Aerosol Can Storage

Q: Our nursing home just completed a state survey and while we were not cited we were “warned” that all aerosols are to be put into fireproof cabinet. The metal cabinets and toolboxes we have them in currently are not adequate. We use metal toolboxes on housekeeping carts to store one can of each cleaning product we use. The surveyor said these would have be logged in and out daily from fireproof cabinet. Is this an actual NFPA requirement?

A: This is not a Life Safety Code requirement. I’m always suspicious when I hear a surveyor ‘warns’ a facility about an alleged issue rather than actually cite them. In this day and age of the CMS dominant mantra of “If you see it, cite it” mentally, I have to question why didn’t the surveyor actually cite it. One reason could be that it is not a violation of any code or regulation, but it is a surveyor preference. Perhaps the surveyor is using his/her authority to cajole the facility into doing something that is actually not required. Would the facility be safer if all aerosols are stored in a fire-rated cabinet? Perhaps, but if it is not a requirement then the ends have to justify the means.

You didn’t say what was in the aerosol cans; are the contents flammable? According to NFPA 30-2012 flammable liquids are permitted to be stored in their original containers up to 1-gallon in size, and you do not need special containment (i.e. fire-rated cabinet) until the aggregate total of the stored product (per smoke compartment) reaches 5 gallons. To me, aerosol cans placed on a housekeeper’s cart would not be considered in storage – they would be considered in use. However, there are other aspects to consider: Are the cans of aerosol products on the housekeeper’s cart safe from unauthorized individuals (i.e. children, dementia patients)? If not, then that may be a valid reason to place them inside a storage container.

I’m not telling you to NOT follow the surveyor’s advice, but I am saying the warning is not based on Life Safety Code or other NFPA requirements. Perhaps it is based on state or local regulations. If you haven’t already done so, ask him/her to cite the code or standard that requires the storage requirements. If there is an actual code or standard that requires it, then we learned something. But if there is not an actual code or standard that requires it, then the surveyor will back down and admit it is a recommendation or preference.

Heated Massaging Seat

Q: I work at an ICF facility. We have a person with arthritis and I was just asked if a heated pad massaging seat could be purchased for them. I know we can’t have heated blankets, personal heaters, etc. With this item having heat, I would assume it would probably not be approved either. Can I get your input??

A: There are no CMS codes or standards that would prohibit this type of device. Actually, there are no codes or standards that would prohibit electric heating blankets, but the perceived risk of danger usually disqualifies them from use.

There will be risks in using this heated, massaging seat that you need to address, such as:

  • Trip hazard with the electrical cord
  • Something heavy rolling on the electrical cord creating a pinch-point, thereby causing a short-circuit over time
  • The seat becoming too hot for the patient

If you address these risks in a risk assessment and mitigate them to the satisfaction of the surveyor, you should be fine.

Strange Observations – Part 27

Continuing in a series of strange things that I have seen while consulting at hospitals…

Older mechanical equipment rooms are going to be a problem for many hospitals. Ultimately, you will find an air-handler or an exhaust fan that has its belt guard missing.

Now, I believe OSHA allows a no-belt guard for equipment that is up off of floor by a certain amount… don’t know how much.

Time to replace the belt, eh?

 

Strange Observations – Part 24

Continuing in a series of strange things that I have seen while consulting at hospitals…

This picture was taken in a staff lounge on a general med-surge unit. I thought it was strange to see a two-burner stove top section on the counter in the staff lounge.

I asked the staff if they had a risk assessment that assesses the risk of fire to surrounding items, and they said they did not.

I cited them for not maintaining a safe environment for their staff.

Construction Safety at a Hospital

I learned recently that a hospital is being sued by the family of a woman who fell in a construction zone and subsequently died. The 85-year-old woman walked past an empty nurses station, through an unlocked door, and fell into a construction pit inside the facility.

The woman suffered a traumatic brain injury and subdural hematoma from the fall, according to court records. In the three weeks before she died, she could rarely recognize her daughter and suffered nightmares.

According to the lawsuit, the state department of health and social services had inspected the hospital 9 days before the accident and noted in a 58-page report that the center had three doors leading to construction areas that, in violation of state safety codes, were left unlocked.

This is a tragedy and I’m sure everyone involved feels terrible about the incident. I purposely did not identify the hospital because that’s not the point… I’m sure they are beating themselves up over this as well.

But it sure appears it was preventable… especially after the state inspectors came in and told them they needed to lock the doors to the construction area.

Every hospitals claims to have excellent patient safety at the foremost of their efforts. And I believe what they mean when they say patient safety is safety concerning clinical and medical issues. What many hospitals seem to overlook or flat-out ignore is Life Safety, Physical Environment Safety and Construction Safety is patient safety as well.

This story is a reminder that construction business is not business as usual when it happens in a hospital. Nothing is ‘as usual’ in a hospital. That is why the business of healthcare is one of the most regulated industries in America.

The hospital in the story had a warning from the state 9 days before the tragic accident. If they had complied with state’s findings, it is likely this tragedy would never had happened.

I want you to understand when the state agencies, accreditation organizations, and local authorities conduct a survey or an inspection at your facility, they are there to help you from hurting yourselves and your patients and staff from safety violations that you are not aware of. Embrace that process and learn from those surveys and inspections. It likely will keep you from tragic situations like the one described above.

Electrical Safety Program

Q: I work in a psychiatric hospital. One of the therapies used here involves our clients doing their own personal laundry, so we have multiple laundry rooms off the units with residential grade laundry equipment. Our staff supervises the use of the equipment, but the clients operate the appliances themselves. When I arrived here, there was no electrical safety program in place. Is a program required, and how extensive?

A: Yes… every hospital must have a program for electrical safety, but the codes and standards are not real specific on the matter. If you are Joint Commission accredited, you are required by EC.01.01.01, EP 8 to have a written Utility Management program, and EC.02.05.01 requires the hospital to manage the risks associated with the utility systems. Electrical safety is considered part of the Utility Management plan and needs to be addressed in the written plan. Also, EC.02.06.01 requires the hospital to establish and maintain a safe, functional environment. If a surveyor were to observe any unsafe activity involving electrical safety, he/she could cite a finding under any of these standards.

The accreditation organizations expect hospitals to comply with other regulatory agencies, such as OSHA, state regulations and local ordinances. OSHA expects compliance with NFPA 70E on electrical safety which may involve all of your maintenance staff. In addition, section 9.1.2 of the 2012 Life Safety Code requires compliance with NFPA 70 for all issues requiring electrical wiring and equipment. So, there are multiple regulations and standards that require healthcare organizations to have a safe electrical environment, and the accreditation organization requires that to be included in the written form of the Utility Management plan. How specific you want to make your electrical safety program is up to you and the regulations enforced by the other authorities.

Are Lit Candles Permitted in Healthcare?

candles web 2A reader recently asked me if lit candles are prohibited in a healthcare occupancy? I’ve researched this before but apparently I never posted anything about this subject. No, the Life Safety Code does not prohibit lit candles in healthcare occupancies, but it does address the need to maintain an environment that is reasonable safe from fire. Take a look at section 4.1.1 of the 2000 Life Safety Code, which says this:

“The goal of this Code is to provide an environment for the occupants that is reasonably safe from fire and similar emergencies by the following means:

1)      Protection of occupants not intimate with the initial fire development;

2)      Improvement of the survivability of occupants with the initial fire development.”

Section 6.2.1.2 of the same Code says the hazards of contents (which is the relative danger of the start and spread of fire) shall be determined by the authority having jurisdiction (AHJ) on the basis of the character of the contents and the processes or operations conducted in the building or structure. Furthermore, section 4.6.1.1 says the AHJ shall determine whether the provisions of the LSC are met. This means any one of the many different AHJs that hospitals have to deal with can enforce the lit candle issue as they see fit. While the issue of lit candles are not that common, I have seen accreditation organizations deal with this in different manners.

When I was a surveyor for The Joint Commission, I surveyed a Native American Medical Center in the southwest, and observed the hospital using lit incense as a form of aroma therapy. I called back to the Standards Interpretation Group and asked about it and they said as long as the lit incense was handled correctly in a proper container, they were okay with it. Conversely, I’ve seen lit candles in an office setting which I wrote up as an observation of an unsafe environment.

On a related topic, open flame food warmers such as Sterno and portable cooking appliances using butane gas are considered hazardous by the definition in section 3.3.13.2 of the 2000 LSC which includes heat-producing appliances in the definition of hazardous areas. Section 19.3.2.1 requires hazardous areas to be confined to a room protected with sprinklers, or 1-hour construction; or both if considered new construction. When surveying for the accreditor, I observed many cases where the open flame food warmers were used in rooms and areas that did not qualify as hazardous areas. In at least one situation like that, the Standards Interpretation Group allowed the open flame food warmers if the area was constantly attended by staff and portable fire extinguishers were present. That is an interpretation made by an AHJ, which the LSC allows them to do.

Lit candles used in religious ceremonies in approved candle holders can be considered acceptable by some AHJs if the risk of fire is assessed. A risk assessment can conclude that as long as the hospital staff is present when the candles are lit and the staff has training on the use of portable fire extinguishers, it should be acceptable. But not all AHJs may accept a risk assessment on lit candles, and they would be well within their right to prohibit it.

The candle in the picture above has no business being there. It was located in a physician sleep room inside the hospital and I think there are too many risks to safety in the form of combustibles. Take a look: I see paper plates; plastic packaging; and a can of alcohol-based hand-rub dispenser; and the candle is not necessary. It does not serve a function of therapy and it does not serve a function of spirituality.

Hospitals will have to develop a policy on lit candles if they want to prohibit them, but may expect some push-back from the therapy folks and the religious folks. Perhaps the policy could provide an exception for those purposes, and have the use of lit candles be approved by the Facility Manager or the Safety Officer prior to use.

As always, check with your state and local authorities to determine what regulations they may have on the general use of lit candles.