The sixth chapter of the Joint Commission
on Accreditation of Healthcare Organizations'
Standards for Behavioral Health Programs
is entitled, "Environment of Care (EC)."
The goal for this function is to provide
a safe, accessible, supportive, effective,
and efficient environment for clients, staff,
and visitors. This chapter includes the
following four areas of focus: 1) planning
for space, equipment, and resources that
are consistent with the mission, vision,
and values of the organization; 2) education
of staff regarding the role of the environment
in safe and therapeutic care; 3) development
of performance standards for the measurement
of staff and program performance in the
management of the EC; and 4) implementation
of the six management plans while simultaneously
measuring, assessing, and improving the
status of the EC.
Accreditation Requirement(s)
To conform to these standards, the organization
must show evidence of the following:
Reduction and control of environmental
hazards and risks
Proactive planning for the prevention
of accidents and injuries
Maintenance
of safe conditions for clients, staff,
and others coming into the program
Opioid treatment programs (OTPs) are
often located in facilities that are part
of a larger organization or are leased
from external sources that are not related
to the program.
If the program exists within a larger
parent organization, many of the EC
responsibilities may reside with that
organization. However, it is incumbent
on the program leaders to assure that
all of the elements of performance
of that organization's EC plans address
the OTP spaces, grounds, facilities,
and utilities.
The program leaders must assure
that there are separate and specific
plans for the OTP that address safety,
security, fire response, and emergency
situations.
If the facilities for the OTP are
leased, leaders need to communicate
their expectations for the proper
maintenance of the building and equipment
that are not under their control.
In leased situations, leaders must
also have access to the documentation
of required testing and maintenance
of building equipment, power, and
utility systems, and be able to have
the landlord produce the appropriate
documents for the survey.
All lease agreements should include
a commitment by the landlord to communicate
any building or equipment problems
that might adversely affect the safety
or health of clients, staff, and visitors
to the program.
The lease agreement should also
set guidelines for the timeliness
of response by the landlord to building
or equipment malfunction.
Staff education in the EC plans must
be included in new employee orientation,
which in almost all cases should occur
on the first day of employment.
All staff members—whether
clinical, administrative, or support—must
be able to speak to their roles in emergency
management situations.
The required annual review of the components
of the EC management plans can be conducted
in a variety of ways. Examples are holding
Safety Fairs where staff can review the
information in a fun and positive atmosphere;
putting the information on computerized
learning modules; conducting activities
such as scavenger hunts, games, and quizzes
focused on identifying; and learning key
information.
Drills that are required by a few of
the management plans can be approached
in a variety of methods. They do not all
have to be a physical reenactment of the
emergency situation.
"Tabletop" drills consist
of a written scenario evaluated by
a multidisciplinary team that write
down and/or discuss their responses
to the scenario.
When actual incidents occur, evaluate
the staff response and the effectiveness
of equipment and other equipment,
such as backup communication systems,
and hold a critique of the event with
a multidisciplinary group of staff.
Results of this critique can fulfill
the requirements of one drill.
Individual departments or areas
of a program may create a different
drill situation for different shifts.
It is important that all shifts and
days/weekend staff members are included
in drills.
In OTPs, staff should be confident
in their ability to recognize escalating
behavior that may lead to potential violence,
and have a strong knowledge base in the
skills and interventions that may assist
in de-escalation of these types of situations.
Staff should also know when the
situation requires outside intervention
and know how to call for that emergency
assistance quickly.
After all such incidents or potential
incidents, a critique should be held
in order to identify opportunities
for improvement and the prevention
of further incidents.
Documentation of ongoing education
and training content is important. Keep
an annual record of all programs offered
to staff related to EC issues, safety,
security, and infection control, and document
individual staff attendance for each.
Document how education and training
needs related to the EC are evaluated
and prioritized. A great method to do
this is to put EC topics on staff meeting
agendas and seek staff input on the areas
that they feel they need education or
"updates."
DON'T miss a scheduled drill or preventive
maintenance activity on equipment or systems.
This is a sure way of getting surveyor
attention focused on your EC monitoring
activities. Set up "tickler"
processes and backups to them. These systems
will assure that you do not become delinquent
in requirements like quarterly fire drills.
Be meticulous in your documentation
of inspection, testing, and maintenance
of all systems
References and Links
Occupational Safety and Health Administration www.osha.gov
