O&P Business News spoke to the experts for ways to ensure safety in orthotic and prosthetic facilities.
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Many O&P practitioners enter the profession with the goal of improving the quality of life for people with limb challenges. Part of caring for patients in this way, however, includes ensuring their safety — and that of other employees — in the office as well.
Accrediting O&P facilities since 1948, the American Board for Certification in Orthotics, Prosthetics and Pedorthics (ABC) also is a deemed authority by Medicare for the Medicare Quality Standards, D. Scott Williamson, Jr., CAE, director of facility accreditation and information services for ABC, said. ABC’s Facility and Safety Management Standards are drawn from governmental agencies, as well as common sense knowledge of the O&P industry and its specific needs.
Accreditation surveyors undergo weeks of training each year to ensure they remain current on standards and issues relevant to O&P facilities. ABC also maintains an advanced communication system for surveyors and leadership so that the information remains consistent.
ABC standards
The first issue Williamson emphasizes is whether or not O&P practices comply with the appropriate provisions of state and local health and fire codes and occupancy classifications. Depending on the location, allied health care facilities may need to comply with either one or both of the two major building code guidebooks jurisdictions used to approve occupancy for buildings: the Building Officials and Code Administrators International (BOCA) codes or the National Fire Protection Association Life Safety codes.
Safety issues tend to get passed over in the everyday details of business, Williamson said, but that does not mean practices are safe. In the course of the last 18 months, there have been more than a dozen catastrophic lab fires in O&P facilities, he told O&P Business News.
In one case, Williamson said, employees walked into the facility one morning to find that everything had melted — telephones melted off the walls, computers melted onto desks — as a result of an intense fire in the laboratory area overnight. The facility ran an extension cord behind the area where plastic was stored, and it had worn out over time. On this particular day, the cord reached the burning temperature of the plastic and the plastic caught fire and spread to the rest of the lab.
Fortunately in that case, the fire had burned itself out in the air-tight lab, but the damage already had been done, he said.
Surveyors explain situations such as this to facility owners during visits. Although it is not part of ABC accreditation standards, surveyors advise business owners not to use extension cords in the first place; if they are necessary, facilities must be sure to use high-quality cords and replace them as they wear out.
Surveyors also point out when fire extinguishers are not up-to-date on their inspections by looking at their tags, as well as teaching those in charge of safety at the facilities how to check if the powder is compacted inside the extinguisher.
“Our standards say that you have a fire program and you have a safety officer, [but] it’s rare to find a person who’s trained in safety management in this profession,” Williamson said. “We try to educate when we come on site.”
This safety officer should maintain a checklist of safety items to review, and know when to check for these issues and who to hire to fix problems accordingly.
Office considerations
O&P facilities must have office spaces available to run the business, but how much space is considered adequate? Office areas should be dedicated spaces and must not double as patient rooms. In addition, business owners should consider proper storage of office supplies.
A large part of preventing hazards, even in office spaces, is cleanliness and organization, Williamson said.
“If you have shelves with stacks and stacks of stuff on them and boxes are blocking the sprinklers, that is a safety hazard,” he said.
He offers facilities a tip he learned when he was in charge of safety, security and housekeeping for a hospital: “Train yourself to look around. You know that there’s a fray in the carpet, or you know that that extension cord is draped across the hall, and you step over it without thinking about it.”
But these are potential safety hazards. Safety officers should walk around the office, looking both up and down for issues.
“Lie back on your exam table. Are your ceiling tiles stained from water? Do you have mold and mildew growing in there?”
He also suggests enlisting a friend to walk through the facility to look for possible hazards.
Within the allied health environment are issues specific to the practice. Overall, however, practitioners are treating patients, and should have the essential items available to do so. Each facility, for example, should have at least one complete first aid kit at all times. After removing an item from the kit, someone — perhaps the designated safety officer — must be sure to replenish it, and keep an up-to-date inventory of the kit’s contents.
Delving deeper into the health care realm, O&P facilities also must have in place methods to reduce the risk of transmission of infection. Although O&P practitioners typically do not deal with blood or other body fluids, there still is the chance of spreading infection. Patients may carry Methicillin-resistant Staphylococcus aureus (MRSA), which can be easily transmitted from one patient to another or from patient to practitioner. For this reason, practitioners must wipe down patient tables and other patient contact surfaces after every patient.
“We’ve had facilities that, when we ask them about their processes, they say they wipe down those tables every single day,” Williamson said. “That’s not good enough.”
Further, practitioners must be able to properly dispose of wound dressings and other materials that might come into direct contact with open skin.
For pediatric-intensive practices, business owners must take a different — smaller — approach to ensuring safety for patients. Outlets should be covered with protective caps, for example.
“We get down on the level of the kids and look around, the places where grownups don’t usually look. What hazards do we see down there?” he said.
Practices specializing in elder care, on the other hand, should consider issues that might affect an older population.
O&P functions
Under the umbrella of maintenance issues, surveyors examine O&P fabrication machines for proper maintenance. They check that items like belts on routers are in good shape and will not snap and fly off, causing possible injury to technicians. Business owners must be certain that there are no broken lights; if light sockets are missing lights, employees and patients could stick their fingers in those sockets and shock themselves. Williamson stresses the importance of having a maintenance process to check for these matters.
ABC accreditation standards require a specific and dedicated laboratory area for servicing, maintaining, repairing and modifying items, and for good reason. Patients can get injured or inhale toxic fumes if they are exposed to the area where technicians grind down a socket.
Any area of a facility that deals with chemicals should have working vent hoods to expel fumes. Another possible complaint deals with canister respirators, which must be certified and fit to a specific individual. Williamson said the government-enforced penalty for sharing the respirators is a minimum $5,000 fine per mask.
Machine safety guards, which often get in the way of being able to maneuver device elements, are required pieces of the machinery, and ABC surveyors check for them.
“I’ve yet to be in an O&P facility where the guards aren’t gone,” Williamson said. “If the guards are off the machine, you’re creating a potential problem for yourself.”
Contingency plan
Perhaps even more important than preventing possible issues is having a plan for what to do when a problem inevitably occurs.
In the case of the company where the computers melted, Williamson said, the staff was unable to access scheduling information and patient files.
“They had to stand outside and wait for people to show up and tell them they couldn’t come in,” he said.
Often, the fire marshal, the police or the insurance company will not allow entrance into the building until the cause of the fire has been determined. Even if records are kept in a fireproof safe in the office, staff members may not be able to access them right away. Williamson suggests having a back-up system off-site so that patients can be contacted with information about alternative arrangements.
This type of plan falls under the requirement that facilities have a disaster plan.
Another standard requires an emergency evacuation drill to keep patients and employees safe as a disaster is happening. As part of practice for fire drills, facilities should designate a staff member to check every room for patients and usher them to safety. Careful thought should be placed on this task, however.
“Do you have a 90-pound receptionist who’s responsible for evacuating the patient rooms, and you’ve got a 350-pound bilateral amputee back there? How’s she going to do it? Do you have wheelchairs available?” he said. “That’s the kind of thing we want people to think about and then drill. Everybody hates doing fire drills but it’s so important to have it routinized so you know what to do when the time comes.”
OSHA regulations
An overriding presence in facility safety standards is the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA), an organization created in 1971 to prevent work-related injuries, illnesses and deaths. Although OSHA has no standards specific to orthotics and prosthetics, its safety and health standards for health care facilities apply to the O&P profession.
Many people misunderstand that OSHA’s rules do apply to small allied health care facilities, Williamson said.
It is true that businesses with 10 or fewer employees that also belong to an industry with low injury and illness rates may be granted an exemption from programmed safety inspections, however they do not receive an exemption from programmed health inspections.
Regardless of this possible exemption, OSHA has jurisdiction over even the smallest practices.
Also, it is important to note that the list of industries that have low illness and injury rates is updated annually, and is therefore subject to change. “Programmed” worksite inspections are those that are scheduled based upon objective or neutral criteria. These inspections do not include those prompted by imminent danger, fatality or catastrophe and formal complaints.
“If you’re a two-person operation, and person two files a complaint about a workplace safety issue, OSHA has jurisdiction,” Williamson said.
He recalls a case where an employee cut off a part of his thumb on a band saw at an O&P facility, and went to the hospital for treatment. At the hospital, his injury was coded as a workplace amputation, which alerted OSHA to visit the facility and do an inspection. In cases such as that, the small size of O&P practices does not matter.
According to a spokesperson for the organization, OSHA’s top priorities in completing facility inspections consist of reports of imminent dangers or accidents about to happen; fatalities or accidents serious enough to send three or more employees to the hospital; employee complaints; referrals from other government agencies; and programmed inspections aimed at specific high-hazard industries, workplaces, occupations or health substances, or other industries identified in its current inspection procedures.
Reasons that OSHA selects specific industries for inspection include factors such as injury incidence rates, citation history, employee exposure to toxic substances, as well as random selection. In addition, OSHA may develop special emphasis programs that are local, regional or national in scope, depending on the distribution of the workplaces involved.
A recent local emphasis program initiated by OSHA, for example, focused on blood borne pathogen exposure in Pennsylvania health care facilities in Philadelphia, Allentown, Erie, Charleston and Pittsburgh.
Enforcement plays an important part in OSHA’s efforts to reduce workplace injuries, illnesses and fatalities. When the agency finds employers who fail to uphold their employee safety and health responsibilities, OSHA deals with them strongly, the spokesperson said.
Safety violations
The number one safety violation Williamson sees is improper storage of flammables, he said.
“They might have a fire cabinet, but the doors of the fire cabinet are left open. We’ve found acetone in Aunt Jemima syrup bottles, sitting out on people’s desks,” he said. “That’s a bad thing.”
All chemicals must be properly labeled and in proper containers.
Along the same lines is the break room. Employers providing a break room must be certain that it is kept separate and distinct from the laboratory and patient areas, and food items must not be stored in a lab refrigerator or vice versa.
Local codes also designate proper storage of large quantities of those flammable chemicals.
“You shouldn’t take your 10 one-gallon cans of acetone and store them all together in one spot, unless it’s in a fireproof cabinet,” Williamson said.
Another seemingly obvious standard is that there should be a no-smoking policy near all flammables and lab areas. ABC’s preference is that facilities maintain a full no-smoking policy covering all areas of the facility, he said, but if necessary, there should be a designated smoking area, away from lab and patient areas.
Other top safety violations Williamson sees are improper equipment maintenance, improper fire extinguisher maintenance and first aid kit maintenance.
Information resources
Business owners have several places to turn for information and assistance in increasing safety precautions for their facilities.
For one, OSHA offers a variety of materials, including brochures, booklets, fact sheets, guidance documents and online references, that highlight pertinent safety and health information related to the health care industry. These materials are available on the OSHA Web site.
In addition, ABC features its full list of accreditation standards on its Web site.
Most important, however, Williamson emphasizes a common sense approach to overall safety. Since O&P facilities owners have additional business concerns, they should designate others to consider safety issues. This will prevent safety issues from damaging — literally — the business.
Williamson encourages business owners to think about the ramifications of not being prepared.
“It shuts down your business,” he said. “Could you recover if your building burned down? What would you do? Is it worth 5 minutes a month of just doing a quick visual survey to see if everything looks okay?” — by Stephanie Z. Pavlou
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