#114 If An Active Shooter or Other Violent Incident Occurred, Would Your Practice be Prepared?

This episode is the second part of episode #106 - Emergency Evacuation Planning.  As workplace violence, especially domestic violence and active shooter incidents are increasing, the Dept. of Homeland Security, the FBI and OSHA are encouraging all employment settings to have an emergency action plan place.  The Divas will discuss the philosophy of Run - Hid - Fight, in the case of a violent incident, resources for creating an emergency action plan and other recommendations to ensure the safety of dental practice employees and patients.

Resources:  

• OSHA Standard 1910.38 Emergency Action Plans  http://bit.ly/3MnehnE 
• OSHA Evacuation Plans and Procedures eTool https://bit.ly/46OroaL
• OSHA Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers  https://bit.ly/3OywOQI
• FBI Active Shooter Safety Resources  https://bit.ly/3OAHDlm
• Dept. of Homeland Security - Active Shooter How to Respond https://bit.ly/46WEjHY

                                                 https://www.thecompliancedivas.com

Transcript

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SPEAKER_01 0:04

Welcome.

SPEAKER_00 0:05

I'm Leslie Cannon. I'm Mary Gavoni.

SPEAKER_01 0:09

I'm Linda Harvey. I'm Olivia Juan. And together we are the Compliance Divas. Welcome to the Compliance Divas Podcast. My name is Mary Gavoni, and I will be the moderator for this episode. The Compliance Divas bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. You can subscribe to the Compliance Divas Podcast through your favorite podcast channel and on our website, thecompliancedeivas.com. The resources that we mentioned during this episode can be found on the compliancedevas.com website and also in the show notes on your favorite podcast app. You can submit questions to support at thecompliancedivas.com by email, and we thank you for joining us. In our previous episode, the Divas discussed the importance of complying with OSHA's requirement for emergency evacuation plans. In this episode, which is part two of that previous episode, we will discuss OSHA's requirements for emergency action plans or what to do if there is an active shooter situation in an area or some other kind of an external threat. And we see these external threats happening more and more in our country. So we do need to be prepared. So, Linda, will you start us off by discussing what are OSHA's minimum elements of an emergency action plan?

SPEAKER_02 1:44

Sure, Mary, I think this is just such an important topic. As you mentioned, there's so many external things happening and external threats, and there's just things that could happen inside the office as well. So specifically, OSHA does have requirements for the emergency action plan. And there are six items that have to be in this plan, Mary. First is the procedure for reporting a fire or other emergency. That means if I walk into the sterilization center and I see a fire, I walk into the kitchen, I see a fire, how do I do? Do I just run around yelling fire? What's the plan? We have to have some organized method for reporting the emergency and making sure that the authorities get notified as well. Next is the procedures for the emergency evacuation. And that is dependent upon the type of evacuation that you have. Is it going to be a fire? Is it uh everybody's on their own because it's an active shooter and you're just trying to run and get out of the office? So having those procedures is important because many times, divas, I bet we've all been in a dental practice when they've received a shipment or they've unpacked a shipment and there's boxes all over the back by the blocking the back exit. And that's exactly where you would need to evacuate in the case of some kind of emergency. And if you have any patients that need any kind of assistance in wheelchair or if they're sedated, or they have a cane or a walker, then you're just eliminating the opportunity for everybody to exit safely. The third step in that is required is the procedures to be followed by employees who remain in the office to operate any critical, they call it plant operations in the OSHA language before evacuating. So that would be turning off the medical gases, turning off sanctions, uh powering down computer or just things that you would want to just quickly take care of. So who would be the person to stay behind and would it be safe for anybody to stay behind? I think that's going to be a case-by-case evaluation depending on the nature of the event. So, Mary, let's say it's a small fire, it's just kind of smoke, it's not in the way, you can quickly shut down some things, you know, then do so. But if it's an active shooter and you just need to evacuate in an emergency, there's not any time to think about protecting your PHI or turning off the medical gas. It's protecting everybody that you can in the office at the time. Then the fourth step is the procedures to account for all the employees after the evacuation. Normally, you know, a small dental practice, that's not too hard to account for your team members. But if you have a very large practice or you have a lot of part-time staff, or you have you know staff that come from other locations, if you're a multi-site or a practice, then who was there that day in addition to the patients? We want to count heads, not text messages, is what I typically say. Number five that has to be included, is the procedures to be followed by employees that are performing any rescue or medical duties. So uh in the event that someone needs to provide first aid or CPR, you know, we all should be trained on CPR. I think that's pretty much universal across all the states. But what other things, uh types of medical duties would someone have to do, apply? You know, so just a simple first aid, um, cuff finger, or what if it's an active shooter and you've got someone who's bleeding as you've exited? You know, how will you take care of that person? So we're thinking a lot more broadly these days. And last but not least, are the name and job title of every employee who may be contacted by employees for who need more information about the plan. So that's a little bit of a lengthy description, but what that means is who's the point person for this emergency action plan? So the rest of the team members can contact the office manager, the safety coordinator, or the doctor to get more information on this plan. And like everything else that we've talked about, Mary, that requires training updates, this plan needs to be reviewed at a minimum on an annual basis. And I'm certainly of the mindset that we should be doing more, even on a more regular basis, Mary. I think that one thing we could do and always recommend is to add safety and compliance to our team meeting agendas and just talk about a few things throughout the year. So you stay up to date and ready, ready, prepared. Emergency preparedness matters. Now I'd like to turn to your second question, Mary, and let's talk about what does OSHA say about active shooters? And OSHA does not have an active shooter standard or even a workplace violence stamp uh standard, but OSHA does have guidance on handling workplace violence, and this is where active shooters would fall. So we will include some resources in the show notes for this podcast so our listeners can access the workplace violence pages and resources on the OSHA website as well as some other websites that we have for you all, because it's very important that you have an active shooter plan in place. Now, before I mention any more about this, I'm going to ask everybody to lean in because I want to tell a story that I just learned about this morning before this podcast began. And that is the fact I have a hygiene friend in one of the metropolitan cities who actually had a friend that was shot in a recent shooting at a medical building in that town. And fortunately, her friend is going to be fine. She was a sales rep sitting in the reception area and she got shot. So we don't have to be just the patient or the employee or the doctor to be in harm's way with an active shooter. Well, as it comes to find out, the same hygienist recently had a threat in her practice by a patient who was angry about something. They sent a very threatening email to the practice. So can you just imagine how this hygienist must feel having a personal friend who was shot in a workplace violence scenario and now her office is being threatened by a patient? This is real. This is happening. So knowing what we need to take care of to be safer in our practice is so important. And I want to bring it home, Barry, to the point that even though there's no particular standard by OSHA, OSHA does have the general duty clause. And this standard, the general duty standard, says that all employers shall furnish each employee a place of employment which is free from recognized hazards that are caused, that are causing or likely to cause death or serious physical harm to employees. And that's a very broad range of hazards from active shooters to fire safety to all kinds of emergency preparedness. But the second piece of this that most of the time we don't mention, and I'm not sure that many of our listeners are aware, but the second half of that statement is that each employee shall comply with the occupational safety and health standards and all rules, regulations, and orders issued pursuant to this act. So that means that we don't really have a right not to wear the PPE, a right not to be compliant. And so we have to be safe as well in our workplace. So, Mary, this is just such an important aspect, and I can't wait to get these resources out to our listeners. So thanks for asking those questions.

SPEAKER_01 8:36

Thank you, Linda. That was such a great um description of um the requirements that need to be in place. And again, we we tend to think that this won't happen in our office, it won't happen in our town. But what we're now seeing in today's society is that it's happening everywhere. And it's it's not a matter of will it happen? It might be more of a matter of when might it happen. So we do need to be prepared. So, Leslie, I would like to call on you to talk about OSHA's really helpful e-tools that they've made available for practices to create their emergency action plans.

SPEAKER_00 9:18

Mary, I was so excited to work with this e-tool, and I discovered how convenient it is and how easy it is for dental practices to utilize it. So, first I want to say the e-tool is located on the OSHA website, and we'll have that link on the compliance diva's website in the resources and also in the show notes. And it helps small or low hazard service or retail businesses implement an action plan, an emergency action plan that does comply with OSHA's emergency standards. And so one of the things that I clicked on when I first went to this page was do I need an emergency action plan? When I clicked on it, I was so excited that it takes you to another page that has an actual checklist that you can click on and you can go through the checklist and identify the things that might be a hazard in your practice. The tools that are provided on the emergency action plan is on how to draft an emergency action plan. But there's also information that drafting an action plan isn't enough for safety of employees. You actually have to go through the training, you have to appoint someone to be in charge, you have to review your plan and evaluate the plan to see how well it works for you and to create muscle memory should the event and any kind of an emergency event occur in your practice. Now, when I went through the checklist, which by the way, when you go to the uh page that has the emergency action plan and you click on why do I need an emergency action plan or do we need one, it says use the OSHA expert, which is a little simple fill-the-blank expert system that helps you write your own emergency action plan. And of course, there may be things that you might add to that list that are particular to your location. Perhaps, you know, in California, we're prone to earthquakes, whereas uh in Olivia's town, uh she's prone to tornadoes. So it might be uh an area or geographic specific, but it gives you an opportunity to answer general issue questions. Um, like, does the plan consider all potential natural and man-made emergencies that could disrupt your workplace? And it gives you examples of that. As I stated, it might be, well, you know, earthquake or tornadoes, but fire or explosion or floods or hurricanes, toxic material releases. We've seen a lot of uh that on the news lately with train accidents, radiologic or biological accidents or civil disturbances and workplace violence. Uh, have several dental offices that are in the San Francisco area. And sometimes there are protests, and that disrupts being able to even get to work or home from work due to the number of individuals either on foot or on bicycles in that area. So the evacuation plan and procedures e-tool is extremely helpful. But I have to stress again that it's important to develop an emergency action plan. And OSHA says a very simple plan will suffice. There are uh really important steps to follow. Using the checklist will help you identify what your plan should look like. The next thing that they tell us, Mary, is that there should be someone responsible to lead and coordinate your emergency plan and evacuation so that that person uh has been identified to other employees and everyone knows who the go-to person is that has the authority to make decisions in an emergency. Also, what's important is of course the employee training to cover certain things on uh how, for example, how you will communicate emergencies to employees. So we know who will be in charge, we know how to communicate. General training should address the following things. Are there individual roles and responsibilities for individuals in the practice? I know in one practice recently we practiced what to do should a patient have an emergency. And the the uh protocol was that the doctor would stay with the patient who's in distress, that uh the assistant would tell the receptionist to call 911, uh, the other assistant would be charged with the responsibility of bringing the first aid AED and oxygen tank into that room. And then uh the receptionist would be charged with the responsibility, or the second receptionist of going out to the street to flag down the ambulance and lead them into the office. So everybody knew what their role and responsibility was. It wasn't just of you know who's going to do what at the time of the situation. It's also important to identify the kind of threats and hazards and protective actions that will be taken, along with how we'll notify. What's our notification? What's our warning or communication system? In hospitals, they have the various different codes of the different colors. What do we do in dental offices to convey that there's an emergency? And then another important fact would be to how do we locate family members in an emergency, both for our patients and for our team members? Do we have emergency contact information on file? And what kind of evacuation, shelter, and accountability procedures are there? And where is the emergency equipment that we might use for first aid? Uh, where's it located and has it been updated? And what are our emergency shutdown procedures if we have to shut down anything as we're leaving or evacuating our practice? So once you've got your plan and you've conducted some drills, then finally it's important to evaluate how your response was. How did we do with our drill? What things could we have done better? And then make little tweaks to your plan to make it fit better. Another facility I was in uh had told everybody to exit a certain door in the event of an emergency. Well, they found when they actually did the drill that there were too many people on that side of the building to exit that drawer. So they changed the protocol to exit at the nearest door and rendezvous at the uh described meeting spot. So, Mary, the e-tool will help anyone who needs to put this plan together. And remember, OSHA does say that it is required and will help them through the steps of how to actually stage the uh emergency evacuation or the emergency protocols and how to initiate it and get everybody's input on how to think this through.

SPEAKER_01 16:00

Oh, Leslie, thank you so much. Um, I'm glad that you shared your story about the the exit doors and too many people. I always ask my practices to be aware that you know, if both of your exit doors or all of your exit doors are blocked, you have to know how else you're going to get out of that particular building or out of that office. So they have to think about whether windows are um an option and how are you going to open the windows if they um are not ones that can open. And a firefighter friend of mine has always said that that's what you use the fire extinguisher for. You shouldn't try to fight the fire, get out of the building. And if you can't get out through a door, then you use the fire extinguisher, which is nice and heavy, to break the glass to get out. So I think that's a good suggestion. So our diva Olivia could not be with us today, but what she wanted to share is information from the Department of Homeland Security and the FBI about elements of training and all kinds of good resource information for active shooter. As Linda said, OSHA does not have a requirement, at least not at this time, for active shooter training and emergency action plans specific to active shooters, but nonetheless, the Department of Homeland Security has created a really great informational booklet that you can read through that explains all the types of things that you should be aware of and plan for if there would be an active shooter. The FBI also has a lot of great um resources, including some videos, and we'll put all these links in the show notes and on our website that you can access. There no charge for access to this information. Both Homeland Security and the FBI even have posters that you can put up in your office that explain what you should do. And the three elements that both of these agencies talk about that you need to consider and plan your protocols around is run, hide, and fight. And so you would run away from the shooter or want to run away from the danger, would be your first plan of action if you can. If not, then you hide. And where would you hide? Would you hide in your office? Are you gonna hide under the desks? Where are you gonna go to hide from that threat? And it could maybe not even be a shooter, it could be somebody um intent on harming a particular employee in the practice, and then fight back if necessary, and only if necessary, because you know that you most likely will be injured if you try to fight back. And one of the things that we've seen over the last number of years with some of the incidents that have been happening is that many times the incidents are some manifestation of domestic violence, a domestic situation, like a soon-to-be former spouse or a domestic partner coming to the office to or coming to a business to kill this person or harm them because they're angry with them. And we have seen that in several dental offices. Linda's gonna talk about one in in just a minute. Um, and OSHA does have guidelines, it's not a standard, but they do have guidelines about um workplace violence, including domestic violence, in the workplace. We will also put that um resource um in the show notes and on the website. But there have been several states. Um, my home state of Michigan is one where a hygienist was killed by her soon-to-be ex-husband. This happened, oh my gosh, more than 20 years ago, where the back door was open and this person was watching outside to see when his soon-to-be former spouse would be in the break room, which was visible from outside alone, and came in the back door very quickly and used a hammer to beat her. Um, before anybody could even respond, she was killed. Um, used the hammer to beat her in the head and killed her. So um it can happen anywhere. And one of the simplest things you can do, and we talked about this in the emergency evacuation um plans episode about keeping that back door locked from the outside and then able to open easily from the inside. So, Linda, can you give us the specifics about a shooting that occurred in our diva Olivia's home state and what the circumstances of that were?

SPEAKER_02 21:09

Oh, Mary, this is gonna have everybody riveted because when you hear these topics, they're just gut-wrenching, but you you you and you wonder how could this happen? You know, you don't want it to happen in your office. So, how do we work on those types of things? But this is a situation where way up tucked in the northeast corner of Tennessee in Kingsport, um, there was a team member's husband who came into the practice that day with intent to kill, and that he did. So this couple, the the adult assistant and her husband were going through a divorce. He had a history of violence towards the family, um, wife and children. And she had a restraining order against him. But because he'd been hired by the doctor to do some work in the past, he knew the inner layouts and other side entrance to this office. So he actually entered the office through a side. Door with an adjoining business. So, Mary, one of the things that we now ask all of our teams, especially because of HIPAA, is do you have any adjoining adjoining doors? Because we're thinking of protecting PHI, protected health information. But this is another reason to ask that, because that's another opportunity that could be for someone to get into the practice. So he came in with the gun and found her, and it just gets the whole the whole drama that ensued was like a horror movie. He was trying to drag her out of the operatory, the doctor tries to intervene. Husband points the gun at him, points the gun at a dental assistant, and ended up shooting his soon-to-be ex-wife in front of everybody. So it was quite a traumatizing situation, and with others almost getting killed along the way, trying to save her. And along she's screaming, you know, please don't let them take me, please don't let them take me. So you can just imagine the chills that were going up and down everybody's spine thinking about this and reacting in the moment and just really lean in because this can happen. So one point to take away from this is if you are having any difficulties and you've got a restraining order in your life, we I really highly recommend team members please share that with your doctor. There may be things that can be done to enhance the safety of the office and the team members and yourself that could be easily implemented, very easily. And I think about another scenario, Mary, when I was speaking in the Atlanta area, this is 10 or 15 years ago now, at least, where some team members there were sharing with me another similar situation where this was a case of a patient that got shot in the chair by her soon to be ex. So in this case, they the office like normal confirmed that patient's appointment, but they didn't know the couple was separated and she had moved out. So it just breaks your heart, I know. So her soon to be ex knew where she was and came and shot her while she was receiving dental care. So things to think about are how can you protect somebody from getting into the front door? That inner reception room door, can it be locked? You know, can we invest in that? What about emergency buttons at the front? We have those in our ambulatory surgery practices. Um, so it's things to consider. So I think there's a lot of opportunity for improvement for safety and awareness. And it's just um something that's very important, Mary. So thanks for bringing this to our attention.

SPEAKER_01 24:25

Thank you, Linda. And I agree with you, people are probably going to be horrified by listening to some of the things on this podcast, but it is the reality check that we all need to know that we now live, unfortunately, in a society that's um prone to violence and prone to violence with weapons. And so we need to be prepared for that. It could happen. And there still is that perception out there that dental practices have a lot of drugs on hand that someone might want to access. So there's another um scenario why somebody may um provoke some violence in a in a setting, thinking that they maybe have access to um to medications. So the key takeaways I think from this episode are number one, have a plan and think about the fact that it could happen in your practice. And as Leslie mentioned, look at the OSHA e tool and see if it can be a help for you if you're not sure where to start with a plan, um, how to put one together, and also access the resources from the FBI and in Homeland Security on the potential for some type of violence having to do with an active shooter. So thank you for joining us. The compliance divas bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. If you have any questions from this episode, submit them by email to support at the compliancedivas.com, and we will answer those questions for you. And all of the resources that we mentioned will be listed again in the show notes for the podcast on your podcast app, and they will be listed on our website, thecompliancedivas.com. So thank you again for listening, and we hope to have you join us again on a future episode.