Bronchoscopy procedures—sometimes you have to be negative!
A while back (I can’t really say how long ago, but certainly before COVID), there was a fair amount of survey focus on environmental considerations for performing bronchoscopy procedures. In general, the expectation was that routine bronchs would be done under negative pressure and if you had to do one on an urgent/emergent basis (i.e., at the bedside), there would be a process in place to ensure that the procedure could be done safely (e.g., appropriate PPE, any needed engineering controls, etc.).
Apparently, concerns and considerations in this regard have lingered enough to prompt our friends in Chicago to issue an FAQ on the subject. One of the interesting things about this one is the opening statement: “The performance of a bronchoscopy procedure in a negative pressure room is a requirement established by ASHRAE 170-2008 ventilation table 7.1. This space provision has been determined by NFPA Code and as such an organization cannot risk assess out of a code requirement.”
I find that choice of language to be very interesting and it makes me wonder if this “philosophy” will be applied to other risk assessments. I suppose not every risk assessment is going to hinge on how one complies with an NFPA (or other regulatory camp) code or standard, but it might not be a bad idea to perhaps dust off some of those risk assessments in the past (the ones relating to CMS categorical waivers might be a good starting point). The “classic” risk assessment process should clearly identify/outline any regulatory requirements, be they consensus code stuff or design criteria like the FGI Guidelines for Design & Construction of Health Care Facilities. As a somewhat related aside, I suspect that we’re likely to see the FGI “card” showing itself with greater frequency during surveys, particularly in the outpatient settings. At any rate, I suspect that risk assessments are going to be scrutinized a little more heavily over the next survey cycle, so it’s important to make sure your assessments are as “bullet-proof” as possible.
The FAQ also links to an additional resource, which outlines the considerations that should figure in the development of infection prevention and control policies. The approach is framed pretty much as a risk assessment process, which I think makes a great deal of sense, so if it’s been a while since you’ve evaluated the risk assessment process/structure in your organization, this should serve as reasonable guidance. As with all things subject to risk assessments, the critical decisions need to reflect not only what is best practice, but also what is sustainable practice in your organization. For good or otherwise, the components of our physical environment are not infinite, and it is of critical importance to ensure that the end product is not only driven by internal consensus, but also driven by what is possible right now. Use the process to identify future improvements? Absolutely! But don’t implement a process that cannot be supported in the now—it’s only going to make things more difficult from a compliance standpoint (and nobody wants to make things more difficult…I hope).
On a closing note, Spring 2024 is coming to a close and Summer is hot on its heels. Please be safe and rest up as you can—the race is on!
About the Author: Steve MacArthur is a safety consultant with The Chartis Group. 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 an advisory board member for Accreditation and Quality Compliance Center. Contact Steve at stevemacsafetyspace@gmail.com.