I hope my 2011 nPSG on MRI safety doesn’t cause any confusion with the Joint Commission’s new NPSG (National Patient Safety Goals). The fact is that this is distinct… it only uses the Joint Commission’s own wording to craft a patient safety goal specific to MRI in an effort to break through the paper-thin fallacy of ‘supporting MRI safety’ without providing (a) specific standards, (b) comparable scrutiny based on TJC published best-practices, (c) enforcement of requisite risk-management standards as they would apply to MRI, or (d) specific expert training on MRI safety issues for their on-site surveyor corps.
So, here is the justification my new nPSG, using the Joint Commission’s own words…
PPS (a Joint Commission publication) Feb, 2007 – “Safety in the MRI suite is both vitally important and unusually challenging to implement because of the invisibility of of the threats coupled with the increasingly common presence of objects that MRI can act upon with disastrous results.”
SEA #38, Preventing Accidents and Injuries in the MRI Suite, Feb, 2008 – “The Joint Commission offers the following recommendations and strategies to health care organizations for reducing MRI accidents and injuries:” [Ten explicit objectives follow]
EoC News (a Joint Commission publication) May, 2009 – “In January 2009, the Joint Commission issued Standard EC.02.02.01, Element of Performance (EP) 1, which lists Sentinel Event Alert among the sources of information to assist in proactively identifying safety and security risks associated with the environment of care.”
EC.02.01.01 – “The organization identifies safety and security risks associated with the environment of care. Note: Risks are identified from internal sources… …and from credible external sources such as Sentinel Event Alerts.”
EoC News (a Joint Commission publication) May, 2009 – “…[W]e do ask each organization to look at the literature — any credible external sources, such as Sentinel Event Alerts — and put into place those things that can help prevent a safety incident involving their patients.” — John Fishbeck, R. A., Associate Director, Department of Standards, The Joint Commission.
SEA #38, Preventing Accidents and Injuries in the MRI Suite, Feb, 2008 – “Implement systems to support safe MRI practice such as written protocols and checklists and periodically review, and assess compliance with your organization’s MRI policies, procedures and protocols.” — paraphrasing Dr. Emanuel Kanal, FACR, FISMRM
Admittedly, a good editor could take my own words and re-purpose them to say something that I would find antithetical, but that’s not what I’ve done here. While I suspect that voices within the Joint Commission might be quick to come up with qualifications / rationalizations as to the un-enforceability of MRI safety, I can’t imagine that they would actually disagree with words that they themselves have spoken, written or published on the subject.
What follows are the 2011 nPSG’s which follow, fairly directly, from the hazard description above:
- nPSG.11.01.01 – Accredited Health Care Organizations that provide MR services must perform a risk / hazard analysis for those services in accordance with EC.02.01.01.
- nPSG.11.01.02 – Provide access restrictions, and both clinical and physical screening, for all persons prior to being granted access to the controlled access areas of the MRI suite, in accordance with the ACR Guidance Document for Safe MR Practices: 2007 and the ACR 4-Zone model described therein.
- nPSG.11.01.03 – Appoint a dedicated MR safety officer with responsibility and authority for implementing and enforcing MR safety procedures.
- nPSG.11.01.04 – Provide and document MR safety training for all MR staff at least annually.
- nPSG.11.01.05 – Use only portable equipment tested and approved as ‘MR Safe’ or ‘MR Conditional’ as appropriate to the MR environment.
- nPSG.11.01.06 – Provide ferromagnetic (only) detection screening for persons and objects prior to admission to controlled access areas within the MRI suite as stipulated in nPSG.11.01.02.
- nPSG.11.01.o7 – Provide padding in accordance with MR equipment manufacturer recommendations to isolate patients from RF coil elements or from conductive materials in proximity to the patient (including the skin-to-skin contact of the patient’s own tissues) during the MR exam.
- nPSG.11.01.08 – Provide hearing protection for all persons in the MR examination room during the MR exam, verifying proper fit before initiation of the exam.
These 8 nPSG’s, if enforced, could actually slash the number of MR accidents dramatically! A retrospective analysis of MRI accident reports to the FDA indicated that more than 92% of MRI clinical adverse events are burns, projectiles and hearing damage. Adherence to these 8 steps could nearly eliminate MRI accidents and injuries!Tobias Gilk, President & MRI Safety Director — Mednovus, Inc. Tobias.Gilk@Mednovus.com www.MEDNOVUS.com Sr. Vice President — RAD-Planning.com TGilk@RAD-Planning.com www.RAD-Planning.com