JCAHO Issues
From CrnaBIZ-Wiki
JCAHO
Share your tips on your recent JCAHO visit.
Labeling Medications For Anesthesia
Q: Do we have to label medications used during anesthesia or sedation?
A: Anytime one or more medications are prepared but not administered immediately (prepared by a person who takes the medication directly to a patient for administration without a break in that continuum), the container (which may be a bag, syringe, bottle, or box) must be labeled.
At a minimum the labeling must include drug name, strength, amount (if not apparent from the container), expiration date if not used within 24 hours, expiration time if expiration will occur in less than 24 hours, and the date prepared and the diluents for all compounded IV admixtures.
In addition, when preparing individualized medications for multiple patients or when the preparer is not the person administering the medication, the label must also include patient name, patient location, directions for use and any applicable cautionary statements either on the label or attached as an accessory label (e.g., needs refrigeration, for IM use only).
In most instances, medications drawn up by an anesthesia provider in the OR suite for immediate use are not required to be labeled. If however, a medication is drawn up prior to the case in the anesthesia prep room by an Anesthesiologist or any other Anesthesia team member, or a syringe is loaded in the OR suite for gradual push during the case, it must be labeled appropriately.Labeling Medication for Anesthesia
JCAHO Inspector Comments
Share your experiences with JCAHO Inspectors, perhaps we can better prepare for the next inspection.
June 2008, our institution was inspected by Dr. Barry Flock of JCAHO, a retired psychiatrist. During his clinical visit in the OR the CRNA had all syringes labeled and drawn up except for propofol. When Dr.Flock arrived the propofol was drawn up in a 20 ml syringe while he watched, the provider then set the propofol down on the anesthesia cart and turned to pre-oxygenate the patient, turned back and picked up the syringe and induced the patient. Later we were cited for failure to label a syringe.
At a follow up question and answer session, when a copy of Labeling Medication for Anesthesia was provided to Dr. Flock he said that when the provider set the syringe down and turned their back on the syringe they had "lost control of the syringe". When asked to clarify this he said anyone could have switched syringes while their back was turned. It was pointed out that if someone were intentionally attempting to undermine the anesthesia provider, a label on a syringe would not matter. He described an event in an ICU where an anesthesia provider had brought a syringe of propofol to sedate a patient, set the syringe down and walked around the bed to check monitors, etc. while doing this someone set down a syringe of "Ensure", which was later picked up by the anesthesia provider and injected.
Our argument was never about propofol in particular because we had been dinged at our previous JCAHO visit 3 years previously and propofol labeling is now our customary practice, however we were lead to believe that the JCAHO website's Labeling Medication for Anesthesia allowed some leeway to anesthesia providers in the Operating Room. Apparently JCAHO inspectors may subjectively interpret these guidelines.
