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Consulting, Education, and Support

Providing education and regulatory preparation services for healthcare by conducting training, facility and life safety surveys with supporting document review (Joint Commission, CMS, OSHA, EPA, CAP, CLIA, AAAHC).


Whether you want a second opinion, additional education or coaching, Marge can help.

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Marge is the author of multiple handbooks, training manuals, and checklists.

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Marge prepares customized presentations across the United States in person and through webinars.

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Marge McFarlane - Healthcare Safety Professional, Consultant, and Educator

Partnering for Superior Performance

Meet Marge McFarlane
PhD, MS, MT (ASCP), CHFM, CHSP, CJCP, HEM, MEP, Principal Superior Performance Consultants, LLC
[email protected]

Marge McFarlane brings over 47 years of comprehensive healthcare experience in the environment of care, life safety, emergency management and infection prevention for construction. McFarlane has authored handbooks on the GHS update to the OSHA Hazard Communication Standard, OSHA training for Medical Facilities and was a contributing author on the special Dark Report for “COVID Risk Assessment/Testing for Laboratories.” She is a frequent presenter for seminars, regional conferences, and audio conferences on OSHA topics, infection prevention (for construction, legionella and COVID-19), hazardous materials/RCRA waste streams, and emergency management. She is currently working with healthcare systems and clinics nationally to identify and mitigate risks in the physical environment and help ensure regulatory compliance.

McFarlane holds a PhD in Safety Engineering and master’s degrees in Environmental and Public Health (ENPH) from the UW – Eau Claire and Risk Control from the UW–Stout. She is an active member of the Wisconsin Healthcare Engineering Association (WHEA) Code Committee and the American Society For Health Care Engineering (ASHE).

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The Company I Keep


OSHA: Beyond COVID-19

Although the Public Health Emergency Declaration ended in May 2023, COVID-19 remains a public health threat. OSHA requires all facility to follow all the General Duty Clause provisions: to maintain a workplace free from recognized hazards that could cause physical injury or death. This includes maintaining mitigation strategies against all infectious diseases: hand hygiene, surface disinfection, employee screening for communicable diseases. Masking and vaccinations are key mitigation strategies.

OSHA also requires all healthcare facilities to have a written Blood Borne Pathogen (BBP) Exposure Control Plan (1910.1030), a written Hazard Communication Plan (1910.1200), general safety and emergency plans, Infection Prevention/TB written Plans as well as annual training. A written Respiratory Protection Plan (1910.134) with fit-testing and annual training is required if any employees wear N95 respirators or powered air purifying respirators (PAPRs). I can assist with annual plan review, revisions/updates, and training.

The OSHA penalties have been increased in 2023 to $15,625 per serious violations and $156, 259 per willful or repeat violations. OSHA will also enforce an instance-by-instance (IBI) citation structure for high hazard willful violations such as falls, trenching, machine guarding, respiratory protection, permit-required confined spaces and lockout tagout. Many OSHA citations were written in 2021 and 2022 to health care facilities that did not comply with the training and fit testing requirements of the OSHA Respiratory Protection Standard.

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Environment of Care EPA/RCRA

The Environment of Care is the physical environment in which safe patient care, treatment and services occurs every day. I provide education to clinical staff as well as to those conducting environmental surveys to transition from “finding and fixing” to “tracking and trending.”

Services include Environment of Care plan reviews for safety and security, hazardous materials and waste, fire response, medical equipment and utilities; selection and tracking of performance indicators, review of the annual evaluation of effectiveness and assistance with documenting risk assessments.

OSHA regulates worker safety, CMS (Centers for Medicare and Medicaid) controls reimbursement for safe patient care, treatment and services and the EPA (Environmental Protection Agency) regulates hazardous waste. Healthcare is faced with complying with the complex and sometimes conflicting regulations from these federal agencies.

Services include navigation of the regulations and a gap analysis to ensure that all elements of compliance are addressed.

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Emergency Management

All facilities are expected to be in full compliance with all published updates to the CMS Emergency Preparedness Conditions of Participation (CoP). Healthcare is structured to provide very good care every day. There are times when there is a rapid increase in the demand for services. Emergencies may be handled by the resources on hand or with the need for additional resources. Everything gets accomplished but at a quicker pace. Disasters may require significant amounts of external resources and coordination and every need may not be met.

Emergency management is the process of planning for and mitigating (reducing the impact of) internal and external events that may require additional resources. Emergency response is the activation of pre-planned processes to respond to and recover from internal or external events and to restore the day-to-day operations of the hospital.

Exercises, drills and actual events are ways to test the current emergency capabilities related to communications, the allocation of resources, staff roles, safety and security, utilities and patient care and staff support. After action reports identify strengths to be maintained and opportunities for improvement.

Services include tailored checklists for exercise design, Emergency Management Committee education, exercise evaluation and after action reports with opportunities for improvement and periodic assessments for completion and sustainability of the improvements

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Life Safety Mock Surveys & Plan Review

A mock survey follows the agenda of regulatory surveys. Joint Commission mock surveys use the life safety document review and facility tour to assess compliance with the standards and elements of performance. The mock survey includes an Environment of Care and Emergency Management session for coaching and plan review. The EOC plan reviews include each of the management plans for safety and security, hazardous materials and waste, fire response, medical equipment and utilities well as the annual evaluation of effectiveness.

CMS mock surveys include life safety document review and facility tour to assess compliance with the Conditions of Participation. The mock survey includes a session for coaching staff in the Conditions of Participation, the expectations for federal surveys and mitigation strategies for the opportunities for improvement identified.

Hospitals are built to “defend in place.” Managing facilities is a challenging and ongoing proposition. I provide an extra set of eyes to help identify opportunities for improvement and strategies for managing those opportunities.

AAAHC mock surveys include a review of the physical environment chapter and supporting documentation

Services include facility tours, life safety plan and document review, interim life safety staff education, and associated plans for improvement as well as assistance in developing a prioritized list for implementation.

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Infection Prevention for Construction

Infection prevention for construction has evolved from “just for” large construction and renovation projects to include a required risk assessment for maintenance and small projects. These small projects may fly under the radar of the facility planning and construction committee but may impact vulnerable populations, even if only for a short period of time.

Services include staff and contractor education as well as strategies for and preparation of risk assessments, monitoring of projects related to the project and document review.

See the facilities modification risk assessment (FMRA)

This document can be used as an infection prevention risk assessment for maintenance and repairs.

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Legionella and other waterborne pathogens continue to cause illness and fatalities in the U.S. The Centers for Medicare and Medicaid (CMS) as well as other Authorities Having Jurisdiction (The Joint Commission, DNV, HFAP) have required Water Management Plans for several years. The focus for healthcare surveys now includes a review of implementation, monitoring, control, and validation. I can assist with a risk assessment for your facility, plan review and training. A key element to success regarding a flushing program can include the use of a Water Infection Control Risk Assessment (WICRA) as outlined in the recently published ASSE 12080 Standards. I have successfully completed the ASSE 12080 requirements for the Legionella Water Safety & Management certification. Let’s review the status of your WMP and make updates as needed.

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Aids to Understanding Compliance

The Support You Need

Forms, Checklists, Webinars, & More

Marge provides education and regulatory preparation services for healthcare by conducting training, facility and life safety surveys with supporting document review.

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OSHA Training Handbook for Healthcare Facilities, 2nd Edition

Identify specific methods to train staff, identify hazards, and document assessments to become a highly effective safety professional.

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The Compliance Guide to the OSHA GHS Standard for Hazardous Chemical Labeling

Written for medical and dental offices and healthcare facilities of all sizes, this handbook includes a downloadable Hazard Communication plan template that is easily customized.

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