“Nice to haves” are a much broader category and can include any practices that would support and enhance a healthcare security program, and make it more robust should a regulatory agency conduct a survey or review. Following such procedures are not compulsory nor even essential in many cases, but they can offer specific resolutions to issues that can have a positive impact on the overall readiness of the security posture of a campus or facility. Examples of “nice to haves” for healthcare security programs might include the National Fire Protection Agency’s (NFPA) Physical Security Guidelines for the Protection of Hospitals (NFPA 730) or the Illumination Engineering Society of North America’s Guideline for Lighting of Facilities (IESNA G-01-03).
Since no one solution exists that can guarantee a healthcare facility will meet all of its regulatory requirements, healthcare security practitioners should rely on a multidisciplinary approach to better prepare for such eventualities. Teamwork with ancillary and clinical departments in a facility will give the best protection from many problems and may offer points of view that might not be considered when seeing a particular issue through just the safety or security lens.
Minor Issues Can Become Big Problems
Healthcare security professionals should also be aware of a domino effect in which minor issues can quickly escalate into significant regulatory nightmares. Take the case of workplace violence. In the fall of 2011, OSHA released a directive on Enforcement Procedures for Investigating or Inspecting Incidents of Workplace Violence. The directive establishes uniform procedures for OSHA field staff for responding to incidents and complaints of workplace violence. It also establishes procedures for conducting inspections in industries considered vulnerable to workplace violence, such as healthcare and social service settings, and late-night retail establishments.
Due in part to this directive and other workplace violence prevention efforts from a variety of other healthcare regulatory agencies, this topic is one of the principal issues in the healthcare security industry today. A domino effect can occur since all of these regulatory agencies work together in one fashion or another, and failure to meet one agency’s requirements can result in a cascade effect, impacting other regulatory requirements and resulting in additional scrutiny of the organization. For example, an OSHA complaint is discovered by local or state regulators who begins an inquiry, which could trigger a Joint Commission or CMMS “for cause” survey.
Regulatory agencies are plentiful when it comes to healthcare facilities and their operations, and for good reason. Many of these agencies are typically thought of as only clinical, however, and solely focused on direct patient care issues. Hospital executives must understand that there are many pitfalls that can occur from a number of non-direct care sources. Knowledge of these agencies, their specific regulations, how they interact with one another and knowing how to mitigate potential incidents before they occur are the best defenses for avoiding costly mistakes while working in the healthcare security environment.
Related Articles:
- OSHA Issues Guidelines for Investigating Workplace Violence
- How to Comply With OSHA Standards
- New Security Design Guidelines for Healthcare Facilities
- Responding to Abusive Patient Behavior (Part I of III): 3 Pitfalls to Avoid When Training Staff
- Responding to Abusive Patient Behavior (Part II of III): 10 Ways to Defuse Incidents
- Responding to Abusive Patient Behavior (Part III of III): Reducing the Risks of Restraints
Bryan Warren is the president of the IAHSS and senior manager of Carolinas HealthCare System Corporate Security.
