Jul 24 2017

Temperature and Humidity Logs for Surgery Hallways

Category: Humidity,Questions and Answers,TemperatureBKeyes @ 12:00 am

Q: During our mock inspection this week at our hospital, they are asking for temp and humidity checks in the surgery hallways. We do monitor the surgery rooms and center core room, along with sterile storage and clean rooms. Is there a regulation or code to monitor the hallway in any part of a hospital?

A: While there are no direct and specific standards that require the monitoring of temperature and humidity in a surgery hallway, it could be an issue that the mock surveyor is concerned about. If you’re Joint Commission accredited, they do have a couple of standards that address this issue:

EC.02.06.01, EP 13

This standard requires the hospital to maintain proper ventilation, temperature and humidity levels suitable for the care, treatment, and services provided. If the mock surveyor believed the temperature or humidity levels in the surgery hallway were not suitable then that would be a legitimate finding. But, this standard does not require the hospital to maintain logs that they are constantly monitoring the temperature or humidity levels.

EC.02.05.01, EP 15

This standard requires the hospital to ensure the ventilation system provides the appropriate air-pressure relationships, air-exchange rates, and filtration efficiencies in areas designed to control airborne contaminants. A note underneath this standard explains that areas designed for the control of airborne contaminants include operating rooms, special procedure rooms, delivery rooms, etc. It does not specially include surgery hallways as an area designed for the control of airborne contaminants, but it would fall under the provisions of air-pressure relationships to the ORs and clean or dirty utility rooms.

It all falls back on what the mock surveyor saw, and why they cited it. If there was a serious deficiency with temperature or humidity in the surgery hallway then the finding appears to be legitimate. However, if the mock surveyor’s opinion is you should be monitoring and logging the temperature and humidity in the surgery hallway just because the mock surveyor thinks it is a good idea, then that does not seem to be a legitimate finding. I suggest you appeal this finding.

Jan 27 2017

Humidity and Temperature in Central Supply

Category: Humidity,Questions and Answers,TemperatureBKeyes @ 12:00 am

Q: I’m working with a hospital on their temperature and humidity monitoring in their Central Supply area, and was wondering what specific parameters they should follow in the two different areas of Central Supply/Storage; and Decontam Area? Should the FGI Guidelines be followed or should the AAMI guidelines be followed?

A: If the organization is CMS certified, all CMS requires on the subject is found in standard §482.41(c)(4) which says “There must be proper ventilation, light, and temperature controls in pharmaceutical, food preparation, and other appropriate areas.” In their Interpretive Guidelines section, they identify the FGI Guidelines as an acceptable standard to incorporate. While they do reference other standards, such as AORN, OSHA, CDC, and NIH, they do not mention AAMI. So, it would seem acceptable to use the FGI Guidelines in this application. Could your client use AAMI guidelines instead? Yes, but they may have to defend this decision (through the use of risk assessments) to surveyors and inspectors.

The interesting thing with CMS is their standard §482.41(c)(4) does not specifically state that the use of the FGI Guidelines are for new construction and renovation only. This has led to some erroneous findings by state agencies performing validation surveys on behalf of CMS whereby surveyors have cited existing conditions that did not meet the more restrictive current edition of the FGI Guidelines. Even in the preface to the current FGI Guidelines, it states that their standards only apply to new construction and renovation, and is not retroactive to existing conditions. CMS has since issued informal communications that the FGI Guidelines only apply to new construction and renovation.

Moving to the Joint Commission standard EC.02.06.05, EP 1, we find that they require compliance with the 2014 FGI Guidelines for new, altered or renovated spaces only; not for existing conditions. HFAP standard 11.07.03 is a repeat of CMS standard §482.41(c)(4) and also references the current edition of the FGI Guidelines. So, it would seem the FGI Guidelines wins by popular affirmation.

When it comes to monitoring, there are differences because the two rooms are not considered to be the same. The Central Supply/Storage is considered a clean room and the Decontam Area is considered a dirty room. If there is an opening between the two rooms, there must be a positive air flow from the clean side to the dirty side.

For new construction:

  • The Sterile Supply/Storage room is required to have a positive air pressure, with a minimum of 4 total air-changes per hour that includes 2 outdoor air changes per hour; and a maximum relative humidity of 60% (no minimum requirements), and a design temperature of 72° – 78° F.
  • The Decontam Area is required to have a negative air pressure, with a minimum of 6 total air-changes per hour that includes 2 outdoor air changes per hour; and there is no maximum or minimum relative humidity required, and a design temperature of 72° – 78° F.

It is important to remember that the current FGI Guidelines are in fact guidelines and not standards. It is very possible that older existing hospitals may not be able to meet these ventilation requirements for new construction. In those cases, it is important to verify what guidelines or standards the ventilation requirements were designed to, and whether or not they are still meeting those original design requirements.

As far as frequency of monitoring… There is not much stated in writing, but Joint Commission seems to expect daily monitoring of air-pressure requirements, which can be easily accomplished through various methods. The least expensive approach is to use a tissue at the bottom of the door to observe whether the air pressure is positive or negative. Other methods utilize inexpensive manual indicators (ball-in-tube, flappers) mounted in the wall near an entrance door, to more elaborate electronic monitoring equipment that would send messages to plant operators when the air pressure is non-compliant.

The air changes per hour rate is much more difficult to monitor, and usually requires manually measuring the air flow at each supply and return/exhaust diffuser with bulky flow-hoods. This is usually done annually, or more often if there have been problems in the past.

Humidity monitoring can be done manually with sling psychrometers; small inexpensive portable battery-operated humidity monitors; or electronic monitoring through the building automation system. The beauty of the building automation system doing the monitoring is it is automatic and there is a record (log) of the measurements; and if there is a reading out of the acceptable range, it automatically notifies the plant operator. The frequency of monitoring temperature and humidity is not stipulated, but it would be reasonable that a surveyor would expect the hospital to have the frequency identified through a risk assessment. I suggest the hospital monitor and log the temperature and humidity daily. Again, it must be documented through a risk assessment to have any validity with a surveyor. If there are other guidelines that recommend more frequent monitoring (such as AORN, AAMI or CDC) then those should be followed.

Aug 14 2015

Nursing Home Temperatures

Category: Nursing Home,Questions and Answers,TemperatureBKeyes @ 12:00 am

Q: My loved one is in a nursing home and needs additional heat in the winter time, what do I do? The building seems to be at a comfortable temperature, but my family member needs extra heat. Is there a heating blanket that passes code? 

A: The CMS State Operations Manual for Nursing Homes, sub-parts 483.70(c) and 483.70(h) requires a ‘comfortable’ environment for the resident. However, CMS does not define what temperature dictates a comfortable environment. Check with the state that the nursing home is located and determine if they have temperature limits for nursing homes. Enter “state regulations for nursing homes” in your internet search engine and include the name of the state the nursing home is located. They may have their state licensing requirements available for download and you can see if they have temperature ranges specified for the residents.

The temperature of the facility is typically set and controlled by nursing home staff, who are active and walking about, performing duties. The residents of the nursing home are typically sedentary and therefore inactive. This difference can cause the workers to be over-heated when the temperature is raised to satisfy the residents, or the residents are uncomfortable when the temperature is set to satisfy the workers. It is a problem that is not easy to resolve. 78° may be a comfortable temperature for residents who are inactive, but would be too warm for workers who are scurrying about. Likewise, 72° may be a comfortable temperature for workers but may be too cool for residents. If you set the temperature in the middle at 75°, you may have a better chance of satisfaction, but ultimately, someone will be uncomfortable. It is not uncommon to see workers wear summer clothing in the middle of winter.

Portable heating devices, such as a space heater are not permitted in patient care areas, according to CMS rules and the NFPA Life Safety Code section 19.7.8 (2000 edition). Electric blankets are not directly addressed by NFPA codes and standards, but it is a good bet that the nursing home would not (or should not) permit them, as they can be dangerous in an institutional setting. Cords can become easily and quickly damaged from moving beds and rolling carts, creating the potential for sparks from electrical shorts. Temperature settings on the control can be fixed too high, or accidentally increased by the resident causing epidermis damage. Hospitals that I consult with typically do not allow electric blankets, and I would not recommend their use in a nursing home. Perhaps warm blankets from a blanket warmer may be a temporary solution to the problem.

The nursing home has an obligation to provide a comfortable environment for your loved one. If you feel there is an inadequate response to your concerns by the nursing home, you can file a complaint at CMS for conditions that you believe are sub-par based on the State Operations Manual for nursing homes:   http://www.medicare.gov/claims-and-appeals/file-a-complaint/complaints.html

I’m sorry if this is not the answer that you are looking for, but I do not believe there are portable heating devices for a nursing home resident that would be permitted under CMS rules and NFPA Life Safety Code standards.