| September 14, 1999
Members of Board of Directors
Board of Registration in Nursing
239 Causeway Street
Boston, MA 02114
Dear Board Members:
Thank you for providing me the opportunity
to comment on the Board's proposed regulations.
My name is Jane Doe. I am a registered nurse
with 12 years of experience in the emergency department. I
also have a clinical specialty in head trauma, coordinating
E.R. and in-hospital plans for patients with this diagnosis.
Working in an emergency department as you know, is never a
predictable setting. Thus, I need to share some practical
insight regarding the regulations, as they have been proposed
by the Board.
My most pressing concern is with the Standards
of Conduct at 2.03. I understand that regulation carries the
weight of law, and I am very concerned about number (39) regarding
the "Security of Controlled Substances". The proposed regulation
places legal responsibility on individual nurses to ensure
the security of "equipment and supplies" used in the administration
of controlled substances. In my busy emergency room, this
type of equipment is not kept under lock and key. Although
the Board may believe that maintaining the security of this
equipment is a good idea, the reality is that nurses do not
necessarily work within institutions that provide them with
systems to accomplish it.
The way the regulation is written, I would
have fallen below the Board's "Standard of Conduct for Nurses"
in the following example. As a new nurse working the night
shift in a large Boston hospital, I had responsibility for
the 15 acute postoperative patients rooming along the back
hall one night. My assigned medication cart was stocked with
a kardex, medications, IVs, assorted syringes and supplies.
I pushed the cart down the hall as I made my way into each
patient room. For infection control reasons, the medication
cart is not brought into individual patient rooms. After spending
15minutes with one patient, I returned to the cart to find
that all the syringes had been stolen off of it. There were
no security control systems on the medication carts.
Under the proposed regulation, I would have
violated a Board standard of conduct. As currently written,
I believe this regulation to be an unreasonable and unfair
expectation of licensed nurses. If the Board is interested
in providing a standard which tells nurses they will be held
responsible for that equipment and those supplies used by
that individual nurse in the administration of controlled
substances, it ought to say just that.
Thank you for your thoughtful consideration
of this letter.
Sincerely,
Jane Doe RN
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