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Include arson as part of your facility's annual HVA documentation and education


July 28, 2017

Add or revisit the likelihood of arson as part of your annual hazard vulnerability analysis (HVA) and work just as closely with local fire investigators as with emergency responders in educating staff on the proper prevention and response to an intentionally set blaze.

A fire in an unused waiting area on a patient care floor at the University of Texas Medical Branch’s John Sealy Hospital in Galveston, Texas, on Jan. 4 was ruled an arson by the State Fire Marshal’s Office. Smoke from the blaze prompted the evacuation of more than 100 patients from the entire 12-story structure, but there were no injuries or deaths.

The blaze is a reminder that arson should be part of your security assessment every year and that security personnel and staff should remain aware of the risk daily, say security experts. In addition, staff should remember that arson is possible in any fire, no matter how small, and that the area must be treated as a potential crime scene until it is determined otherwise.

Arson should be part of HVA

Arson is easy to overlook during annual security and HVA assessments, says Bryan Warren, director of corporate security for the Carolinas Healthcare System, which is based in Charlotte, N.C., and has dozens of facilities throughout North and South Carolina.

“Arson, historically, has been pretty rare in the health care industry,” says Warren, who is also a past president of the International Association for Healthcare Security and Safety.

“However, with an increased focus of violent extremists and the ease and low cost of incendiary materials, I am afraid that it is enjoying a resurgence of consideration, as are many of the old school/low tech ways to vandalize and attack a target.” He pointed to the recent use of large vehicles to ram a target.

OSHA and others also note that arson can also be related to workplace violence.

Joint Commission requires HVA

The Joint Commission requires a HVA under Emergency Management standard EM.01.01.01, EP 2. The HVA should identify emergencies that could impact a hospital’s ability to provide care to patients, the likelihood of an event occurring, and the consequences, and that analysis must be documented. EP 3 requires hospitals to include community agencies in the process.

The possibility of arson should be not only included in the HVA, says Warren, but “security personnel should be educated as to the potential precursors and indicators of arson planning.” That would include the presence of large amounts of flammable materials in unusual locations, the presence or theft of accelerants, and other suspicious activity that might involve materials that could be used for arson, Warren says.

In Galveston, the fire was set in a waiting area just off the building’s central elevator system but outside a wing that was closed for renovations. The work included adding sprinklers to the building, which was constructed before fire codes required all patient areas to be fully sprinklered.

Because the wing was closed, the waiting area was not being used. However, the waiting area was located on the second floor, which also connects to another building on campus so the waiting area was still accessible by the public.

Changes made after Galveston fire

Since the fire, UTMB Health has made several changes in response to lessons learned, says Jack Tarpley, UTMB Health’s associate vice president for environmental health and safety. The health system has reduced the amount of unoccupied space that is considered not-in-use but is still available to the general public, such as walk-through areas. Such areas are or will be walled off or the spaces otherwise secured as a deterrent, notes Tarpley.

Also, the hospital is eliminating or reducing unattended equipment or supplies in accessible areas such as elevator lobbies, hallways, alcoves or waiting areas. “As a hospital we have requirements to not store equipment or supplies in corridors, but beyond that there is a concerted effort to eliminate stored or staged material if it is not in-use,” Tarpley states.

Most of the John Sealy building had to be shut down for repairs from the fire, which was contained by fire doors to the as-yet-unsprinklered waiting area, and from smoke, which went throughout the building, especially after firefighters breached the doors to get to the flames. The hospital took advantage of the down time to retrofit remaining areas with sprinklers, Tarpley says.

All of those changes mirror recommendations by Warren and a colleague, Bret M. Martin, director of fire, life safety and utilities for Carolinas HealthCare System facilities management corporate support.

Including arson as part of your facility’s security and emergency planning, says Martin, can be broken into five categories: prevention, detection, suppression, investigation and prosecution.

Consider five categories in your review

Review your HVA and security plans using the following recommendations in these areas:

Prevention: Control access to areas not constantly attended by security, says Martin. Keep visitors from accessing back areas of the hospital without being vetted, pre-screened or accompanied. Where possible, use security cameras in areas frequented by the general public, including areas for visitors and family members, and keep surveillance video for a minimum of 30 days. In common areas or common paths of travel, the time and date stamp for a person’s progression through a facility can put them at the scene at a defined time, Martin notes.

Warren recommends including local fire and arson investigators in security and emergency management planning, just as you would law enforcement or other first responders in workplace violence prevention and disaster planning.

That should include inviting fire and arson investigators “to tour with Life Safety and maintenance personnel to better understand the layout of the facility and its processes before an event occurs,” says Warren.

Detection:  Early detection of smoke and heat of course are paramount in patient safety, but are also important to arson investigations. “Early detection of either accidental or intentional incendiary events is key,” says Martin, as is the quick, trained response by staff after alarms go off. “Having a defend-in-place policy for a facility will require a quick human element response to the source of the alarm for early attempts at extinguishing, assessing condition, assessing fuel source, etc.”   

Suppression: Along with detection, sprinkler protection is also a key to successful investigations, notes Martin. The reason “many arson cases fall apart is the fire is left to burn up the evidence. Early suppression can preserve signs and/or evidence of arson,” notes Martin.

Investigation: Help investigators with whatever resources you have available and educate hospital staff members on the need to maintain the scene untouched as much as possible after a fire is out. “It is important to train security and fire response personnel that once the immediately risk of the fire is eliminated, until the true cause is determined, it should be preserved and treaty as a crime scene until proper investigators arrive,” warns Martin.

He pointed to a recent event in which a patient intentionally set a bed on fire. Sprinklers and a fire extinguisher contained the damage from the flames. “However, the space became a show-and-tell of various people traipsing in and out of the room taking pictures and disturbing the scene,” Martin notes. Until the fire investigator arrived, “we didn’t treat the room, the floor, the wing, as a potential crime scene and restrict unauthorized personnel.”

Even the smallest of fires should be protected. “I have done fire investigations for trashcan fires in restrooms where, by the time I get there, they have already gone in and thrown the trashcan away and begun cleaning up the room. Albeit well intended, this can ruin any true-cause determination and/or future prosecution, if the ignition source or fuel has been removed.”

In addition, gather information from internal resources such as video from closed-circuit television monitoring or badge-reader reports, and share that as soon as possible with local police and fire arson investigators, says Warren. The investigation should be a collaborative process, if nothing else to form and strengthen that public-private relationship for the future, he says.

But just having that information can be a challenge, Warren notes. Explain to leadership that extra resources may be necessary. “Many smaller (and some medium to larger) health care facilities have eschewed their own internal security programs in the name of cost reduction and in many of these cases there is no one that can assist with such internal processes,” he observes.

Prosecution: Understand the investigative process and discuss when to prosecute cases. “This is open for wide debate. There is the inclination to not call attention to the event,” to prevent undue public or media attention. “In my opinion, facilities should have an aggressive prosecutorial approach to arson events,” says Martin.

And it may not even be possible in some instances. “In our particular bed case, I learn an interesting fact in that they couldn’t prosecute for arson because the fire damage was contained to the bed and did not progress into the structure part of the facility. The floor covering did not have heat damage. So, per state law, they couldn’t charge the person with arson because all the fire protection and suppression systems worked and confined the fire to the bed,” notes Martin.

This story originally appeared in Environment of Care Leader.

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