Center for Improvement in Healthcare Quality Newsletter
October 2021


How Survey Ready is your Emergency Cart?

By: Gina Miller
The infamous emergency cart; better known as the crash cart. Hopefully, it is seldom used. However, it needs to be immediately ready to roll in an emergency. How do you balance the accessibility requirements with security for the equipment and medications contained therein? Let’s look at the regulatory requirements and how to apply them.
According to the NFPA 101 Life Safety Code, a crash cart is always considered “in use”; therefore, a crash cart along a corridor wall or near patient rooms will not be cited for blocking the means of egress. Carts are allowed to be stored in hallways or outside patient rooms. There is another misconception that a defibrillator needs to be plugged into a red emergency receptacle. The regulations do not specifically require they be plugged into an emergency powered outlet – but they do require that there is a process for assuring that the equipment is immediately usable, including during a prolonged power outage. If you do not plug into emergency power outlets, assure that staff can verbalize what is done during a power outage to assure readiness. If your defibrillator is non-battery powered, it must be plugged into an emergency receptacle during active use.
Do you need to keep a printed monitor strip to document your daily (or twice daily) check of the defibrillator? Unless the manufacturer of your defibrillator or your policy and procedures specifically requires that documentation, there is no reason to keep them. Surveyors love to compare the strips printed with the documentation of defibrillator checks. Do the checks; destroy the strips.
There always seem to be questions about the requirements for medication security on the crash cart. CMS requires that medications be stored in a secure manner to prevent tampering, theft, or diversion in accordance with law and regulation. Since items on emergency carts are required to be immediately accessible, there is a balance between keeping the cart secure while making it “immediately accessible” in the event of an emergency. Considering the intended nature and use of emergency carts, organizations must balance security with the requirement that emergency medications and supplies are readily available when needed.
Securing your carts with a padlock or keycode may be counter-productive. While you are required to ensure the security of medication, use of a device that creates a delay or blocks immediate access could potentially lead a surveyor to interpret the cart as not immediately accessible, especially if an employee is unable to recall the code when asked to open the cart. If using a keycode, assure that all staff who may need access to emergency carts (including those floating to your unit) know the code. If codes are used, organizations are encouraged to use the same code throughout the hospital. This will ensure that staff who either work multiple areas or respond in an emergency will be able to immediately access the emergency cart.
Are plastic breakaway locks considered security? They are not “security”, but they are considered an appropriate device to allow the organization to detect tampering while allowing the medications to be immediately accessed in an emergency. Use of a breakaway tag with a numeric identification number is acceptable, as long as there is a defined process to monitor the integrity of the breakaway lock and track the numeric identification, i.e., checked daily and the cart is in a staffed area. There are a couple caveats; carts that are stored in areas not staffed 24/7 or in units that are temporarily closed must be stored in a secured or locked location. Additionally, if your cart contains a controlled substance, it must be locked.
What could trip you up in a survey? Here are the most commonly cited emergency cart findings:
  • Not performing daily checks and inspections according to the organization’s policy – especially in units not staffed 24/7. This includes documenting that a check was performed when the recorder strip attached or documented does not verify that a test was completed
  • Not performing defibrillator checks according to the manufacturer’s recommendations
  • Expired defibrillator pads or other expired equipment or medications
  • Concentrated magnesium stored without clear labeling that dilution is required prior to administration. Any concentrated electrolyte stored outside of the pharmacy must have precautions taken to prevent inadvertent misadministration
  • Expired ACLS or PALS guidelines. Organizations are not required to keep guidelines on emergency carts, but if you do, the most current guidelines must be available to staff
  • Drained batteries on equipment because the cart was not plugged into an outlet
  • Staff unable to demonstrate use of equipment and/or how to change from adult to pediatric use
Keeping your carts well prepared and employing systemized processes throughout the organization will assure that they will be both ready for use and survey-ready when needed to provide high-quality, safe emergency care.
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