INTRODUCTION

Overview

This topic elaborates on the role of a Hyperbaric Safety Director, including aspects related to designation, training/education and policies.

Authors also explain the rationale behind having a formally designated and specifically trained Safety Director in each hyperbaric medicine facility, even if a management organization has one Safety Director named at the corporate level for all of their facilities. Hyperbaric providers are encouraged to read this technical document in order to find out what applies to their facility, and why each facility should have its own designated safety director in order to comply with the intent and requirements of local, state, and national codes/ requirements. Designation of the Safety Director in writing and an appropriate job description for the role are paramount to hyperbaric facility safety. See job description template in topic "Hyperbaric Safety Director".

Background

Definition 

Language requiring an individual with the responsibilities of Hyperbaric Safety Director (HSD) has been in NFPA 99 since 1970 (56D). NFPA 99, 14.3 Administration and Maintenance contains the operational requirements for all hyperbaric facilities.  Section 14.3 identifies the designation of the Safety Director (14.3.1.3.2) as one of the most important requirements [3]. The NFPA 99 (14.3.1.3.2) requires that each facility designate an on-site Hyperbaric Safety Director (HSD) to be in charge of all hyperbaric equipment and maintain the operational safety requirements of Chapter 14.  [1] 

• Further explanation is provided in A.14.3.1.3.2 - The complexity of hyperbaric chambers is such that one person should be designated chamber operator, such as a person in a position of responsible authority. The safety director should serve on the health care facility safety committee. Due to a conflict of responsibility, the same individual should not serve as both Medical Director and Safety Director. In addition, due to conflict of responsibility the Hyperbaric Safety Director should not be the attending hyperbaric physician or non-physician provider.

About the term “Hyperbaric Safety Director”

The term “Safety Director” is used for convenience. It is the intent of 14.3.1.3.2 to establish a set of safety responsibilities for the responsible person, regardless of the actual job title assigned by the human resources department. That person should be knowledgeable and have the training and experience to recognize hazards.  [1]  

• The National Board of Diving and Hyperbaric Medical Technology’s (NBDHMT) position statement regarding the term Safety Director is as follows: The term Hyperbaric Safety Director can be replaced with other titles of similar meaning and identical intent. Examples include Hyperbaric Safety Supervisor, Hyperbaric Safety Technologist, Lead Hyperbaric Safety Technologist, Hyperbaric Safety Manager, and Duty Hyperbaric Safety Technologist, and like terms. It is not the intent of the NBDHMT to assign a title. Rather, the intent of this Position Statement is to identify and emphasize the need for a trained and designated hyperbaric safety individual at each facility.[2]

Relevance

Regulatory and accreditation bodies such as the National Fire Protection Association (NFPA), the American Society of Mechanical Engineers' safety Standard for Pressure Vessels for Human Occupancy (ASME PVHO-1), the Undersea and Hyperbaric Medical Society (UHMS) and the National Board of Diving and Hyperbaric Medical Technology (NBDHMT) have expectation that each hyperbaric medicine facility has a designated and trained individual function as a Safety Director to work in conjunction with the hyperbaric medicine Medical Director and the appropriate hospital/facility safety committees. The medical director, rather than simply a figurehead, must take an active role in conjunction with that of the hyperbaric safety officer. Not only is it an organizational role, but it is also a public safety role. See topic "Role of the Medical Director in Hyperbaric Safety".

These aforementioned organizations provide guidance and recommendation(s) in order to ensure compliance with regulatory and industry standards within the hyperbaric facility, as summarized below:

• The NFPA 99 (2018 Edition: Chapter 14) provides the regulatory requirement(s) and guidelines for Hyperbaric Facilities. Within Chapter 14 of the NFPA 99 are the guidelines that must be established to ensure safe operations of the hyperbaric facility.  [1]
• As stated above, NFPA 99 (14.3.1.3.2) requires that each facility designate an on-site Hyperbaric Safety Director (HSD) to be in charge of all hyperbaric equipment and maintain the operational safety requirements of Chapter 14.
• The UHMS Facility Accreditation Manual is a comprehensive evaluation of standards of care and patient safety through the evaluation of each hyperbaric facility, equipment, staff and training, in order to ensure that the highest level of quality is provided. [3]
• UHMS facility accreditation probe HBOHR 2.2 states that the individual designated as the Safety Director must attend a Hyperbaric Safety Director training course. Further, it expects that a Certified Hyperbaric Registered Nurse (CHRN) or Certified Hyperbaric Technologist (CHT) be on the premises when chamber operations are occurring.[3] 
• The UHMS facility accreditation probe HBOA 6.0 states that “A safety director of the hyperbaric facility has been designated in writing.” [1][3][4] 
• In a position statement, the NBDHMT states that the codes and standards expressed in the ASME PVHO-1 [5] and the NFPA 99, Health Care Facilities Code, Chapter 14, (Hyperbaric Facilities) be rigorously adhered to.  [1]
• It is the position of the National Board of Diving & Hyperbaric Medical Technology that every clinical hyperbaric medicine service designate a Hyperbaric Safety Director. This position is consistent with a previous NBDHMT Position Statement regarding adherence to recognized codes and standards.  [1]

TRAINING AND EDUCATION

The role of Safety Director requires additional, specific, and technical education in order to carry out the requirements for the facility. This is an ongoing and recurring requirement. Simply attending one advanced hyperbaric medicine safety course is inadequate to fulfill the spirit of these codes and position statements. 

Training, education, and experience are the fundamentals of qualified staff.  Each of these should be considered when selecting the Hyperbaric Safety Director.  

In regard to training of the Hyperbaric Safety Director, NFPA 99 (A.14.3.1.3.3) states [1]: 

• "It is incumbent upon the governing body to insist that rules and regulations with respect to practices and conduct in hyperbaric facilities, including qualifications and training of hyperbaric personnel, be adopted by the medical or administrative staff of the institution, and that regulations for inspection and maintenance are in use by the administrative, maintenance, and ancillary (and, in the case of a hospital, nursing and other professional) personnel."
• In addition, Appendix A (A.14.3.1.3.4) states – “It is recommended that training of hyperbaric chamber personnel be closely monitored, following the guidelines and publications of the Undersea & Hyperbaric Medical Society, the Baromedical Nurses Association, and the National Board of Diving and Hyperbaric Medical Technology”. 
• Note to readers: The NFPA Appendices are important resources, as they provide ‘real-world’ examples of the thoughts behind the codes stated in Chapter 14.

The NBDHMT opinion regarding training and education of the Hyperbaric Safety Director is stated in a position statement [2]: 

• "The Hyperbaric Safety Director should undergo formal and comprehensive training in the safety aspects of hyperbaric medicine and related technology. They should develop, maintain and manage a safety program based upon compliance with recognized standards. The resulting program should demonstrate effective elements of hazard mitigation, while employing recognized risk management concepts." 

The Hyperbaric Safety Training Course is an advanced hyperbaric medicine course that educates and aides the development of critical thinking skills and how to develop the processes to evaluate safety issues.  

POLICY - SAFETY DIRECTOR DESIGNATION

Purpose

To comply with NFPA chapter 14 [1], every Hyperbaric Medicine Service/Facility will appoint a Safety Director. 

Policy

Every Hyperbaric Medicine Service/Facility shall designate a Safety Director.

The NFPA 99 (2012 Edition: Chapter 14) provides the regulatory requirement(s) and guidelines for Hyperbaric Facilities. Within Chapter 14 of the NFPA 99 are the guidelines that must be established to ensure safe operations of the hyperbaric facility [1]. 

National Fire Protection Association (NFPA), the American Society of Mechanical Engineers' safety Standard for Pressure Vessels for Human Occupancy (ASME PVHO-1), the Undersea and Hyperbaric Medical Society (UHMS) and the National Board of Diving and Hyperbaric Medical Technology (NBDHMT) have expectation that each hyperbaric medicine facility has a designated and trained individual function as a Safety Director to work in conjunction with the hyperbaric medicine Medical Director and the appropriate hospital/facility safety committees. These organizations provide guidance and recommendation(s) in order to ensure compliance with regulatory and industry standards within the hyperbaric facility.

Procedure

1. Designation of the Safety Director should be documented in writing according to institutional policy with the corresponding administrative approval.
2. The Safety Director must meet the minimum qualifications stated in the UHMS Facility Guidelines specifically: successfully completing a UHMS, NBDHT - approved hyperbaric safety course, have a minimum of 12 months of hyperbaric chamber operation experience, and obtain a “CHT or CHRN” certification upon eligibility.
3. The Safety Director shall work closely with facility management personnel and the hyperbaric physician(s) to establish procedures for safe operation and maintenance of the hyperbaric facility. 
4. The Safety Director will make the necessary recommendations for program safety policy and procedures. 
   
5. The Safety Director has been given the authority to restrict or remove any potential hazardous supply or equipment items from the chamber.
   
6. The responsibility for the care and safety of patients and personnel is that of the Hyperbaric Medicine Service and the Medical Staff. 
   
7. It is also the responsibility of the Hyperbaric Medicine Service Medical Staff office to insist that adequate rules and regulations, with respect to practices and conduct within the hyperbaric facility, including qualifications and training of hyperbaric personnel, be met.
8. The Medical Director of the hyperbaric facility shall work with the Safety Director to establish minimum staff qualifications.