Q: We have a battle going on at our hospital regarding whether cardboard boxes can remain in a pharmacy clean storage room. Some staff is saying the boxes must go. I thought that was only the case in an OR clean sterile room. In this situation, the pharmacy clean storage room is 1-hour fire rated. I guess this question will apply to all of our clean storage rooms in our hospital
A: You have two different standards at play, here. From a Life Safety Code point of view, you are compliant. Cardboard boxes are combustible, and having multiple cardboard boxes stored in a room requires the room to be maintained as a hazardous area. According to section 18.104.22.168 of the 2012 Life Safety Code, the room would have to be 1-hour fire-rated or be sprinklered. You say the room is 1-hour fire-rated, so you are compliant with the Life Safety Code. There is no other Life Safety Code requirement that would prevent the storage of cardboard boxes in that room.
However, as I said, there is another standard at hand here. From an Infection Control point of view, cardboard boxes used for shipment presents many problems:
The boxes are dirty. They have been riding in the back of trucks for days, and they have been sitting on receiving docks which is a very transient environment. These boxes are not acceptable from an Infection Control consideration to be stored in a clean environment, let alone a sterile environment.
The boxes may contain insects or vermin. In some cases, you have no idea where these boxes came from. Insects can make a home in the cardboard boxes and then be shipped to your facility. Vermin have been known to hide in a cardboard box and also be transferred to other places.
If left on the floor, the boxes may become wet. A wet cardboard box becomes soggy and falls-apart and leaves a trail of contaminants that provides a place for mold or mildew to grow.
While there may not be a specific standard in the accreditation organization’s manual, or a CMS CoP standard that prohibits cardboard shipping boxes from being stored in a clean environment (i.e. pharmacy storage room), it is generally understood that most surveyors and inspectors will cite an organization for doing so. This is due to the perceived Infection Control issues described above. They would typically cite the facility under a general duty standard that requires the organization to maintain a safe environment for their patients and staff.
My advice is to remove the cardboard shipping containers from the facility at the point where you receive them (i.e. receiving dock) and discontinue storing any paper or cardboard container on a floor that has the potential to be wet. Discuss this issue with your Infection Control specialist. I’m sure they have an opinion on cardboard shipping boxes.
Brad Keyes, CHSP, is the owner of KEYES Life Safety Compliance, and his expertise is in the management of the Life Safety Program, including the Environment of Care and Emergency Management programs.
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