By Safety Management Group
In today’s ever-more-competitive and cost-conscious healthcare environment, hospitals and other healthcare facilities don’t have the luxury of shutting their doors when there is a need for construction or renovation.
During a hospital’s normal operations, a long list of Life Safety Measures protects the safety of patients, visitors, and those who work in the hospital. They include everything from exit signs and clear pathways to egress points, to fire protection systems and smoke barriers, to evacuation plans.
When construction, renovation, or extensive maintenance brings additional complexity to operations, a new level of safety activities must be added. Interim Life Safety Measures (ILSM) are incorporated to address issues created by the work activity. ILSM have been identified by The Joint Commission and the National Fire Protection Association to compensate for hazards caused by Life Safety Code deficiencies or construction activity.
An effective ILSM program provides the necessary protection with zero disruptions to patient care and hospital operations. In our experience, the most practical programs involve six steps. In this article, we’ll examine each of those six steps and how they may impact the life safety of your patients, staff, and visitors. While these elements apply to many types of healthcare facilities, we’ll use the term “hospitals” for simplicity.
1. Pre-construction Risk Assessment
Well before any work begins, a Pre-Construction Risk Assessment (PCRA) will help you identify the overall risks the project will create for patients, staff, and contractors. A thorough PCRA focuses on both the systems within the hospital and how construction-related activity may disturb patient safety. It also calls attention to areas in which an ILSM assessment should be performed.
The PCRA should be developed by representatives from the hospital safety staff, the contractor(s) or maintenance team, and the hospital’s project manager based upon walk-throughs of the project area and any adjacent areas that may be impacted. It should concentrate on questions such as these:
– Will noise generated by the project impact departments or units? If so, those departments should be notified, and wherever practical, measures should be taken to reduce noise to acceptable levels.
– Will vibration created by the work affect departments or units? Here again, departments should be notified, and steps taken to mitigate vibration.
– Have emergency procedures for accidental events that could impact life safety or patient care been established and posted? Those procedures should include emergency contact information, locations of main valves, switches, and controls, as well as a plan for any unexpected outages.
– Will any system that requires an ILSM assessment be taken out of service (even briefly) during the project? That includes systems for fire alarms, fire suppression, and electrical service powering any life safety locations and equipment, as well as any system whose disruption creases a life safety code deficiency. Note that fire alarms and fire suppression outages also require utility shutdown notifications.
– Will any of the systems that require utility shutdown notifications be out of service at any time during the project? This list could include:
– Domestic Water
– Medical Gas
– Sewage
– HVAC
– Elevators
– Pneumatic Tube System
– Building Management System
– Deionized Water
– Card Reader Access Controls
– Security Cameras
– Information Services Cables/Wi-Fi
– Will the project require any abatement of asbestos or other hazardous materials?
– Will the contractors use any hazardous chemicals? Fumes and odors must be controlled, or alternate products should be specified.
– Is the work classified as a B, C, D or E project type? If so, an Infection Control Risk Assessment must be performed.
2. Interim Life Safety Measures assessments
Next, ILSM assessments must be performed on any system or element that could create a life safety code deficiency. Among the questions that should be asked as part of this process are: – Will any egress pathways or exits be altered or obstructed?
– Will access to emergency services and for emergency responders be impaired, restricted, or rerouted?
– Will any fire detection or alarm systems be impaired?
– Will any part of the fire suppression or sprinkler system be impaired?
– Will any smoke/firewalls, doors, or assemblies be compromised?
– Will the fire safety of personnel in adjacent areas be affected?
– Will it be necessary to install temporary construction partitions?
– Will the project result in the accumulation of debris and/or materials and increase the combustible load in the work area?
– Will the project activity include significant ignition sources (e.g. cutting, welding, soldering, or other activities involving an open flame)?
– Will the project activity present any other safety-related hazards?
Armed with the answers to these questions, the team can develop plans to address life safety code deficiencies. It is critical that all participants involved in the assessments, including any affected hospital departments, review these plans and sign off prior to the beginning of the work.
3. Implementing the ILSM plans
Once the assessments and plans are complete, load the information into an ILSM database to allow for more efficient management. Copies of the plans should be shared with all contractor supervisory personnel and the appropriate hospital managers. They should also be posted in highly visible and readily accessible locations on the site, so that contractor staff can refer to them as needed during the course of the project. It may also be appropriate to make copies available to local first responders.
It’s also important to note than an ILSM assessment is a living document and one that will need to be continuously updated as the project progresses. As the plan is updated, revisions should be posted as necessary and circulated to all parties, with a record of when they were received by each.
4. Contractor and Staff Training
An important aspect of ILSM programs is project-specific training for contractors and maintenance personnel. The need to develop an understanding of the systems that are in place to protect patients and how they work they will perform could compromise those systems. It’s particularly important that they grasp the seriousness of the ILSM plan.
Hospital staff members also need to receive safety training. They must understand any ways in which their familiar life safety systems may have been (or will be) altered, based upon the specific details within the PCRA.
In situations where ILSM plans are in place, it’s important to ensure that the staff is thoroughly familiar with basic emergency procedures. Specifically, they need to understand the RACE (Rescue, Activate, Contain, Extinguish) concept for dealing with emergencies, and the PASS (Pull, Aim, Squeeze, Sweep) process for using fire extinguishers correctly. Depending upon the nature of the project and the specific details of the ILSM plans, they may need instruction in other emergency procedures.
Even if staff members or contractor personnel have been through similar construction projects that involved learning these procedures, it is critically important to repeat training. Human memories are imperfect, and repeated training is the best way to ensure that the correct actions will be taken instinctively in a crisis situation.
Generally speaking, training should not be a one-time event that occurs only at the beginning of a project. As you track and trend the information from your walk-throughs, use that data to determine ways to focus your training efforts. By sharing information with the contractors, maintenance personnel, and hospital staff, you’ll foster continuous learning and enhance safe practices.
5. Verifying compliance
Once the project is underway, the focus shifts to monitoring compliance with the stated ILSM measures. An ILSM Compliance Checklist is a practical, effective tool that simplifies monitoring and documentation of ILSM performance.
At minimum, ILSM compliance should be observed and documented through a daily walk-through. (Large or complex projects may even benefit from more frequent walk-throughs.) More frequent walk-throughs in the early stages of the project are particularly important, because they quickly establish expectations for compliance.
Your ILSM Compliance Checklist should address all pertinent items. The following points are among those that will be probably be included:
– Are exits free and unobstructed? Construction-area exits should be inspected daily, with the contractor maintaining an egress log.
– Is access to emergency services and entrance and exit discharges unobstructed? Encourage contractors to avoid propping or wedging open doors (a very common issue in this setting).
– Is there clear exterior access for police, fire, and other emergency responders?
– Is the fire alarm system in working order? Where deficiencies are noted, ensure that a fire watch is provided. Provide additional fire extinguishers and ensure that personnel are trained in fire extinguisher use for healthcare facilities.
– Are fire suppression systems functioning properly? If not, ensure that alternate means of responding to fires are in place and assign properly trained firewatch personnel as needed.
– Have temporary partitions been installed safely and correctly so that they provide the desired protection (access, noise, dust, etc.)?
– Ensure that personnel working in your facility comply with the requirements regarding use of tobacco products.
– Monitor housekeeping conditions and ensure that construction debris is removed promptly. Equipment, tools, and materials should be stored inside the construction zone and not in the hallway or in public areas.
– Are all temporary exit signs and project signs maintained in a good condition?
– Make sure that evacuation routes, access control, and required emergency information are updated as conditions change.
– Monitor hot work operations and ensure that the facility’s hot work procedure is implemented, with properly trained firewatch personnel on hand.
– Inspect fire extinguishers and ensure that access to them is not obstructed. Contractors should clearly identify extinguisher locations.
6. Closeout Procedures
As the project nears the end, it’s time to prepare to turn the newly constructed or renovated space over to the hospital department or other user groups. Before that occurs, you’ll need to verify that all life safety deficiencies have been corrected.
A closeout checklist is a particularly helpful tool for documenting that the project has been completed and is ready to be turned over. Among the most common issues that such a checklist can address are:
– Are all exits to be free and unobstructed?
– Are all exit signs are operational and installed as designed, and has the contractor removed all temporary signs?
– Ensure that all access to emergency services has been restored.
– Verify and document that maintenance acceptance testing for smoke/sprinkler systems has occurred when the project involved modifying or installing new systems.
– Ensure that the area is equipped with the appropriate number of fire extinguishers.
– Have contractors removed all construction materials and equipment?
– Have all emergency evacuations signs been installed and updated?
– Verify that all ceiling tiles have been installed.
– Ensure that spaces are clean and ready for occupancy.
– Remove any other safety related hazards or conditions prior to accepting the area.
All parties involved in the pre-project assessment should participate in the walk-through for the closeout checklist, and all questions must be satisfactorily answered and issues resolved before the space may be occupied.
One final thought
Be sure that your ISLM program incorporates comprehensive training for everyone on the site. The success of your program depends on how well you communicate its importance to the individuals whose work impacts the life safety of the patients, staff, and visitors
