TJC Provides Tips for Meeting Problematic Life Safety Compliance Requirements
By David Stymiest, PE, CHFM, CHSP, FASHE
TJC Director of Engineering George Mills provides tips for meeting problematic life safety compliance issues in the July 2013 of The Joint Commission’s EC News. This valuable multi-page article addresses the following elements of performance (EPs) and related types of survey requirements for improvement:
Friday, July 19, 2013
Thursday, July 18, 2013
ASHRAE Publishes Improved HVAC Design Manual for Hospitals & Clinics
By Ron Holdaway, PE, CEM, LEED AP
ASHRAE recently published the 2nd edition of the HVAC Design Manual for Hospitals and Clinics. ASHRAE states that this book, a complete rewrite of the 1st edition, focuses specifically on HVAC system design for health care facilities, omitting general system descriptions that are readily available in other ASHRAE publications.
By Ron Holdaway, PE, CEM, LEED APASHRAE recently published the 2nd edition of the HVAC Design Manual for Hospitals and Clinics. ASHRAE states that this book, a complete rewrite of the 1st edition, focuses specifically on HVAC system design for health care facilities, omitting general system descriptions that are readily available in other ASHRAE publications.
Wednesday, July 17, 2013
TJC Strengthens Leadership Accountability for Emergency Management
By David Stymiest, PE, CHFM, CHSP, FASHEIn the July 2014 issue of Joint Commission Perspectives, TJC officially issued new and revised leadership requirements intended to provide “a clearer description of leadership-level oversight of emergency management.” The new and revised elements of performance are all effective January 1, 2014.
Tuesday, July 16, 2013
TJC Issues 2014 National Patient Safety Goal on Clinical Alarm System Safety
By David Stymiest, PE, CHFM, CHSP, FASHEIn its Joint Commission Online article dated June 26, 2013 (available at http://www.jointcommission.org/assets/1/23/jconline_June_26_13.pdf) The Joint Commission announced a new 2014 National Patient Safety Goal NPSG.06.01.01 on clinical alarm safety for both hospitals and critical access hospitals. The July 2013 issue of Joint Commission Perspectives discusses the new NPSG in detail.
Tuesday, June 4, 2013
Compliance News: TJC Revisits EC Plans
By David Stymiest, PE, CHFM, CHSP, FASHE
A recent article placed in both the EC News and TJC Perspectives clarified TJC requirements for management plans. Written for the June 2013 issues by TJC Department of Engineering Director George Mills for the Clarifications and Expectations segment of both publications, the article clarified some issues that have been resulting in TJC requirements for improvement (RFIs) during survey.
By David Stymiest, PE, CHFM, CHSP, FASHE
A recent article placed in both the EC News and TJC Perspectives clarified TJC requirements for management plans. Written for the June 2013 issues by TJC Department of Engineering Director George Mills for the Clarifications and Expectations segment of both publications, the article clarified some issues that have been resulting in TJC requirements for improvement (RFIs) during survey.
Monday, June 3, 2013
Compliance News: Reducing Emergency Power Vulnerabilities
By David Stymiest, PE, CHFM, CHSP, FASHE
Healthcare facility emergency power systems are held to a very high standard. They are expected to deliver power to what they must, when they must, for as long as they must. A review of some medical journals will find references to clinical expectations for “uninterrupted power supply” and similar phrases. In fact uninterrupted power is not guaranteed despite the misconceptions of some clinical personnel. Hospital power systems are not as robust as large data center power systems, and even data center power systems sometimes fail. But healthcare facilities can take steps to reduce the probability of emergency power failures.
Firstly it is helpful to understand the differences between reliability, availability and dependability. Reliability can be considered the probability that a system operates and gives the same result on successive trials. Availability on the other hand can be considered the probability that a system will function at any instant required, including the next instant, and for as long as required from that point. And finally dependability can be considered as the metric that measures availability, reliability & maintenance support.
By David Stymiest, PE, CHFM, CHSP, FASHE
Healthcare facility emergency power systems are held to a very high standard. They are expected to deliver power to what they must, when they must, for as long as they must. A review of some medical journals will find references to clinical expectations for “uninterrupted power supply” and similar phrases. In fact uninterrupted power is not guaranteed despite the misconceptions of some clinical personnel. Hospital power systems are not as robust as large data center power systems, and even data center power systems sometimes fail. But healthcare facilities can take steps to reduce the probability of emergency power failures.
Firstly it is helpful to understand the differences between reliability, availability and dependability. Reliability can be considered the probability that a system operates and gives the same result on successive trials. Availability on the other hand can be considered the probability that a system will function at any instant required, including the next instant, and for as long as required from that point. And finally dependability can be considered as the metric that measures availability, reliability & maintenance support.
Friday, May 31, 2013
Compliance News: CMS Issues Categorical Waiver
By David Stymiest, PE, CHFM, CHSP, FASHE
The Centers for Medicare & Medicaid Services (CMS) issued a categorical Life Safety Code waiver permitting new and existing ventilation systems supplying hospital and critical access hospital (CAH) anesthetizing locations to operate with a relative humidity (RH) of ≥20%, instead of ≥35%. CMS is also recommending that RH not exceed 60% in these locations.
CMS issued the new Survey & Certification memorandum # S&C: 13-25-LSC & ASC on April 19, 2013. In its S&C memo, CMS referenced the recent code changes that adopted the lower requirements. Many hospitals are expected to welcome this change, and it was supported by ASHE.
Organizations will not need to apply for this waiver or wait until they are cited by CMS or by state validation surveyors representing CMS. However if organizations choose to take advantage of this waiver, they are required to document their decision to do so (such as within Safety Committee meeting minutes) before they start using it. Organizations are also required to advise every Life Safety Code survey team at the beginning of any survey of their prior decision to use the CMS waiver. CMS stated that lack of documentation of the prior decision to use the waiver may result in citations that would otherwise have been unnecessary.
The CMS waiver does not overrule more stringent state or local laws or regulations nor does it apply if the reduction of the relative humidity would negatively affect ventilation system performance.
According to CMS, organizations must still monitor relative humidity levels in anesthetizing locations and must take action when needed to ensure that RH levels remain at or above 20%. Specifically, the CMS S&C memo stated “Facilities must monitor RH levels in anesthetizing locations and be able to provide evidence that the RH levels are maintained at or above 20%. When outdoor humidity and internal moisture are not sufficient to achieve the minimum humidity level, then humidification must be provided by means of the hospital’s or CAH’s ventilation systems. In addition, facilities must provide evidence that timely corrective actions are performed successfully in instances when internal monitoring determines RH levels are below the permitted range.”
The categorical waiver contains 17 pages of details including updated State Operations Manual Appendices A, I, L and W. All organizations should obtain a copy of the letter and review it closely.
The URL for the CMS Survey and Certification Memo is:
http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-13-25.pdf
By David Stymiest, PE, CHFM, CHSP, FASHE
The Centers for Medicare & Medicaid Services (CMS) issued a categorical Life Safety Code waiver permitting new and existing ventilation systems supplying hospital and critical access hospital (CAH) anesthetizing locations to operate with a relative humidity (RH) of ≥20%, instead of ≥35%. CMS is also recommending that RH not exceed 60% in these locations.
CMS issued the new Survey & Certification memorandum # S&C: 13-25-LSC & ASC on April 19, 2013. In its S&C memo, CMS referenced the recent code changes that adopted the lower requirements. Many hospitals are expected to welcome this change, and it was supported by ASHE.
Organizations will not need to apply for this waiver or wait until they are cited by CMS or by state validation surveyors representing CMS. However if organizations choose to take advantage of this waiver, they are required to document their decision to do so (such as within Safety Committee meeting minutes) before they start using it. Organizations are also required to advise every Life Safety Code survey team at the beginning of any survey of their prior decision to use the CMS waiver. CMS stated that lack of documentation of the prior decision to use the waiver may result in citations that would otherwise have been unnecessary.
The CMS waiver does not overrule more stringent state or local laws or regulations nor does it apply if the reduction of the relative humidity would negatively affect ventilation system performance.
According to CMS, organizations must still monitor relative humidity levels in anesthetizing locations and must take action when needed to ensure that RH levels remain at or above 20%. Specifically, the CMS S&C memo stated “Facilities must monitor RH levels in anesthetizing locations and be able to provide evidence that the RH levels are maintained at or above 20%. When outdoor humidity and internal moisture are not sufficient to achieve the minimum humidity level, then humidification must be provided by means of the hospital’s or CAH’s ventilation systems. In addition, facilities must provide evidence that timely corrective actions are performed successfully in instances when internal monitoring determines RH levels are below the permitted range.”
The categorical waiver contains 17 pages of details including updated State Operations Manual Appendices A, I, L and W. All organizations should obtain a copy of the letter and review it closely.
The URL for the CMS Survey and Certification Memo is:
http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-13-25.pdf
Friday, May 3, 2013
CMS Issues Categorical Waiver to Lower OR Humidity Requirement
CMS is lowering the humidity requirement for operating rooms from at least 35 percent to at least 20 percent. In its S&C letter, CMS referenced the recent code changes that adopted the lower requirements.
You will not need to apply for this waiver or wait until you are cited, however if you choose to take advantage of this waiver (and I expect many hospitals will) you must document your decision to do so (such as within your Safety Committee meeting minutes) before you start using it. You must also advise every Life Safety Code survey team at the beginning of any survey that you have made the prior decision to use the CMS waiver. CMS stated that lack of documentation of your prior decision to use the waiver may result in your being cited against the 35 percent requirement.
The CMS waiver does not overrule more stringent state or local laws or regulations.
The CMS waiver does not apply if the reduction of the relative humidity would negatively affect ventilation system performance.
According to CMS, you must still monitor relative humidity levels in anesthetizing locations and must take action when needed to ensure that RH levels remain at or above 20 percent.
The URL for the CMS Survey and Certification Memo is:
I suggest that you read the entire CMS S&C memo and share it with your staff.
Monday, April 8, 2013
Compliance News: The Power of Tracers
by David Stymiest, PE, CHFM, CHSP, FASHE
The Joint Commission (TJC) discussed the use of a sample hazardous material and waste management environment of care (EOC) tracer in its March 2013 issue of EC News. The article provided specific examples for conducting the tracer to explore issues related to orientation and training, physical environment, and quality improvement priority focus areas.
EC News articles also discussed the use of non-patient tracers in June 2011 (sterilizer maintenance) September 2012 (fire safety) and November 2012 (utilities systems). An earlier Joint Commission International publication also discussed the uses and benefits of a similar tracer methodology approach called System Tracers. In the writer’s opinion, tracers of this nature have been proven to be extremely powerful in assessing not only compliance with individual TJC Standards and Elements of Performance but also in determining where opportunities for improving the EOC management processes exist within an organization. As TJC also stated in its November 2012 issue, “Performing mock tracers can help your organization evaluate the effectiveness of its policies, engage staff in looking for opportunities to improve processes, and identify compliance issues that need attention.”
EC News articles also discussed the use of non-patient tracers in June 2011 (sterilizer maintenance) September 2012 (fire safety) and November 2012 (utilities systems). An earlier Joint Commission International publication also discussed the uses and benefits of a similar tracer methodology approach called System Tracers. In the writer’s opinion, tracers of this nature have been proven to be extremely powerful in assessing not only compliance with individual TJC Standards and Elements of Performance but also in determining where opportunities for improving the EOC management processes exist within an organization. As TJC also stated in its November 2012 issue, “Performing mock tracers can help your organization evaluate the effectiveness of its policies, engage staff in looking for opportunities to improve processes, and identify compliance issues that need attention.”
Compliance News: Risk Icons Considered as TJC FSA Replaces PPR
by David Stymiest, PE, CHFM, CHSP, FASHE
Users of The Joint Commission’s (TJC’s) 2012 "Update 2" and 2013 accreditation manuals found a new RISK ICON "R" in selected elements of performance. According to TJC in its September 26, 2012 Joint Commission Online edition, This new icon is related to TJC’s "Replacement of the Periodic Performance Review (PPR) with the Focused Standards Assessment (FSA)" and the "new risk icons denote elements of performance (EPs) assessed through the FSA process, applicable to all except the long term care program." A more comprehensive discussion occurred in TJC’s October 2012 Perspectives.
Compliance News: EOC Risk Assessments
by David Stymiest, PE, CHFM, CHSP, FASHE
In
its March 2013 issues of both Perspectives and EC News The Joint
Commission (TJC) continued to promote the use of risk assessments to
evaluate whether to accept, mitigate or avoid environmental risks when
there not definitive right or wrong answers. The articles by Joint
Commission engineering director George Mills reiterated previous TJC
guidance on 7-step risk assessments.
Read more »
Read more »
Friday, March 15, 2013
Generator Risk Assessments
An ASHE member recently posted on the ASHE Listserv asking if anyone knew of a generator risk assessment.
We responded to the Listerv:
1. "Log into ASHE's website and go to
http://www.ashe.org/resources/management_monographs/mg2009stymiest.html
http://www.ashe.org/resources/management_monographs/mg2009stymiest.html
2. "Managing Hospital Emergency Power Systems - Testing, Operation, Maintenance and Power Failure Planning".
3. A PDF of this document is available for free to all ASHE members. It can be downloaded from that URL.
3. A PDF of this document is available for free to all ASHE members. It can be downloaded from that URL.
Please feel free to contact me if you have any questions.
Monday, January 7, 2013
After The Storm - Expanding the Concept of Emergency Power Reliability
by David Stymiest, PE, CHFM, CHSP,
FASHE
As
mission-critical equipment, hospital emergency power systems are
expected to provide power consistently to what they must, when they must
and for as long as they must. This is a tall order, and the impact of
an emergency power system failure when normal utility power also has
failed is potentially severe for patient care.
The
failure of some facility emergency power systems during and after last
fall’s superstorm Sandy already has spawned investigations, which
ultimately will result in lessons learned and more knowledge upon which
health facilities professionals can base best practices to reduce
vulnerabilities.
Thursday, December 6, 2012
Compliance News: Holiday Decorations
by Robert Trotter, BS, MCP and David Stymiest, PE, CHFM, CHSP, FASHE
Many of this newsletter’s readers are regularly confronted with questions concerning holiday decorations. The Joint Commission’s 2012 Hospital Accreditation Standards, Standard LS.02.01.70 EP-1 states: “The hospital prohibits all combustible decorations that are not flame retardant. (For full text and any exceptions, refer to NFPA 101-2000: 18/19.7.5.4.)”
In NFPA 101-2000®, paragraph 18/19.7.5.4 states “Combustible decorations shall be prohibited in any health care occupancy unless they are flame-retardant. Exception: Combustible decorations, such as photographs and paintings, in such limited quantities that a hazard of fire development or spread is not present.”
Compliance News: ECRI Institute Lists 2013's Top 10 Health Technology Hazards
by David Stymiest, PE, CHFM, CHSP, FASHE
The ECRI Institute recently published a 25-page special report entitled “ECRI Institute 2013 Top 10 Health Technology Hazards” – available at www.ecri.org/2013hazards. In its introduction, ECRI encourages facilities to use the list of generic hazards as a “starting point for patient safety discussions and for setting their health technology safety priorities.” This report is comprehensive with a multitude of useful recommendations along with exhaustive lists of further reference publications. We recommend that our readers use the link above to acquire their own copies of the ECRI publication for review and possible action.
ECRI stated that it considered a number of factors in determining which hazards actually made it to the top 10 list, including potential for harm, frequency/likelihood of the hazard, how widespread is the hazard, whether the problem is difficult to recognize or challenging to rectify, and whether the hazard has a high profile in the media.
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