All safety-related incidents, including accidents, injuries and property damage, are reported immediately to the direct care supervisor and/or the campus maintenance staff for immediate attention. The supervisor will determine if the event meets the criteria for notification to an administrator after conducting a preliminary investigation and taking whatever immediate action is necessary. The administrator will determine if the event meets the criteria for notification to the on-call Senior Manager.

Depending on the nature and seriousness of the event, nursing (e.g., for injuries) and/or maintenance (e.g., for property damage) may also be notified.

An Incident Report will be completed for any safety-related event and depending on the nature and significance of the event, an investigation may be initiated by the Senior Vice President or the Program Director, in consultation with the Executive Director. The Quality Assurance Director would conduct such an investigation.

In the event that an outside municipality or company (i.e., fire, ambulance, police, hazmat, utility, etc.) is called onto a campus for an incident that disrupts services in some way, the Director of Quality Assurance conducts a thorough review of the incident and debriefs the incident with relevant managers and staff. The debriefing report is also shared with members of the Senior Management Team.
The purpose of this review and debriefing is to learn from the incident and, if possible, to prevent such incidents from occurring in the future.

Hillcrest will periodically evaluate the impact of buildings, grounds, equipment and internal physical systems on Hillcrest students, clients, staff and services and will make improvements, including both minor and major improvements, as indicated and as feasible, for each campus.

Planning for specific and significant demolition, renovation and/or construction projects will include impact assessment procedures for the project. The impact assessment is intended to identify conditions that could potentially compromise student, clients or staff safety and/or care in occupied areas of the buildings or in any part of the campus in which work is being done for, at least the following factors: air quality, infection control, utilities, noise/vibration, and emergency procedures.

Depending on the outcome of the project impact assessment, Hillcrest will select and implement controls and measures to reduce, minimize and/or eliminate any impact upon or risk to Hillcrest students, clients and staff. Additionally, on every such project of significance Hillcrest works closely with the local Fire, Building and Health authorities to insure compliance with local and state codes and standards.

On an ongoing basis, HEC operates a proactive program to identify and reduce adverse events and safety risks.  With regard to routine safety assessments, please refer to section V. Hazard Surveillance.

The primary objectives of the Safety Management Plan are to:
• Establish and maintain a physical environment free of hazards.
• Manage student, client and staff activities to reduce the risk of injuries.
Hillcrest will accomplish these objectives in a manner compliant with regulations promulgated by the Mass. Dept. of Early Education and Care (DEEC), Mass. Department of Elementary and Secondary Education (DESE), standards established by the Joint Commission (JC), and all other applicable laws, regulations and standards.

PURPOSE
Hillcrest Educational Centers is committed to providing a safe environment for students, clients, staff and visitors. Safety management is an interactive process designed to involve all staff members in the continuous monitoring and evaluation of the elements that make up a safe and secure environment of care. Each staff member, regardless of position or role, is trained and expected to be vigilant and proactive with regard to safety and security in order to maximize the therapeutic and protective nature of the Hillcrest environment for students, clients and staff. The Safety Management Plan helps to define and structure this process.

In the event that any Hillcrest campus or site is significantly affected by a disaster or emergency event, one that fundamentally affects operations, at least the following activities will be considered and/or implemented.

A) Structural and building systems inspections.
As needed and as indicated by the nature and extent of the disaster/emergency event, structural and/or building systems inspections will be conducted by both the Hillcrest Maintenance Department, local building inspectors, and by outside consultants (e.g., architects, engineers).

B) Disaster counseling for students and staff.
Disaster recovery counseling (individual, group) could be conducted for students and/or for staff by Hillcrest staff who trained in Emotional First Aid as members of the Berkshire Trauma Response Team; Hillcrest Clinical personnel from other campuses; and/or trained disaster recovery personnel from an outside agency (e.g., American Red Cross). Hillcrest will determine the indicated modality and format contingent upon the nature and extent of the disaster/emergency event.

Hillcrest staff and their families also have access to EAP counseling on a confidential, as needed basis.

This Plan shall be reviewed and evaluated each year for its effectiveness, scope, performance and objectives. A work group minimally consisting of the Director of Quality Assurance, the Director of Facilities, and the Chairpersons from each campus EOC Committee and/or their designee will conduct the review and evaluation between March and May of each year. The results of the review and evaluation, and related recommendations, will be reported sequentially to the campus EOC Committees and the Senior Management Team for their review and approval. Barring unforeseen and unavoidable delays, this revised Plan will be implemented each July at the beginning of the new Program Year.

All new staff, regardless of their position, role or work site, participate in a 9 day Orientation to the agency and designated work site which includes a module on emergency preparedness and response.

On an ongoing basis, program staff participate in Emergency Preparedness and Response training each quarter.

Monitoring of performance regarding actual or potential risks related to the following areas are conducted on an ongoing basis in different ways.

A) Staff knowledge and skills
The monitoring of staff knowledge and skills (e.g., EMTs, trained First Responders) is conducted through regular observation of performance by supervisors, through formal supervision meetings, through annual performance evaluations, and through at least 24 hours of training and staff development conducted each year. Training in emergency procedures is conducted quarterly, as required by DEEC regulations.

B) Level of staff participation
The monitoring of staff participation is accomplished through means described above in section A). Training in emergency procedures is conducted quarterly, as required by DEEC regulations.

C) Monitoring and inspection activities
As noted in other Environment of Care Plans, all utility systems at residential campuses are tested and/or inspected quarterly. Equipment is tested/inspected on a schedule recommended by the manufacturer. All facilities are inspected for safety and maintenance issues at least monthly.

D) Emergency and incident reporting
All incident reports, including reports related to emergency situations and physical restraints, are reviewed by supervisors, nursing staff, clinical staff, and program managers. Incidents which are not documented require follow up by supervisors, and incident reports which are not completed correctly or according to procedure, are returned for follow up by the supervisor.

Data on emergency incidents is maintained and is reviewed on a regular basis by the campus Improving Organizational Performance Committee and agency administration. Data on emergency events is reviewed on an as needed basis by the campus/program Environment of Care Committee.

E) Inspection, preventive maintenance and testing of equipment
As noted above in Section C), residential campus equipment is tested/inspected and maintained on a schedule recommended by the manufacturer.

Internal communications on campuses can be conducted in at least five ways: in-person, via the telephone intercom system, via walkie talkie, via urgent priority email, and via cell phone text messages, and one-way communications via the campus paging system. In the event that the telephone intercom and paging systems are not operational, alternative measures will be employed.

Communications between campuses and Central Administration and other parts of the “outside world” are conducted in four ways: in-person, via the regular telephone, via cell phone, and via email sent through T1 cable.

In the event that none of these electronic communication methods are operative, in-person communication will be attempted (e.g., with the fire department or police).

[Note: Program specific Evacuation and Intruder Protocol procedures are also covered in the Hillcrest Emergency Manuals.]

If, as a result of an emergency/disaster, the threat of such, or for any other reason, campus facilities cannot support adequate safety for students and staff, and/or care and treatment of students, evacuation procedures will be implemented. Evacuation procedures will only be initiated by the Executive Director, Senior Vice President, the Program Director and/or his/her designee, or by an authorized member of the agency Senior Management Team.

After being notified and confirming, and/or determining that an emergency evacuation is necessary, the Executive Director, Senior Vice President, and/or the Program Director or the administrator in charge will contact Central Administration and apprise them of the situation. The administrator in charge will make arrangements to evacuate the campus, including all students and staff, to the nearest suitable relocation site, preferably another Hillcrest site. The day program will relocate students to their residences, if that can be safely done. The Executive Director, Senior Vice President, and/or the Program Director will determine what supplies, medication and records can safely be prepared for evacuation, and when. However, the safety, well-being, and protection of the students and staff are always the first and foremost priority of all decision makers during the evacuation process.

If conditions are such that supplies, water and food, medication and records can be prepared for transport without compromising the safety of students and staff, the Executive Director, Senior Vice President, and/or the Program Director or his/her designee will notify all available department heads and supervisors of the need to evacuate the campus. He/she will provide direction to department heads as to how they and their staff will be deployed during the evacuation and relocation with regard to preparing supplies, food and water, medication and records; securing and preparing vehicles; communications; or assisting direct care staff with students.

If conditions are such that supplies, water and food, medication and records cannot safely be prepared for transport, department heads and their available staff, and supervisors will be deployed in preparing the students and staff for transport as soon as possible, initiating security procedures for the campus, and gathering telephones, cell phones and walkie talkies for emergency communication during the evacuation.

If conditions allow, the nursing staff at residential programs will prepare at least one day’s medication for all students. They will also secure for travel all lists and information related to the daily meds and medical needs of the students being evacuated.

Provided it is safe to do so, the residential supervisor on duty will bring the students’ Emergency Medical Files and, additionally, necessary supplies from the campus to the relocation site. Supplies will be selected based on current, emerging and projected conditions, and the selected relocation site. Supplies may include such things as bed linens, articles of clothing, ADL supplies.

Once the students and staff have reached the relocation site, the supervisor on duty will notify the Program Director or the manager in charge if he/she is not at the relocation site. The supervisor and/or available administrators will survey the site and make a list of supplies that are needed. Once the list of supplies has been compiled, the supervisor will call the other campuses and/or emergency management agencies to procure the needed supplies.

If there is not enough bed space at a single campus, the students will then be placed in the other campuses or relocation sites on a space available basis. The Program Director or the manager in charge will then notify the nursing department that the students are being evacuated and the nursing department shall insure that the students’ medications and medication charts, if available, are delivered to the campus(s), provided it is safe to do so. The supervisor will also bring student case records and medication files, and deliver them to the campus nurse.
If evacuated residential students cannot be housed at either a Hillcrest campus or the administrative offices, the students shall be housed at a motel or emergency shelter until suitable on campus quarters are available. If this contingency becomes necessary, the Program Director or the manager in charge and Central Administration will arrange for necessary staffing and support.

If this contingency becomes necessary, the Program Director or the manager in charge will contact motels and/or emergency shelters in the area and reserve space for the students and staff.

The Program Director or the manager in charge will keep the nursing department and Central Administration appraised of the students’ relocation sites. The nursing department will insure that the students’ medications and any necessary medical supplies, if available, are in place at the relocation site, provided it is safe to do so.

Finally, in the event that a student at any program refuses to leave a building during an actual disaster evacuation, as opposed to an evacuation drill, the student will be physically removed by staff in a manner consistent with Hillcrest’s physical intervention policy, if possible. However, since an evacuation would only be conducted if remaining inside a building or on a campus would present imminent danger of serious injury to students and staff, any student refusing to cooperate with evacuation procedures will be physically removed by staff as quickly and safely as possible.