Mac’s Safety Space: Risk takes a holiday…not!
As one might imagine, I’ve had the chance to review a lot of different risk assessments over the course of the last little while (OK, maybe more than a little while…unless 20-plus years is a little while). One of the interesting dynamics I’ve encountered relates to the surveillance of construction areas, etc. and how those types of activities are administered. Unless it is a focused fire watch, surveillance activities are often confined to regular weekday hours with minimal, if any, surveillance on weekends, nights, and holidays. I suppose if you have a really robust process for oversight of what’s going on with projects (i.e., hot work, shutdowns, mucking about behind containment walls) you could make the case that the periods of greatest risk are when construction activities are occurring and “off hours” represent periods of lesser or no risk. But how does one quantify that (if it is, indeed, even quantifiable)?
For instance, the 2012 edition of the Life Safety Code® (NFPA 101-2012 – 18/19/20/22.214.171.124) requires: “The means of egress in any area undergoing construction, repair, or improvements shall be inspected daily for compliance with 126.96.36.199…” As a reminder, 188.8.131.52 states: “Means of egress shall be continuously maintained free of all obstructions or impediments to full instant use in the case of fire or other emergency.”
So, from a strict code compliance standpoint (and, really, when it comes to construction, renovation, etc., is there really any other compliance standpoint), the surveillance process needs to account for a means of ensuring that egress routes are “continuously maintained free of all obstructions or impediments to full instant use in the case of fire or other emergency” and that means is required to occur “daily.” Now, I will freely admit that the LSC does not specifically call out a definition of “daily” and even our friends from Chicago stop short of defining “daily” in their list of frequency interpretations, but I would be hard-pressed to endorse a frequency that was less than at least once in a 24-hour period. Much like those seemingly ubiquitous commercials alerting folks to the risks of shingles, risks don’t care about scheduling and staffing, or really much of anything. So it becomes a question(s) of:
- Does the level of risk really change on evenings, weekends, and holidays?
- Does the level of risk change when space is occupied or empty?
Certainly, the activities going on in the project space will have some bearing on the level of risk—projects tend to be riskier at the beginning than at the end (hopefully)—but having a clear sense of the ebb and flow of risk in any project should be a key component of the assessment process. As I am wont to say, when it comes to risk, you don’t get credit for doing the math in your head, so to speak. The process calls for the identification and mitigation of whatever risks are in the project mix. That way, you can be assured that your processes match up with the level of risks.
About the Author: Steve MacArthur is a safety consultant with Chartis Clinical Quality Solutions (formerly known as The Greeley Company) in Danvers, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Healthcare Safety Leader. Contact Steve at firstname.lastname@example.org.