As we monitor TJC survey reports, we continue to see surveyors cite environmental safety risks in behavioral health settings including psychiatric hospitals, psychiatric units in acute care hospitals and sometimes in BH residential settings. Examples of issues cited include loopable fixtures in bedrooms and bathrooms, use of plastic trash can liners, non-breakaway rods in closets and showers and other ligature risks in the environment. When these risks are identified, the surveyor typically asks the organization if they have conducted a risk assessment. All too often, the organization is unable to demonstrate that a formal risk assessment was conducted and documented. Thus, the findings stick and must be addressed via corrective actions after the survey.

In order to address this issue proactively, we highly recommend that you formally evaluate the environmental safety risks in your environment. We recently updated the tool we compiled a few years ago Environmental Risk Assessment for Behavioral Health Settings. It covers bedrooms, bathrooms and other areas and identifies best practice safety features against which your environment should be evaluated. Many of our clients have used the tool to conduct their environmental risk assessments and develop action plans for reducing the risks they identify.

Keep in mind that when a specific safety risk is identified (e.g. exposed under-sink plumbing fixtures as a potential hanging risk), that issue needs to be analyzed in order to make a decision about whether to accept the risk, mitigate the risk, or eliminate the risk. This analysis needs to be robust and needs to be documented. We recommend the following strategies:

• Be sure to bring data to the table. Review your incident database, client satisfaction data and complaints. Summarize the relevant data and present it to the team for their review and analysis.
• Conduct a literature review to identify current professional thinking and best practices related to the topic.
• Research the regulations. Clarify the TJC, CMS and state licensing requirements related to the issue.
• Once you have reached a decision, clearly state your “organizational position” and include a full rationale for how you decided upon this position.
• Document your conclusions in a formal report.
• Have the report reviewed by the appropriate committees and attach it to their minutes. Once these bodies have reviewed the report and approved the organizational position, document this approval in their minutes.

In 2013, TJC published a very useful article on the 7 Step Approach to Risk Assessment in March 2013 Perspectives, page 5. It describes a model for analyzing identified safety issues and making decisions about how to address safety risks. We have found it to be a very useful tool.

Finally, be aware of the excellent resource Design Guide for the Built Environment of Behavioral Health Facilities. It was updated in May 2015 and is available on the Facilities Guidelines Institute website. The Design Guide identifies specific resources for safety products in the BH setting and can save valuable time when researching best products.