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DNV GL © 2014 SAFER, SMARTER, GREENER DNV GL © 2014 DNV-GL Medical Equipment and ISO 9001 1 Brennan Scott BA, CHOP DNV-GL Sector Lead

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Page 1: DNV-GL Medical Equipment and ISO 9001...If the hospital is using an AEM program, the equipment managed through that program must be readily separately identifiable as subject to AEM

DNV GL © 2014 SAFER, SMARTER, GREENER DNV GL © 2014

DNV-GL Medical Equipment and ISO 9001

1

Brennan Scott BA, CHOP

DNV-GL Sector Lead

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DNV GL © 2014

Course Learning Objectives

This session will enable the attendee to:

1. Describe the DNV GL Physical Environment survey process,

including unique methods specific to medical equipment

management.

2. Discuss the NIAHO® Requirements that apply to Medical

Equipment

3. Outline how the integration of ISO 9001 concepts affect the

development of a hospital’s Medical Equipment Management System procedures.

4. Explain the lineage from a CoP to a medical equipment finding.

5. Discuss current issues and common findings related to the

NIAHO® Medical Equipment Management accreditation survey.

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DNV GL © 2014

Highly skilled people across the world

300+ offices

100 countries

18,500 employees

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DNV GL © 2014

DNV GL Main Industries

4

Food & Beverage Automotive Transport

IT & Telecom Health Care Finance

Energy

Maritime

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DNV GL © 2014

DNV-GL Services

Acute Care Hospital Accreditation

Critical Access Hospital Accreditation

Managing Infection Risks Certification (MIR)

Hip and Knee Certification

Ventricular Assisted Device (VAD)

Certified Healthcare Operations Professional

Certification (CHOP)

Primary & Comprehensive Stroke

Numerous ISO & Risk Management Education courses

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DNV GL © 2014

Healthcare

Our services:

Hospital Accreditation to DNV

GL standards

Managing Infection Risk

Disease-specific certifications

Management systems

certification

Training

2,400 HEALTHCARE ORGANZATIONS

ACCREDITED OR CERTIFIED

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DNV GL © 2014

More value, lower $

Focus on sequence and interactions of processes throughout the hospital

ISO 9001 Gradual Introduction @ no additional staff

Demeanor of the survey team

No survey findings “tipping” point

Constant readiness

Collaboration, sharing of ideas

Feature of NIAHO Benefit to Hospital

Fear becomes confidence

Clear, traceable pathway to improve

Stable standards, infrequent change Sustainable system

Annual Surveys

Key Features

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DNV GL © 2014

About ISO 9001

Who Developed ISO 9001?

– ISO 9001 was developed through the International Organization for

Standardization

– This organization began in 1946 and published the first revision of the ISO

9001 standard in 1987

– The current revision of ISO 9001 is the revision four dated 2015

– The 2015 9001 standard is a Quality Management System that requires the

organization to perform risk based thinking

When did ISO 9001 become recognized by healthcare?

– Healthcare has started to embrace ISO 9001 within the last several years,

(primarily since 2008)

– More recently with DNV-GL receiving deeming authority from the Centers for

Medicare and Medicaid Services, (CMS) to accredit hospitals in 2008, ISO 9001

is rapidly gaining recognition in healthcare

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DNV GL © 2014

DNVGL Accreditation Progression

1st visit:

– Gain Accreditation to NIAHO® - meet the requirements of CMS

– ISO introduction & education; compliance or certification within 3 years

2nd visit: 1 year after accreditation

– Continue Accreditation by undergoing a survey to NIAHO®

– Survey for progress in implementing ISO 9001

3rd visit: 2 years after accreditation

– Continue Accreditation by undergoing survey to NIAHO®

– Continue to work toward ISO 9001 Implementation (ISO dress rehearsal)

4th visit: 3 years after accreditation

– NIAHO® survey and last year to achieve ISO 9001 compliance/certification

– If in compliance with ISO 9001 – a statement included in Certificate of

Accreditation

– May choose to demonstrate compliance by obtaining a separate ISO 9001

Certificate

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DNV GL © 2014

ISO System Structure

10

Operational-Business

Practices-Regulatory ISO 9001 Systems

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DNV GL © 2014

NIAHO® Standard Requirement Chapters

Quality Management System

Governing Body

Chief Executive Officer

Medical Staff

Nursing Services

Staffing Management

Rehabilitation Services

Obstetric Services

Emergency Department

Outpatient Services

Dietary Services

Patient Rights

Infection Control

Medical Records Service

Medication Management

Surgical Services

Anesthesia Services

Laboratory Services

Respiratory Care Services

Medical Imaging

Nuclear Medicine Services

Discharge Planning

Utilization Review

Physical Environment

Organ, Eye and Tissue Procurement

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DNV GL © 2014

Time Frame for ISO 9001 Compliance/Certification

QM.2 ISO 9001 QUALITY MANAGEMENT SYSTEM

SR.1 Compliance with the ISO 9001 standard must occur within three (3)

years after the initial deemed NIAHO® accreditation. The Organization shall

either demonstrate compliance with the ISO 9001 Quality Management System

principles through a NIAHO® accreditation survey or maintain Certification

through an Accredited Registrar. Only certificates covered by an accreditation

under an IAF MLA (International Accreditation Forum Multilateral Recognition

Agreement) signatory shall be eligible. The organization shall maintain ISO 9001

compliance or formal Certification in order remain eligible for NIAHO®

Accreditation.

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DNV GL © 2014

NIAHO® Physical Environment (PE) Management Systems

PE.1 Facility

PE.2 Life Safety Management System

PE.3 Safety Management System

PE.4 Security Management System

PE.5 Hazardous Material (Hazmat) Management

System

PE.6 Emergency Management System

PE.7 Medical Equipment Management System

PE.8 Utility Management System

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DNV GL © 2014

Physical Environment - PE.7 Medical Equipment

PE.7 MEDICAL EQUIPMENT MANAGEMENT SYSTEM

SR.1 The organization shall establish a Medical Equipment Management System that provides

processes for the acquisition, safe use, and the appropriate selection of equipment.

What is included in an effective Medical Equipment Management Plan/System?

SR.2 The Medical Equipment Management System shall address issues related to the

organization’s initial service inspection, the orientation, and the demonstration of use.

This includes rented equipment, loaned equipment and demonstration equipment.

SR.3 The Medical Equipment Management System shall address criteria for the selection of

equipment.

SR.4 The Medical Equipment Management System shall address incidents related to serious

injury or illness or death (See SMDA 1990).

SR.5 The Medical Equipment Management System shall have a process for reporting and

investigating equipment management problems, failures, and user errors.

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Physical Environment - PE.7 Medical Equipment

When reviewing a report from the Bio-Medical Department, the report must be accurate and

contain the appropriate information.

It is common for these reports to show preventative maintenance completion rates above the

hospitals goal, however upon a thorough review, UTL, UFM, CIU has been entered as

completed or not accounted for in the total number.

These reports should indicate a corrective action plan when targets or goals are missed.

These reports should be reported to the Quality Management Oversight group to ensure that

leadership is aware of the current conditions of the hospital medical equipment.

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Physical Environment – PE.7 Medical Equipment

SR.6 The Medical Equipment Management System shall address a process for determining

timing and complexity of medical equipment maintenance.

All Alternative Equipment Maintenance must meet the steps described in the Interpretive

Guidelines within PE.7 of the NIAHO standards.

Imaging/radiologic equipment, whether used for diagnostic or therapeutic purposes, is

governed by 42 CFR 482.26(b)(2) and must be maintained per manufacturer’s recommendations.

• SR.7 The Medical Equipment Management System shall address the process of receiving and

responding to recalls and alerts.

Records of calibration for measuring equipment must be retained and responded to when found

to be “Out of Tolerance.” This also includes hospital operations equipment.

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DNV GL © 2014

NIAHO® PE.7 MEDICAL EQUIPMENT MANAGEMENT SYSTEM

Alternate Equipment Management (AEM) Program

A hospital may, under certain conditions, use equipment maintenance activities

and frequencies that differ from those recommended by the manufacturer.

Hospitals that choose to employ alternate maintenance activities and/or schedules

must develop, implement, and maintain a documented AEM program to minimize

risks to patients and others in the hospital associated with the use of facility or

medical equipment. The AEM program must be based on generally accepted

standards of practice for facility or medical equipment maintenance.

An example of guidelines for a medical equipment maintenance program may be

found in the American National Standards Institute/ Association for the

Advancement of Medical Instrumentation document: ANSI/AAMI EQ 56:1999/ (R)

2013, Recommended Practice for a Medical Equipment Management Program.

Likewise, an example of guidelines for physical plant equipment may be found in

the American Society for Healthcare Engineering (ASHE) 2009 document:

Maintenance Management for Health Care Facilities. There may be similar

documents issued by other nationally recognized organizations which hospitals

might choose to reference.

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DNV GL © 2014

NIAHO® PE.7 MEDICAL EQUIPMENT MANAGEMENT SYSTEM

Decision to Place Equipment in an AEM Program

The determination of whether it is safe to perform facility or medical equipment

maintenance without following the equipment manufacturer recommendations

must be made by qualified personnel, regardless of whether they are hospital

employees or contractors.

In the case of medical equipment, a clinical or biomedical technician or engineer

would be considered qualified. Highly specialized or complex equipment may

require specialized knowledge or training in order for personnel to be considered

qualified to make a decision to place such equipment in an AEM program.

A hospital is expected to identify any equipment in its AEM program which is

“critical equipment,” i.e., biomedical or physical plant equipment for which there is a risk of serious injury or death to a patient or staff person should the

equipment fail. Surveyors must focus their review of a hospital’s AEM program on critical equipment in that program and the hospital’s documentation of the factors and evidence it considered in developing an AEM strategy for that equipment.

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NIAHO® PE.7 MEDICAL EQUIPMENT MANAGEMENT SYSTEM

Equipment not Eligible for Placement in the AEM Program:

Imaging/radiologic equipment, whether used for diagnostic or therapeutic

purposes, is governed by 42 CFR 482.26(b)(2) and must be maintained per

manufacturer’s recommendations.

The equipment is a medical laser device. It should be noted that for medical

lasers the U.S. Food and Drug Administration requires manufacturers to provide a

schedule of maintenance and adequate instructions for service adjustments and

service procedures to purchasers and, at cost, to any other parties requesting

them.

New equipment for which sufficient maintenance history, either based on the

hospital’s own or its contractor’s records, or available publicly from nationally recognized sources, is not available to support a risk-based determination must

not be immediately included in the AEM program. New equipment must be

maintained in accordance with manufacturer recommendations until a sufficient

amount of maintenance history has been acquired to determine whether the

alteration of maintenance activities or frequencies would be safe.

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DNV GL © 2014

NIAHO® PE.7 MEDICAL EQUIPMENT MANAGEMENT SYSTEM

AEM Program Documentation:

The pertinent types and level of risks to patient or staff health and safety;

Alternate maintenance activities, and the maintenance strategy and any other

rationale used to determine those activities; the differences from the

manufacturer’s recommended maintenance activities are made explicit, unless the hospital is unable to obtain the manufacturer’s maintenance recommendations, due to the age of the equipment or the manufacturer’s restricting the availability of its recommendations;

Alternate maintenance frequencies to be used, if any, and the maintenance

strategy and any other rationale used to determine those frequencies.

The date when AEM program maintenance activities were performed and, if

applicable, further actions required/taken; and

Documentation of any equipment failures (not including failures due to operator

error), including whether there was resulting harm to an individual.)

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DNV GL © 2014

NIAHO® PE.7 MEDICAL EQUIPMENT MANAGEMENT SYSTEM

Equipment Inventory:

All hospital facility and medical equipment, regardless of whether it is leased or

owned, and regardless of whether it is maintained according to manufacturer

recommendations or is in an AEM program, is expected to be listed in an

inventory which includes a record of maintenance activities.

If the hospital is using an AEM program, the equipment managed through that

program must be readily separately identifiable as subject to AEM. Critical

equipment, whether in an AEM program or not, must also be readily identified as

such.

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DNV GL © 2014

NIAHO® PE.7 MEDICAL EQUIPMENT MANAGEMENT SYSTEM

To facilitate effective management, a well-designed equipment inventory contains

the following information for all equipment included. However, hospitals have the

flexibility to demonstrate how alternative means they use are effective in enabling

them to manage their equipment:

A unique identification number;

The equipment manufacturer;

The equipment model number;

The equipment serial number;

A description of the equipment;

The location of the equipment (for equipment generally kept in a fixed location);

The identity of the department considered to “own” the equipment;

Identification of the service provider;

The acceptance date; and

Any additional information the hospital believes may be useful for proper

management of the equipment.

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DNV GL © 2014

NIAHO® MI.3 MEDICAL IMAGING EQUIPMENT

SR.2 Documentation of preventative maintenance and repairs of

radiology equipment shall be maintained (See PE.7).

Interpretive Guidelines:

The hospital must have policies and procedures in place to ensure that periodic

inspections of radiology equipment are conducted. When these periodic

inspections have identified that equipment is not operating or malfunctioning, this

equipment is removed from service and repaired and verified prior to being put

into operation for patient care. The hospital must maintain repair documentation

and records for periodic maintenance.

Either the hospital staff or a qualified contract entity must ensure that equipment

is inspected in accordance with manufacturer’s instructions, Federal and State laws, regulations, and guidelines, and hospital policy.

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DNV GL © 2014

NIAHO® NM.3 NUCLEAR MEDICINE EQUIPMENT & SUPPLIES

SR.1 Equipment and supplies must be appropriate for the types of

nuclear medicine services offered and must be maintained for safe and

efficient performance (See PE.7).

SR.2 The equipment must be maintained in safe operating condition and

inspected, tested, and calibrated at least annually by qualified personnel

(See PE.7).

SR.3 Documentation of equipment testing and preventative maintenance

shall be maintained (See PE.7).

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DNV GL © 2014

NIAHO® NM.3 NUCLEAR MEDICINE EQUIPMENT & SUPPLIES

Interpretive Guidelines:

The hospital must develop and implement a preventive maintenance process to

ensure that nuclear medicine equipment is maintained in safe operating condition

to ensure accurate results and patient, staff, and public safety.

Nuclear medicine equipment must be inspected, tested and calibrated at least

annually by qualified personnel in accordance with Federal and State laws,

regulations and guidelines and appropriate documentation (records) maintained.

Supplies must be appropriate for the types of nuclear medicine services offered

and must be maintained for the safety for the patients, staff, and public.

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DNV GL © 2014

Patient Care Vicinity

What is the official definition of Patient Care Vicinity?

NFPA 99 2012 3.3.139 Patient Care Vicinity. A space, within a location

intended for the examination and treatment of patients, extending 1.8 m (6 ft)

beyond the normal location of the bed, chair, table, treadmill, or other device that

supports the patient during examination and treatment and extending vertically to

(7 ft 6 in.) above the floor.

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Electrical Equipment

Relocatable Power Taps (RPT’s) are now allowed in the patient care vicinity with the adoption of the NFPA 99 2012 edition.

RPT must be Permanently attached to equipment assembly

The sum of the ampacity ≤ 75% ampacity of the flexible cord connecting the

outlets

The means of preventing overloading ≤ 75%.

The electrical and mechanical integrity of assembly is regularly verified and

documented

• Extension cords are considered temporary wiring and RPT’s used in the patient vicinity must be of hospital grade.

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Equipment in Corridors

In the 2000 standard, there was very little allowance for items to be stored in the

corridors, mainly equipment and carts that were in use.

In the 2012 standard, there are a few allowances. In addition to equipment and

carts in use; crash carts; and isolation carts for isolation patients, wheeled patient

lift and transport equipment are permitted to be stored in corridors as long as they

don’t reduce the corridor width below 5 ft., and the fire plan and training

address relocation of the equipment in an emergency

(NFPA 101 2012 19.2.3.4(4)).

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ISO 9001 Resource Management Concepts

7.1.6 Organizational knowledge

7.2 Competence

7.3 Awareness

Personnel performing work affecting conformity to product requirements shall be

competent on the basis of appropriate education, training, skills and experience.

The organization determines the necessary competence for personnel

performing work affecting conformity to product requirements, provides training or

take other actions to achieve the necessary competence, evaluates the

effectiveness of the actions taken, ensures that its personnel are aware of the

relevance and importance of their activities and how they contribute to the

achievement of the quality objectives, and maintains appropriate records of

education, training, skills and experience.

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Awareness

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ISO 9001 Infrastructure and work environment

7.1.3 Infrastructure

7.1.4 Environment for the operation of processes

The organization determines, provides and maintains the infrastructure needed to

achieve conformity to product requirements. Infrastructure includes, as applicable,

– a) buildings, workspace and associated utilities,

– b) process equipment (both hardware and software), and

– c) supporting services (such as transport, communication or information

systems).

The organization determines and manages the work environment needed to achieve

conformity to product requirements.

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ISO 9001 Control of monitoring and measuring equipment

7.1.5 Monitoring and measuring resources

Where necessary to ensure valid results, measuring equipment shall

– be calibrated or verified, or both, at specified intervals, or prior to use,

against measurement standards

– traceable to international or national measurement standards; where no

such standards exist, the basis used for calibration or verification shall be

recorded

– be adjusted or re-adjusted as necessary;

– have identification in order to determine its calibration status;

– be safeguarded from adjustments that would invalidate the measurement

result;

– be protected from damage and deterioration during handling,

maintenance and storage.

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ISO 9001 Control of monitoring and measuring equipment

7.1.5 Monitoring and measuring resources

The organization assesses and records the validity of the previous

measuring results when the equipment is found not to conform to

requirements. The organization takes appropriate action on the equipment

and any product affected

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7.1.5 Monitoring and measuring equipment

Record

Traceability

NIST National Institute of Standards & Technology

Calibration Lab

Hospital

God of Weights

A

B

C

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ISO 9001 Top Management Responsibilities: Communication

7.4 Communication

The organization ensures that responsibilities and authorities are defined

and communicated within the organization.

The organization ensures that appropriate communication processes are

established within the organization and that communication takes place

regarding the effectiveness of the quality management system

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Ineffective communication does not achieve quality objectives

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7.5 Documented Information

7.5.1 General

The Hospital’s QMS shall include:

a) documented information required by this International Standard;

One type of Documented information consists of “documents” which gives instruction/information that must be “maintained”

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7.5 Documented Information

7.5.1 General

– b) documented information determined by the Hospital as being necessary for

the effectiveness of the quality management system.

Example: Emergency Management Program

NOTE: The extent of documented information is dependent on:

– a) the size of Hospital and its type of activities, processes, products and

services;

– b) the complexity of processes and their interactions;

– c) the competence of persons.

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The extent of documented information is up to you!!

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7.5 Documented Information

7.5.3.2 For the control of documented information, the Hospital shall address

the following activities, as applicable:

– a) distribution, access, retrieval and use;

– b) storage and preservation, including preservation of legibility;

– c) control of changes (e.g. version control);

– d) retention and disposition.

Documented information of external origin determined by the hospital to be

necessary for the planning and operation of the QMS shall be identified as

appropriate, and controlled.

Examples include:

– NIAHO

– ISO

– NFPA

– OSHA

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What do we need to keep again?

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ISO 9001 Purchasing Process Concepts

8.4 Control of externally provided products and services

8.4.2 Type and extent of control of external provision

8.4.3 Information for external providers

The organization ensures that purchased product conforms to specified purchase

requirements. The type and extent of control applied to the supplier and the

purchased product is dependent upon the effect of the purchased product on

subsequent product realization or the final product.

Purchasing information describes the product to be purchased

– The organization establishes and implements the inspection or other activities

necessary for ensuring that purchased product meets specified purchase

requirements.

– Where the organization or its customer intends to perform verification at the

supplier's premises, the organization states the intended verification

arrangements and method of product release in the purchasing information.

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ISO 9001 Control of Nonconforming Product

8.7 Control of nonconforming process ,outputs,

products and services

The organization ensures that product which does not conform to product

requirements is identified and controlled to prevent its unintended use or delivery.

A documented procedure shall be established to define the controls and related

responsibilities and authorities for dealing with nonconforming product.

Where applicable, the organization deals with nonconforming product by one or

more of the following ways:

– by taking action to eliminate the detected nonconformity

– by taking action to preclude its original intended use or application.

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ISO 9001 Corrective Action Concepts

The organization takes action to eliminate the causes of

nonconformities in order to prevent recurrence.

Corrective actions shall be appropriate to the effects of the

nonconformities encountered.

A documented procedure is established to define requirements for

– reviewing nonconformities (including customer complaints),

– determining the causes of nonconformities,

– evaluating the need for action to ensure that nonconformities do not

recur,

– determining and implementing action needed,

– records of the results of action taken

– reviewing the effectiveness of the corrective action taken.

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CMS CoP Accreditation Oversight

482.41(c)(2)

Facilities, supplies, and equipment

must be maintained to ensure an

acceptable level of safety and quality.

(Please note that changes to the

interpretive guidelines per S&C:14-07

hospital were made but not in the

standard itself)

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Physical Environment and Infection Prevention

DNV GL PE surveyors are

trained in infection

prevention and how the physical

environment relates to it.

DNV GL surveyors work

as a team to identify unsafe

concerns surrounding

infection within the hospital

DNV GL PE surveyors will

attend the infection

prevention interview

DNV GL PE surveyors will

write IC findings

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Physical Environment – PE.7 Medical Equipment

PE.7 Medical Equipment Management System - Common Findings

Oversight of contracted services.

Validation of corrective actions or deficiencies for medical equipment.

Broken LOTO process.

Improper application or unapproved AEM.

Quality data not reported up to QMS.

Training for in-house medical equipment staff.

20 August 2018 © Det Norske Veritas AS. All rights reserved

Slide 47

Page 48: DNV-GL Medical Equipment and ISO 9001...If the hospital is using an AEM program, the equipment managed through that program must be readily separately identifiable as subject to AEM

DNV GL © 2014

Example Finding

During the Physical Environment document review and staff interview of the

Medical Equipment Management System, the surveyor observed the organization

has up to 10,000 pieces of medical equipment that are considered exempt from

receiving preventive maintenance as per OEM recommendations. It was also

noted, no evidence was presented that the organization has performed an AEM

for the equipment placed on the exempt status. The hospital’s current process to determine the AEM is a risk assessment developed in the late 1990’s and has not been reviewed since 2011. No evidence of the required documentation history of

the operation of the equipment’s function, per NIAHO standards for establishing an AEM, has been utilized. Not all of the organization’s medical equipment items are found in the organization’s medical equipment inventory.

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Page 49: DNV-GL Medical Equipment and ISO 9001...If the hospital is using an AEM program, the equipment managed through that program must be readily separately identifiable as subject to AEM

DNV GL © 2014

Example Finding

During the Physical Environment document review of the Medical Equipment

Management System, the surveyor observed the most recent medical equipment

monthly PM completion report presented to the organization, consisted of 100%

Life Support and 100% non-life support PM completion rates. However, this

process is not effective as the report did not include “unable to locate equipment,” “equipment in use,” “user error,” and equipment being repaired. This does not

give the organization a clear understanding of reporting and investigating

equipment management problems, failures, and user errors.

In addition, the surveyor was presented a document that reflected an 8% rate of

equipment that was determined to be “unable to locate.” Given this information,

the reports presented by the organization cannot reflect a PM completion rate of

100%.

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Page 50: DNV-GL Medical Equipment and ISO 9001...If the hospital is using an AEM program, the equipment managed through that program must be readily separately identifiable as subject to AEM

DNV GL © 2014

Example Finding

During the physical environment/life safety tour, the surveyor observed the

following piece of medical equipment not being maintained in a safe manner:

Baroness – 1st floor Central Wing West – in corridor outside double doors

Carescape Dynamap V123, reference #1234567-002, insulated connectors were

frayed and exposed due to strain.

During the Physical Environment document review, the surveyor observed no

evidence the organization has developed and implemented a documented process

for reporting and investigating test equipment when found to be out of tolerance.

Note: Further review of the Medical Equipment documented information found that

3 certificates of calibration were found to be “Out Of Tolerance” when returned to

the hospital from the vendor. The hospital was unaware as to the status of the test

equipment when returned.

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Page 51: DNV-GL Medical Equipment and ISO 9001...If the hospital is using an AEM program, the equipment managed through that program must be readily separately identifiable as subject to AEM

DNV GL © 2014

What is Our #1 Finding?

Failure to analyze data

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Page 52: DNV-GL Medical Equipment and ISO 9001...If the hospital is using an AEM program, the equipment managed through that program must be readily separately identifiable as subject to AEM

DNV GL © 2014

Questions

Page 53: DNV-GL Medical Equipment and ISO 9001...If the hospital is using an AEM program, the equipment managed through that program must be readily separately identifiable as subject to AEM

DNV GL © 2014

SAFER, SMARTER, GREENER

www.dnvgl.com

Brennan Scott BA, CHOP Physical Environment Sector Lead [email protected]

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www.dnvglhealthcare.com