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BOC Facility Principles UPDATED JULY 2020 BOCATC.ORG/FACILITY BOC FACILITY PRINCIPLES BOCATC.ORG 2 Table of Contents INTRODUCTION 3 PRELIMINARY QUESTIONS 4 16 ACCESSIBILITY 5 PRIVACY AND CONFIDENTIALITY 6 SAFETY AND INFECTION CONTROL 7 Bloodborne Pathogens 7 Personal Protective Equipment 8 Disposal of Potentially Hazardous/ Contaminated Materials 8 Hand Hygiene 9 Cleaning and Disinfecting 9 Open-Toe Shoes 10 Electrical Safety 10 Walking/Working Surfaces 11 Patient Safety and Supervision 11 Reporting Adverse Medical Events 12 Storage and Handling 12 Emergency Preparedness 13 Means of Egress and Exit Routes 13 DISPLAY OF LICENSES, CERTIFICATIONS AND PROFESSIONAL STANDARDS 14 APPENDIX I: REFERENCES 1 15 APPENDIX II: REGULATORY BODIES BY PRACTICE SETTING 16 APPENDIX III: OSHA 17 BOC FACILITY PRINCIPLES BOCATC.ORG 3 The operation of an athletics program is complex. A critical portion, of the program includes the administration of an athletic training facility. Some administrators (e.g., athletic directors, principals, superintendents) can be unaware of the many federal, state and local regulations and standards that govern athletic health care services. At the national level no fewer than eight federal agencies have regulations that can impact athletic health care services. Local, state and national non- governmental bodies have issued rules, regulations and position statements that must be considered when reviewing and establishing policies for athletic training facilities. Athletic health care services are not commonly delivered in a traditional health care setting, but in an athletic training facility. Most commonly, an athletic training facility serves as this point for health care. Local, state and federal entities issue regulations and standards – which often overlap – to ensure the quality of facilities where health care services are delivered. Failure to observe safety policies not only increases risk, but also increases exposure to liability suits alleging negligence. You may not be aware of all regulations and best practices that need to be followed. Individuals within your organization with specialized knowledge should review guidelines to ensure a thorough and complete assessment. Those who should be involved include but are not limited to: Athletic TrainersHuman relations department personnel Physician(s)Environmental services managers Legal department/ lawyers Custodial/sanitation supervisors Risk managersAthletic directors Building supervisors Principals/superintendents This document was created to provide the means for secondary and post-secondary educational institutions and organizations to self-assess their policies, procedures and facilities to ensure the safe, effective operation and compliance of athletic health care services. This manual was created by the Facility Standards Work Group in 2012. Its members developed the comprehensive document detailing what is essential to ensure a safe, properly equipped athletic training facility. The work group included: Jerry Diehl (Committee Chair) Randy Cohen, ATC, DPT David Edell, MEd, ATC, LAT, CSCS Doug Killgore, CMAAChad Kinart, MS, ATC David Klossner, PhD, ATC Brian Michelotti The following resources will help you gauge your athletic training facility’s compliance with applicable state, federal and oversight agency regulations, as well as best practices. Introduction BOC FACILITY PRINCIPLES BOCATC.ORG 4 Preliminary Questions RequirementYesNoComments, necessary action items and questions Is your program EXEMPT from state or federal OSHA regulations? Is your program EXEMPT from compliance with Title IX? Is your athletic training facility EXEMPT from federal ADA requirements? Do you have any other licensed health care practitioners besides the Athletic Trainer working in your organization? Do you have someone who is responsible for risk management for your organization? Are patient health records managed in paper or electronic format? High schools, colleges, universities, community colleges and the like are often exempt from some state and/or federal rules and regulations. Before beginning your assessment it is important to establish context for answering the questions in the document with your internal group of experts. BOC FACILITY PRINCIPLES BOCATC.ORG 5 Accessibility RequirementYesNoComments, necessary action items and questions Athletic training facility is accessible according to ADA regulations: • Doorways are adequately wide (32 inches for single doors and 48 inches for double doors) • Ramps and handrails are installed • Door assists are available The Americans with Disability Act (ADA) of 1990 required that buildings and rooms be accessible for those with disabilities. This can include disabled (temporary or permanent) patients, staff or visitors. Most buildings constructed in the past 20 years are ADA compliant or have been modified to become compliant. However, in areas where otherwise able-bodied persons work and play, this may not always be the case. As has been stated previously, some organizations are exempt from federal regulations such as the ADA. Why is this important for athletic training facilities? You may have athletes, staff or students who may need wider doorways, ramps, door assists or other accommodations because they are on crutches or using wheelchairs. Additionally, EMT or fire department personnel may need access to these areas, including elevators, to safely access and transport someone who is ill or injured. BOC FACILITY PRINCIPLES BOCATC.ORG 6 Privacy and Confidentiality RequirementYesNoComments, necessary action items and questions Employee education about storage and handling of confidential patient information is available (i.e., FERPA and HIPAA) Communication to employees about storage and handling of confidential patient records occurs Evidence of the above communication is documented All interactions between patients and Athletic Trainers or other health care providers are documented in the health records of each patient and securely maintained The facility has a locked file cabinet for all patient health files Electronic and paper copies of health information are protected and accessible/transferred only to authorized individuals. (i.e., FERPA, HIPAA and HiTECH) There is a place to have private conversations with their patients and/or their parents Communication occurs with employees about their responsibility for ensuring the confidentiality of health care information Evidence of the above communication is documented Rules and regulations govern the handling of sensitive information. This includes the documentation, storage and dissemination of health records, as well as the use of electronic health records (EHR/EMR). Examples of sensitive information include the following: pre-participation exams, health records, physician visits/follow-ups, diagnostic reports, phone calls and text messages. Why is this important for athletic training facilities? Not only must you document patient care, you must make sure that the information is properly stored and secured (including EHR/ EMR). Having confidential information that is not properly secured puts the facility at risk of potential lawsuits in the event data is stolen. BOC FACILITY PRINCIPLES BOCATC.ORG 7 Safety and Infection Control RequirementYesNoComments, necessary action items and questions Employee education about bloodborne pathogens is sufficient Communication to employees occurs on a regular basis Evidence of the above communication is documented Safety is all-encompassing. This includes examining the policies and procedures of the program for the safety of patients and employees, as well as the safe operation of the athletic training facility. Why is this important for athletic training facilities? Employee education on the potential job- related safety and health hazards protects the employee and patients. It is important to identify the set(s) of regulations with which your athletic health care program is required to be in compliance, such as OSHA or the local health department. Human relations staff members may be the best source to help answer these questions. Insurance, legal and risk management professionals can assist in identifying the regulations that apply to your program. BLOODBORNE PATHOGENS Employers are required to educate employees regarding safety and protection against accidental transmission of bloodborne pathogens. This education extends to those responsible for the daily maintenance and upkeep of the facility, such as housekeeping or custodial staff. The Center for Disease Control (CDC) provides information on infection control to prevent the spread of infections in health care settings. ATs should take into consideration laws, rules, regulations and/or guidance implemented due to local, state and/or federal declared emergencies (e.g. state health departments, CDC, World Health Organization (WHO), etc.) BOC FACILITY PRINCIPLES BOCATC.ORG 8 Safety and Control RequirementYesNoComments, necessary action items and questions Personal protective equipment is available for employees Employee education and information is sufficient and up to date with latest standards Communication to employees about the required use of personal protective equipment occurs Evidence of the above communication is documented RequirementYesNoComments, necessary action items and questions Employee education on disposal of bio-hazardous or sharps materials is sufficient and up to date with latest standards Communication to employees occurs Evidence of the above communication is documented Separate containers or receptacles for the disposal of biohazardous materials are available within the athletic training facility Secure containers for disposal of sharps is available within the athletic training facility PERSONAL PROTECTIVE EQUIPMENT In order to protect staff and the patient, employers must provide personal protective equipment and instruction on its use Employers are also responsible for assuring employee compliance with personal protective equipment laws. Examples of personal protective equipment include but are not limited to: • Personal protective equipment for eyes, face, head and extremities (e.g., gloves, masks) • Protective clothing • Respiratory devices • Protective shields and barriers DISPOSAL OF POTENTIALLY HAZARDOUS/ CONTAMINATED MATERIALS • Bio-hazardous Materials - Any solid or liquid waste that poses serious threat of transmitting infection to humans, including towels, gloves and bandages • Sharps Materials - Any device or object used to puncture or lacerate the skin BOC FACILITY PRINCIPLES BOCATC.ORG 9 Safety and Control RequirementYesNoComments, necessary action items and questions Adequate facilities for hand-washing or hand sanitation are available throughout the athletic training facility Employee education and information is sufficient and up to date with latest standards Communication to employees occurs Evidence of the above communication is documented RequirementYesNoComments, necessary action items and questions Appropriate and adequate supplies are available to properly handle patient care equipment and instruments/devices Appropriate and adequate supplies are available to properly clean and disinfect patient care equipment and instruments/ devices Appropriate and adequate supplies are available to clean and disinfect the healthcare environment appropriately Employee education about handling, cleaning and disinfecting patient care equipment and instruments/devices and the health care environment Communication to employees occurs Evidence of the above communication is documented HAND HYGIENE It goes without saying that the cleanliness of those working in the facility, as well as the facility itself, is important to ensure safe and effective treatment. Not all facilities may have access to sinks; however, a facility can improve sanitary conditions with the addition of hand sanitizing units. CLEANING AND DISINFECTING The CDC provides evidence based recommendations on the preferred methods for cleaning, disinfection and sterilization of patient care medical devices and for cleaning and disinfecting the health care environment.Next >