extinguisher inspections, so pay close attention to the 2009 wording.
Happy Labor Day . . .
I was recently asked whether organizations should create a policy to meet the requirements of EC.4.14. That Joint Commission (formerly JCAHO) standard requires hospitals to establish strategies to handle assets and resources during emergencies.
I don't know that I would necessarily recommend creating a policy to address all the elements of EC.4.14, as much because the individual elements carry across the whole operational continuum of an organization. In other words, there are pieces of EC.4.14 that "belong" to facilities, some to materials management, some to other department-level folks, etc.
I daresay that these should probably be addressed as a function of your response plan. This then folds up into your incident command structure for use during actual emergencies.
Managing assets and resource during an emergency needs to be "living" process and very fluid. My experience has been that once these things get to policy level, they lose a lot of flexibility in the process.
As you ponder the 2009 EC standards, hazardous materials and waste under EC.02.02.01 bears watching.
The Joint Commission (formerly JCAHO) did a lot of shifting around in this section. My fear is that Joint Commission officials are readying this area for some intensified scrutiny.
I think the Environmental Protection Agency’s (EPA) healthcare-based activities in different parts of the country have identified hazmat management as something hospitals don’t yet do especially well (though, to be honest, I don’t think Joint Commission surveyors have received good education about EPA topics, either).
One to keep an eye on.
Let’s talk for a moment about what I like to call “safe-curity”--in other words, the combining of safety and security functions into EC.02.01.01 in the 2009 Joint Commission (formerly JCAHO) standards.
The safety and security risk assessment processes (which includes appropriately managing the risk in the EC) have been folded into EP 3. This will continue to be the general duty clause section of the EC standards; anything surveyors see that they don’t like becomes fodder.
Folks are going to have to be very diligent in documenting the decision-making process when identifying risk strategies. For instance, there is a nonbinding ANSI standard that requires the testing of eyewash stations on a weekly basis; however, if any organization chooses to test at a lesser frequency, it must have a documented risk assessment supporting that decision, otherwise a citation can occur.
I can see similar risk exposures relative to under-sink storage, management of crash carts, handling IV solutions, and all that.
In the 2009 EC standards, EC.02.06.05 deals with concerns surrounding construction, renovation, and demolition.
The standard’s provisions haven’t changed from earlier versions. However, I want to impress upon you the need for construction management to begin as a proactive pursuit--which means before the infection control coordinator discovers the facilities folks have knocked down a wall. I’ve been running into this problem with increasing frequency.
I would ask pointed questions to your infection control professionals and see how much squirming occurs. This is not a process for which the forgiveness versus permission equation can be applied.
I read a story earlier this month in the St. Louis Post-Dispatch about a company with a new type of patient evacuation device called the Med Sled. The manufacturers noted in the story that using the sled-like device, a nurse weighing 100 pounds could take a 200-pount patient down flights of stairs during an evacuation.
I don’t know much about this product beyond what was in the newspaper article and what I’ve read on the company’s Web site, and customers seem satisfied based on online testimonials. But I will say that George Mills, senior engineer at The Joint Commission, is concerned in general about evacuation plans and how realistic they are when it comes to physically moving patients.
I remember at a session Mills spoke at during the National Fire Protection Association’s annual conference in June, he asked attendees if they’ve ever tried performing two-person evacuations of patients for any length of time.
"It’s a lot of work," he said, and specifically mentioned the difficulty of a nurse trying to move a 250–300-pound person.
I’ve never evacuated anyone during an emergency, but years ago HCPro filmed a nursing home evacuation video that I was an extra in. During one shot, three of us had to carry an actor portraying a patient down a flight of stairs, and I was sweating after the third or fourth take.
I guess ultimately, whatever devices your hospital uses to aid evacuations, make sure during drills that nurses and other unit staff members test their abilities to use those devices.
Posted At : August 13, 2008 11:30 AM
| Posted By : Steve MacArthur
Related Categories:
The Joint Commission
Answer: Not likely . . .
Question: Is he ever going to shut up about risk assessments?
I still sense there are those of you out there who remain somewhat unconvinced of the importance of the risk assessment process. You know you have to do it ‘cause it’s a requirement, but if you don’t go at it in a purposeful manner, it won’t do you any good beyond probably passing survey muster--but we’re not just about that anymore, are we?
In looking at all the lovely reconfigured standards and performance elements, I can’t help but think that in order to succeed at the management of risk in the EC, it is of critical importance to adopt a data-driven risk assessment model.
I mean, just look at the new 2009 iteration of the The Joint Commission’s general duty clause (formerly EC.1.10, EPs 4 and 5):
- EC.02.01.01, EP 1—The "hospital identifies safety and security risks associated with the environment of care. Risks are identified from internal sources such as ongoing monitoring of the environment, results of root cause analyses, results of annual proactive risk assessments of high-risk processes, and from credible external sources such as Sentinel Event Alerts." But wait, there’s more…
- EC.02.01.01, EP 3--The "hospital take action to minimize or eliminate identified safety and security risks in the physical environment."
That means you have hunt these risks down and either reduce them to the lowest possible impact (and think about how you’re going to measure that!) or eradicate them completely (this, I believe, is somewhat more succinct than to "select and implement procedures and controls to achieve the lowest potential for adverse impact on the safety and health of…").
Now, you and I both know that if we can somehow create a risk-neutral condition, that’s a pretty good day’s work. Is that going to be enough moving forward? Thus our charge is crafting a process that absolutely, positively demonstrates our compliance efforts and the successes we have (and will continue) to derive from those efforts.
Posted At : August 11, 2008 3:48 PM
| Posted By : Steve MacArthur
Related Categories:
The Joint Commission
It’s ideally a site that will provide you an opportunity to forge anew the relationships between the facilities/safety folks and those in the land of survey preparation.
The Center for Healthcare Accreditation has been in existence for a little while now, and a lot of hospitals all over the country have been able to make really good use of an ongoing relationship with, arguably, one of the most skilled and professional groups of consultants: The Greeley Company team. (Yes, full disclosure, I’m fortunate enough to be able to count myself among that august group. Call me biased, if you will, but seriously good folks).
At any rate, I’m also going to be doing some blogging on that side of things--content exclusive to the Center for Healthcare Accreditation site-- aimed at furthering the diplomatic relations between you guys and the folks in quality, performance improvement, and risk management (and trust me, this is a relationship that will benefit everyone involved).
While Mac’s Safety space will remain my priority audience every week, my new duties are all about helping folks to be better in their management of the care environment--and every little bit helps.
And so, I’d appreciate your checking out the site ( http://accreditationcenter.com) and even more, I’d appreciate your giving the folks in your organization charged with survey preparation a head’s up about the site. Who knows, maybe they’ll let you bring me to your “house” for a visit. What fun would that be!?!
Keep those cards and letters coming!
In 2009, disaster privileging will move from The Joint Commission’s medical staff chapter to the EM standards.
EM.02.02.13 allows hospitals to grant disaster privileges to volunteer licensed independent practitioners (generally speaking, physicians).
I’ve found that having a doc in the room can make a very big difference with the tone of surveyor interrogatories.
Posted At : August 6, 2008 2:26 PM
| Posted By : Steve MacArthur
Related Categories:
The Joint Commission
Let’s talk about clearance around fire extinguishers, medical gas zone shut-off valves, and the like.
The key concept that comes into play during survey is whether access to the equipment is obstructed.
I have heard anecdotally that there are some Joint Commission (formerly JCAHO) surveyors who are applying the requirements for clearance around electrical panels found in the NFPA 70, National Electrical Code, which calls for 36 inches of clear space in front of the panel.
But in the absence of a national standard that specifically identifies the device we’re seeking clearance around, it ultimately comes down to a risk assessment.
In conducting a risk assessment, remember extinguishers, medical gas shut-off valves, etc., are used solely in the case of an emergency, so when you need it, you need it "now". Anything that impedes that process can (and almost certainly rightly so) increase the risk to life, health, and safety, which pretty much flies in the face of good risk management.
Hi everyone, it's Scott Wallask checking in today.
When I was at the ASHE conference last month, George Mills (senior engineer at The Joint Commission) mentioned that life safety surveyors would now be reviewing a trio of leadership standards in addition to giving their well-known EC scrutiny.
Here's the list of the LD standards Mills specifically mentioned, along with examples from him about how they might work into life safety concerns:
- LD.2.20, EP #2--Facility leaders hold staff members accountable for their responsibilities. Example: Not having fire protection equipment inspection records available from third-party contractors.
- LD.3.80, EP #4--Leaders provide for adequate equipment and resources. Example: Administrators cut off budget spending for plans for improvement (PFIs) under the Statement of Conditions.
- LD.4.50, EP #2--Leaders give priority to problematic processes. Example: Establishing unrealistic PFI completion dates (e.g., fixing a large fire barrier penetration by 2015).
Mills covered a whole lot more about Life Safety Code matters, which we'll detail in the upcoming issue of Healthcare Life Safety Compliance.
Thanks, Scott Wallask, swallask@hcpro.com
Someone asked me recently about whether nurse call pull cords could be wrapped around the handrails in patient bathrooms.
The consensus on these pull cords is that they need to extend down to a point just off the floor so if a patient falls to the floor, he or she can still summon assistance. The cord shouldn’t touch the floor so it doesn’t get all scuzzy--generally speaking, hanging the cord to the top of the baseboard is a good guide.
As far as the wrapping the cord around the handrail, it’s as much a performance issue as it is anything else. If the alarm still works as intended (meaning it activates with the same amount of downward pressure), then it should be fine.
That said, I’ve never really been clear on why folks felt that they had to do “the wrap.” If the cord is too long, then it should be trimmed to the appropriate length and that would do it.
I’ve noticed a wee beastie under The Joint Commission’s upcoming 2009 emergency management standards, and it concerns licensed independent practitioners (LIPs).
Check out EM.02.02.07 (management of staff members during emergencies). EP #8 states:
The hospital communicates in writing with each of its licensed independent practitioners regarding his or her role(s) in emergency response and to whom he or she reports during an emergency.
This wording may be no big deal, but I’m thinking that any time we see an “each” in the standards it complicates compliance.
Also of note, The Joint Commission doesn’t even qualify the LIPs with “appropriate” or “applicable”, which I guess could mean you need to notify certain LIPs in writing to stay out of the way (and you know which ones they would be in your house).
Posted At : July 25, 2008 1:04 PM
| Posted By : Steve MacArthur
Related Categories:
The Joint Commission
When it comes to a list of items to monitor in the EC, the starting point is element of performance #1 under EC.9.10:
- Injuries to patients or other coming to the hospital
- Incidents of property damage
- Occupational illnesses and injuries to employees
- Security incidents involving patients, workers, or others
- Hazardous materials and waste spills, exposures, and related incidents
- Fire safety management problems, deficiencies, and failures
- Medical equipment management problems, failures, and user errors
- Utility system management problems, failures, or user errors
Now there's a whole lot of risk that lives in these bullets above. Thus, the acid test becomes one of risk recognition, assessment, intervention, and ongoing performance monitoring.
An increasingly critical function of the survey process is the risk assessment portion and then the quality of the interventions that you choose to manage the risks.
Requirements for improvement in the EC are up, not so much because there are significant program failures, but rather because of a whole bunch of minor deficiencies that are aggregated into serious findings.
Mix this in with each member of the survey team being responsible for finding stuff and you have the oft-cited recipe for disaster.
Ultimately, the onus is on each organization to define what these EC risks mean and then defend the risk management approach they've chosen.
I recently chatted with someone about items you need to monitor in the EC.
There are myriad activities, primarily represented through the "C" elements of performance (EPs) in the EC chapter, that revolve around the "care and feeding" of the care environment--medical equipment, life safety equipment, emergency power equipment, conduction of safety rounds, and the like.
A solid EC program is going to have a process for monitoring compliance with all these "have to" elements, just to ensure that the EC program’s baseline competencies, if you will, are in place and functioning appropriately.
Beyond the activities and processes that you "have to do," things get a whole lot grayer in very short order.
The key standard for the rest of the monitoring expectations is EC.9.10 (the hospital monitors conditions in the environment). These expectations are pretty much a function of the risk management process in the care environment. There are six EPs involved in EC.9.10, pretty much divided into constant activities and periodic (at least annually) evaluations of the whole kit and caboodle.
More on this topic in my next post . . .
Hi, it’s Scott Wallask signing in today. I just got back Tuesday night from the American Society for Healthcare Engineering (ASHE) conference.
Lots happening on The Joint Commission (formerly JCAHO) front, as you can imagine. We’ll be covering this in detail in upcoming issues of Briefings on Hospital Safety and Healthcare Life Safety Compliance.
One thing I did want to mention is that George Mills, senior engineer at The Joint Commission, said he was concerned about the lack of realistic utility contingencies in hospital emergency operations plans.
From Mills view, some utility contingency provisions read great on paper, but are never really tested and thus aren’t reliable.
Mills asked ASHE attendees this: “When was the last time [you] walked through to make sure these things are even operating?” In other words, if your utility contingency plans center of certain equipment working, check this equipment out during down time before a disaster strikes.
Mills would rather have a utility failure occur when hospitals are expecting it during testing than during an emergency when patient lives are at risk, he said.
By the way, if you need help with the 2009 emergency management, life safety, or EC standards and can spare a day away from the office, come to our Environment of Care for 2009 seminar September 5 in Boston.
Posted At : July 18, 2008 8:24 PM
| Posted By : Steve MacArthur
Related Categories:
The Joint Commission
When it comes down to the annual EC evaluation process, what you want to do is formulate responses to some basic questions:
- What got better?
- How do we know it got better? (A measurable indicator is a joy forever.)
- How do we know it will stay better? (And we may not right away, but we do need to figure out how to keep an eye on things.)
- What didn’t get better? (Remember, improvement is about getting better, it is not, I repeat, not about staying the same. Staying the same is one step closer to getting worse than getting better is .Yow, does that even make sense? I think so…)
- What do we have to do to make it better?
- How will we know when it’s better? (There’s got to be some way of knowing.)
Which leads me to our next reconfiguration: the wonderful world of surveillance rounds, safety tours, environmental tours, whatever you call them in your house.
There has been an on-so-subtle alteration in The Joint Commission’s expectations for our annual and semi-annual rounds. The intent of conducting the rounds is to “evaluate the effectiveness of previously implemented activities intended to minimize or eliminate environment of care risks.”
My advice? If you haven’t started aggregating the information (particularly deficiencies) you’re gathering during surveillance rounds, you better get to it quick. In many instances, that’s your most reliable internal data source (i.e., your own two eyes).
Then use that information to identify improvement opportunities, including how you’ll know when they’ve “improved.” All the other stuff is nice, but anything that doesn’t speak to the improved/improving/not yet improved continuum is not going to help you.
If you want to talk about capital projects, talk about them in the context of improvement. You spent eight kazillion bucks – something damn well better have improved.
(BTW, when you identify capital projects, practice coming up with ways to measure the effectiveness. Even reducing the number of complaints, outages, etc. is valid. Figure out something.)
Did you hear that great sighing sound earlier? In all candor, I have to tell you that I was one of those sighers.
(Is “sighers” a word? Probably not, but the blogosphere can’t rest on such formalities).
The other shoe has dropped, and The Joint Commission 2009 standards changes have (finally!) been posted on the Web.
The question then becomes: Celebration or commiseration? What do we do?
For the moment, it appears that a moderately restrained celebration will suffice. The key words indicating the disposition of the current standards I noted in reviewing the materials are the following:
- Retention--No change in the applicable EP, i.e., the song remains the same.
- Consolidation--A slight change, a blending, if you will, of risk management activities under a general umbrella. For instance, all the safety education elements are now living in one happy house, EC.03.01.01, and, perhaps most controversially, the safety and security standards have become one under EC.02.01.01.
- Split--EPs previously containing multiple component requirements are broken down into the individual components. For instance, EC.3.10, EP #3 under the 2008 standards speaks to the risk management of chemicals, which has been further broken out in the 2009 standards under EC.02.02.01 to reflect the risk management of hazardous chemicals, radiation equipment and lasers, and hazardous gases and vapors.
As near as I can tell (and this has pretty much been the indication as this initiative has rolled out), there are no new requirements, per se. What appears to be changing is more a function of how EPs could be scored during a survey, especially those (banana) splits.
In my client work, I have often compared the current survey process’ arrival at “jeopardy” as not so much death by a sucking chest wound, but more death by a thousand cuts--and the Swiss survey knife appears to have grown a couple more blades. While my obsessive-compulsive disorder has not yet resulted in my counting up the number of EPs in play, rest assured I will.
There is a fundamental constant that every time The Joint Commission deck gets shuffled, there is a likelihood of some resulting confusion, not only in the EC community at large, but also in the surveyor community.
More Entries
|
