Safety Considerations in Facility Design

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By Sherry Metzger

Whether you are designing and constructing a new O&P facility or renovating an existing one, patient and employee safety considerations are important. Creating a safe, nurturing, and healing environment for patients that is also functionally efficient and safe for employees can seem like a daunting task-especially considering the variousaccreditation standards and requirements. While an exhaustive list of safety standards is beyond the scope of this article, the following basic overview of safety considerations and additional references should provide a good starting point.

Getting Started

Improperly designed environments may pose serious health risks. Proper planning provides safety and reduces the need to "retrofit" safety features later, which is often a difficult and costly approach. Therefore, it is important to consult specialists such as infection-control professionals, architects, engineers, and safety professionals in the early stages of design. Several accreditation and governmental safety agencies are useful resources to guide healthcare facilities to build infection prevention and safety into the planning process.

Nongovernmental O&P-Specific Accreditation

The Benefits Improvement and Protection Act (BIPA) of 2000-the federal law that establishes the definitions for qualified O&P practitioners and suppliers-defines a qualified O&P supplier or practitioner as "any entity that is accredited by the American Board for Certification in Orthotics and Prosthetics (ABC) or by the Board for Orthotist/Prosthetist Certification (BOC)." Facilities that serve the Medicare population must be accredited by one of these organizations in order to bill for services.

ABC has been accrediting O&P facilities since 1948, focusing on the quality of O&P patient care. The standards, as tested in the field through on-site evaluations, "increase efficiency and support initiatives to improve patient outcomes and the program encompasses comments and recommendations from a variety of resources including the federal government, business owners, clinical practitioners, patients, and healthcare payer and referral sources," according to ABC. For an application, visit www.abcop.org/Facility_Accreditation.asp

BOC, founded in 1984, offers credentialing for orthotists, prosthetists, orthotic fitters, and mastectomy fitters. Facility accreditation standards are "consistent with local, state, and national laws and regulations (e.g., OSHA and ADA)," according to the BOC. An application can be obtained at www.bocusa.org

Late last year, both ABC and BOC received the Centers for Medicare and Medicaid Services (CMS) deemed status as accrediting organizations for suppliers of Durable Medical Equipment, Orthotics, Prosthetics, and Supplies (DMEPOS). Therefore, every facility that serves or bills Medicare patients must be accredited. Because CMS is implementing new standards for manufacturers and suppliers of DMEPOS, mandatory ABC and BOC facility accreditation will reflect these changes in upcoming months. To read more about the CMS Quality Standards, visit www.oandpcare.org/MLN

Governmental Agency Requirements

The Occupational Safety and Health Administration (OSHA), a branch of the U.S. Department of Labor, provides the most comprehensive listing of safety regulations. OSHA provides guidance and requirements for proper ventilation, noise level, sanitation, illumination, and fire safety. Exposure limits, chemical properties, health hazards, emergency medical procedures, exposure sources and control methods, storage, spills, leaks, special requirements, respiratory protection, and personal protective equipment when using chemicals, hazardous materials, and radiation are also provided. The General Duty Clause requires an employer to "furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees" and to "comply with occupational safety and health standards." Because individual facility requirements differ, general recommendations are provided below. A more specific and extensive listing can be obtained at www.osha.gov

The Joint Commission on Accreditation of Healthcare Organizations (JCAHO) evaluates and accredits more than 15,000 healthcare organizations and programs in the United States. An independent, not-for-profit organization, JCAHO is the nation's predominant standards-setting and accrediting body in healthcare. Joint Commission Resources (JCR), an affiliate of JCAHO, provides independent and confidential services, including consultation to healthcare organizations and education through programs, publications, and multimedia products. The JCAHO website ( www.jcaho.org ) and the JCR website, ( www.jcrinc.com ) provide comprehensive guides to help individuals learn more about the safety and quality of JCAHO-accredited healthcare organizations and programs.

Other Safety Considerations

Accessibility

The Americans with Disabilities Act (ADA) and the Architectural Barriers Act of 1968 (ABA) offer useful measurements for accessibility compliance that can be found at www.access-board.gov/ada-aba/final.htm

Air Quality Management

Poorly ventilated rooms have been associated with opportunistic infections such as aspergillosis, pneumonia, and tuberculosis. Chemical exposures and environmental pollutants are also a concern. Ventilation requirements for patient protection differ from the safety considerations for reducing employee exposure to airborne fumes or particles. The appropriate controls are designed with these differences in mind, as well as preventing exposure to common airborne fungal particles generated during construction or renovation. Design criteria for healthcare facilities are published by the American Institute of Architects (AIA).

OSHA recommends local exhaust ventilation "be designed to prevent dispersion into the air of dusts, fumes, mists, vapors, and gases in concentrations causing harmful exposure. Such exhaust systems shall be so designed that dusts, fumes, mists, vapor, or gases are not drawn through the work area of employees. Hoods connected to exhaust systems shall be used, and such hoods shall be designed, located, and placed so that the dust or dirt particles shall fall or be projected into the hoods in the direction of the airflow. No wheels, discs, straps, or belts shall be operated in such manner and in such direction as to cause the dust and dirt particles to be thrown into the operator's breathing zone. Exhaust systems for grinding, polishing, and buffing operations should be designed in accordance with American Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems."

Performing an Infection Control Risk Assessment (ICRA) is also a good idea. The ICRA elements required for consideration are located in Chapter 1.5 of the 2006 AIA Guidelines and are divided into three areas: processes for design, construction, and mitigation. An "ICRA is a multidisciplinary, organizational, documented process that focuses on reduction of risk from infection and acts through phases of facility planning, design, construction, renovation, facility maintenance." ICRA considers several factors, including the facility's patient population, programs, impact of disrupting essential services to patients and employees, patient placement or relocation, ventilation needs, exhaust systems for hazardous agents, and limiting waterborne opportunistic pathogens. Numerous resources are available to assist organizations with development and implementation of an ICRA, including AIA workshops or an ICRA Matrix, a published assessment. The construction matrix tool includes a sample permit that follows the format of the matrix, assessing patient-risk categories and environmental-risk groups to determine appropriate class or level of precautions. Both the AIA and JCAHO require documentation of the ICRA.

Sherry Metzger, MS, is a freelance writer with degrees in anatomy and neurobiology. She is based in Westminster, Colorado, and can be reached at sherry@opedge.com