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If it's September, it's time for Executive Briefings!

Hospital Safety Insider, September 12, 2018

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 I suspect that, over the next few weeks, as I learn of stuff coming out of the various and sundry Joint Commission Executive Briefings sessions, I’ll be sharing some thoughts, etc., in those regards here in the ol’ blog.

The first thing to “pop” at me was some information regarding Chapter 15 (Features of Fire Protection) in NFPA 99 Health Facilities Code (2012 edition) relating to the management of surgical fire risks. If you’ve not had a chance to check out section 13 of said chapter, I think it will be worth your while as there are a couple of things that in the past one might have described as a best practice. But, with the official adoption of NFPA 99 by CMS, this has become (more or less, but definitely more than before) the law of the land. From a practical standpoint, I can absolutely get behind the concepts contained in this section (I’m pretty comfortable with the position that any surgical fire is at least one more than we should have), but from a strict compliance standpoint, I know that it can be very challenging to get the folks up in surgery to “play ball” with the physical environment rules and regulations.

As one might expect, the whole thing breaks down into a few components: hazard assessment; establishment of fire prevention procedures; management of germicides and antiseptics; establishment of emergency procedures; orientation and training. I think the piece of this that might benefit from some focused attention relates to the management of germicides and antiseptics, particularly as a function of the required “timeout” for the germicide/antiseptic application process. And yes my friends, I did say “required”; Section 15.13.3.6 indicates (quite specifically) that a preoperative “timeout” period shall be conducted prior to the initiation of any surgical procedure using flammable liquid germicides or antiseptics to verify that:

• Application site of flammable germicide or antiseptic is dry prior to draping and use of electrosurgery, cautery, or a laser
• Pooling of solution has not occurred or has been corrected
• Any solution-soaked materials have been removed from the operating room (OR) prior to draping and use of electrosurgery, cautery, or a laser

Now, I will freely and openly admit that I’ve not done a deep dive into the later chapters of NFPA 99 (though that’s on my to-do list), so I hadn’t bumped into this, but I can definitely see this being a potential vulnerability, particularly in light of the recent FDA scrutiny (and it goes to Linda B’s question in follow-up to a recent blog posting—I probably should have turtled to this at that point—mea maxima culpa). At any rate, nothing in this section of NFPA 99 is arguable unless you don’t have it in place and a surveyor “goes there,” so perhaps you should be sure that your OR folks are already “there” sooner rather than later.

Two closing items:

• The good folks at the Facilities Guidelines Institute have provided a state-by-state resource identifying which states have adopted the FGI guidelines (completely, partially, not really). You can find that information here.
• Also,  Triumvirate Environmental is presenting a couple of webinars over the next little while that might be of interest. The one this week (sorry for the short notice) deals with the recently established by EPA’s Hazardous Waste e-Manifest Program and then the week after next, there’s a program on Best Practices to Optimize Your Waste Documentation Program. While I can’t call these crazy risky survey vulnerabilities, EC.02.02.01 is still percolating around the top of the most frequently cited list, so it never hurts to obtain greater familiarity with this stuff.

Enjoy your week safely!

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