Tuesday, March 20, 2007

Speaking of pharmaceuticals, I could use some myself...

...because I've been piddling around with my pharmacy at Wheatlands all day.

There is a primary set of regulations that dictate how pharmacies should be run and how chemicals in them should be processed called USP 797. There are three levels of pharmacies, classified depending on the hazardousness or the specialness of the chemicals that get mixed in them: low-risk CSP, medium-risk CSP, and high-risk CSP. For this entire project, we've been designing Wheatlands' pharmacy as a low-risk CSP pharmacy. They mix pretty tame stuff and only use it in-house (it's not a pharmacy like the ones at which you fill your prescriptions, like a CVS or Walgreens). The head of nursing showed the floor plan of the pharmacy to a pharmacist in a nearby larger town and had him review it with his understanding of USP 797. He said it looked good to him.

Well, some guy who's supplying the fume hood for the chemotherapy chemical mixing room mentioned USP 797 again and told the head of nursing about a few things she better make sure she had in the pharmacy, such as seamless flooring and HEPA filters. The design team leaps into the air and shouts, "What?! We thought we did that already!" So, I call this guy and he sends me to a website where I get the 100+ page PDF of USP 797 (which I've been trying to find for this whole project). I ask him about flooring and light fixtures, and he says:

"Oh, I don't really do much with the building. I'm more concerned with the processes in the pharmacy, like where and how they handle the chemicals."

Well, thanks, Scooter Bob. Why the fuck did you mention finishes if you don't actually look at them? Anyway, the design reviews the standards, clarified a few of our finishes, confirmed that we had all the right filters and fixtures, and went on our way. As I was wrapping up this issue, I emailed the hospital and informed them that all was well, we comply with the USP 797 regulations for a low-risk CSP pharmacy.

We do have a low-risk pharmacy, right?

The head of nursing confirmed this for us.

Then I got an email on Friday. The head of nursing had been idly talking to her pharmacist in the other town over and mentioned that she was mixing a "banana bag" (an IV bag that includes vitamins and electrolytes, often given to severely dehydrated patients or alcoholics in the ED), and the pharmacist suddenly says, "Oh, banana bags? Those make you have a medium-risk CSP pharmacy."


The design team goes into another tailspin. Everyone tears open their copies of the USP 797 again to discover that we now need an extra sink in the ante area/buffer room, which means we have to sawcut the slab (with the seamless flooring already installed) to install another waste line. Worse, my mechanical engineer found fishy language in USP 797 saying that the buffer room "should" provide 40 feet per minute airflow in that room. This room is only 140 square feet total--40 fpm is going to turn that room into a wind tunnel. "Pixie, they'll get so annoyed with their papers and gowns blowing around in that room that they'll just shut off the equipment and never use it!" my engineer nearly wept into the phone.

I call the head of nursing and get a name and phone number for the state pharmacy board. I call and talk to a guy who's trying to be helpful, but God help him he works for the government and can only say so much because he only knows so much. "So what about this 40 fpm airflow in this buffer room?" I asked him. "We're already supplying more air than required for a low-risk CSP, but that's gonna turn that room into a wind tunnel. Do we have to do it? The code says 'should', not 'shall', which would be more definitive." And he says:

"We really don't so much with the building, ma'am. We're more concerned with the processes in the pharmacy, like wher and how they handle the chemicals."

Wow. Deja poo: I feel like I've heard this shit before.

So, he says for the purposes of the Kansas state pharmacy board, he says that as long as the airflow in the room is the same as what this one clinical requirement says on this one page of the USP 797, they're fine. So, I call my engineer back, who stil feels weird about the whole thing, so I give him the pharmacy board guy's name and number.

Later this evening at home, Guy asks me how was my day. Now, comedian Chris Rock says that the question "How was your day?" is a 45-minute conversation for a woman. This is also true for me. I'm venting about the pharmacy and how we've gotta design to this ridiculous and unclear code and how this pharmacy guy said that they hadn't even adopted USP 797 yet but would be later this year--

"Bullshit!" crowed Guy. "When I did the addition to Sunflower Medical Center out there three years ago, the state board said they were gonna pass USP 797 'later that year.' They still haven't! It's fucking impossible for state agencies to adopt new codes and regs because the state legislature has to pass the law for them and they're too busy arguing over funding education and banning gay marriage!"

I put down the spoon I was using to stir my pasta alfredo and called my engineer from home. "Jerry, have you called the pharmacy board guy yet?"
He sighed. "No, it's on my list."
"When you call, dude, don't push him too hard on the 40 fpm thing. They've been saying they were gonna pass USP 797 for over three years now, so we don't wanna back this guy into a corner and make him tell us to follow the letter of the code."
"Which will just back us into a corner."
"No sweat, Pixie. I'll poke him with a very dull stick tomorrow."
"Thank you sir."
"I hear something sizzling."
"Shit! My pasta!"
I"m hanging up now, Pix."


ms. kitty said...

My God, you have to know a lot of stuff to be an architect! It never occurred to me that a building designer would have to take so much into account in putting together the specs for a structure. But of course it's essential. I do not envy you, Pixie. It's easy to be a minister, in comparison.

faded said...

Don't the code guy drive you crazy?

What was ok in one county was not acceptable in another county. The disturbing part was both counties were using the same building code.

I really loved the "after the fact" code changes. The floor plans had been thru code review, the inspectors had been inspecting at the correct times and the project passed all of it's inspections, and then a problem is found relating to the something that was approved early in the construction process.

You say it was accepted 8 months ago, here is the approval in writing. The code guy says we changed are minds, go tear it up. This happened on about 20% of the projects at Pickles, Pickles and Pickles architects.

These problems always cropped up with a particular inspector in the city of Pinkville. When he retired all the contractors in the city threw a party, but it was not to honor him. They visited years of anger and hatred on him for his behavior as city building inspector.

ms. kitty said...

Pixie, do you know a Denver archyteck who goes by the name of Pickle? He used to be on the A-Basin ski patrol with my ex and me. The comment by Faded made me think of him. I don't remember his real name.

Mile High Pixie said...

Faded: Sad thing is, it's not even the code guy proper. It's a set of codes that the hospital has to follow but that no one who checks life safety knows about. That's what makes us crazy.

Ms. Kitty: not familiar with a Pickle, nor were any of my immediate coworkers. And it's funny how much I realize I've learned in the past almost-seven years.