Environment of Care

COMPLIANCE MANUAL

Thomas J. Huser, MS, CHSP

A Guide to the Joint Commission Standards

FOURTH EDITION

Environment of Care COMPLIANCE MANUAL

Thomas J. Huser, MS, CHSP

A Guide to the Joint Commission Standards

FOURTH EDITION

Environment of Care Compliance Manual: A Guide to the Joint Commission Standards, Fourth Edition, is published by HCPro, Inc.

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List of figures ..........................................................................................................................................vi

Dedication ............................................................................................................................................ viii

About the author .................................................................................................................................... ix

Preface .................................................................................................................................................... xi

Chapter 1: Strategies for the Environment of Care ............................................................................ 1

A Brief History of PTSM and EC Function ......................................................................................................2

The Joint Commission Today: What to Expect in the Upcoming Year.........................................................3

The Key to EC Compliance: Strong Team, Strong Plan ..................................................................................5

Chapter 2: Safety and Security ............................................................................................................. 7

2009 Environment of Care Scoring ...................................................................................................................8

EC.01.01.01: Minimizing EC Risks ..................................................................................................................10

EC.02.01.01: Managing Safety and Security Risks .........................................................................................12

EC.02.01.03: Smoking Prohibitions .................................................................................................................18

Survey Hot Spots ...............................................................................................................................................20

Chapter 3: Hazardous Materials and Waste ..................................................................................... 41

Definitions of “Hazardous Chemicals” and “Hazardous Waste” ..................................................................41

EC.02.02.01: Managing Hazardous Material and Waste ...............................................................................42

Survey Hot Spots ...............................................................................................................................................52

Contents

iv Environment of Care Compliance Manual, Fourth Edition© 2008 HCPro, Inc.

Contents

Chapter 4: Fire Prevention ................................................................................................................... 87

Survey Focus on Fire Safety, Buildings, Equipment, and Emergency Power ..............................................88

EC.02.03.01: Managing Fire Risks ...................................................................................................................89

EC.02.03.03: Conducting Fire Drills ...............................................................................................................93

EC.02.03.05: Maintaining Fire Safety Equipment, Features ..........................................................................96

Survey Hot Spots .............................................................................................................................................103

Chapter 5: Medical Equipment .......................................................................................................... 111

Documentation Must Be Detailed and Managed Well ...............................................................................112

EC.02.04.01: Managing Medical Equipment Risks ......................................................................................113

EC.02.04.03: Testing, Maintaining, and Inspecting Medical Equipment .................................................119

Survey Hot Spots .............................................................................................................................................121

Chapter 6: Utilities Management ...................................................................................................... 131

Utilities Management: Purpose and Scope ...................................................................................................131

EC.02.05.01: Managing Utility Risks .............................................................................................................132

EC.02.05.03: Emergency Power Sources .......................................................................................................139

EC.02.05.05: Testing, Inspecting, and Maintaining Utility Systems ..........................................................142

EC.02.05.07: Inspection, Testing, and Maintenance of Emergency Power ...............................................144

EC.02.05.09: Maintaining, Testing, and Inspecting Medical Gas, Vacuums .............................................149

Survey Hot Spots .............................................................................................................................................151

Chapter 7: Functional Environment .................................................................................................. 163

EC.02.06.01: A Safe and Functional Environment .......................................................................................163

EC.02.06.05: Design and Construction ........................................................................................................169

Survey Hot Spots .............................................................................................................................................171

Environment of Care Compliance Manual, Fourth Edition v© 2008 HCPro, Inc.

Contents

Chapter 8: Staff Competency ............................................................................................................. 173

EC.03.01.01: Responsibilities and Roles in the EC ......................................................................................173

Survey Hot Spots .............................................................................................................................................175

Chapter 9: Demonstrating Implementation of Care ....................................................................... 177

Leadership’s Role in EC ...................................................................................................................................177

EC.04.01.01: Organizational Monitoring ......................................................................................................178

EC.04.01.03: Recognizing and Resolving Areas of Concern ......................................................................185

EC.04.01.05: Improving the EC ......................................................................................................................186

Survey Hot Spots .............................................................................................................................................187

Chapter 10: Updated Survey Hotspots ............................................................................................. 195

Hot Spots Checklist .........................................................................................................................................196

Appendix: Using the Files on Your Environment of Care CD-ROM ............................................. 199

Management Plans ...........................................................................................................................................199

Chapter Files ....................................................................................................................................................200

vi Environment of Care Compliance Manual, Fourth Edition© 2008 HCPro, Inc.

Chapter 2

Figure 2.1: The SOA Form ................................................................................................................................21

Figure 2.2: Blank Witness Statement Form.....................................................................................................21

Figure 2.3: Blank Supplement Report ..............................................................................................................22

Figure 2.4: Injury Information Sheet ...............................................................................................................23

Figure 2.5: Fall/Injury Report ...........................................................................................................................24

Figure 2.6: Security Activity Log ......................................................................................................................26

Figure 2.7: Elopement/AWOL Report Form ..................................................................................................28

Figure 2.8: Security Incident Report Form .....................................................................................................30

Figure 2.9: Plans and Policies for Worker Safety ............................................................................................31

Figure 2.10: Smoking Intervention Form ........................................................................................................32

Figure 2.11: Security Department Statement of Purpose ..............................................................................33

Figure 2.12: Firearms and Weapons Policy .....................................................................................................35

Figure 2.13: Forensic Patient Policy/Procedure..............................................................................................37

Figure 2.14: Extra Patrol Sign-In Form ...........................................................................................................39

Figure 2.15: Narcotics Discrepancy Report Form ..........................................................................................40

Chapter 3

Figure 3.1: Chemical Response Plan ...............................................................................................................55

Figure 3.2: Hazard Communication Program ................................................................................................65

Figure 3.3: Asbestos Management Policy ........................................................................................................67

Figure 3.4: Hazardous Waste Policy.................................................................................................................71

Figure 3.5: Infectious Waste Policy ..................................................................................................................75

Figure 3.6: DOT Hazmat Transportation Security Plan ................................................................................78

Figure 3.7: Alarm/Odor Response Form.........................................................................................................85

List of figures

Environment of Care Compliance Manual, Fourth Edition vii© 2008 HCPro, Inc.

List of figures

Chapter 4

Figure 4.1: Life Safety System Preventative Maintenance Grid ..................................................................104

Figure 4.2: Fire Alarm Response Record ......................................................................................................105

Figure 4.3: Fire Drill Evaluation Form ..........................................................................................................106

Figure 4.4: Fire Watch Log ..............................................................................................................................108

Figure 4.5: Fire Watch Report Form ..............................................................................................................109

Figure 4.6: Life Safety Systems Shutdown Advisory Form ..........................................................................110

Chapter 5

Figure 5.1: Medical Equipment Safety Policy ...............................................................................................123

Figure 5.2: Preventive Maintenance of Electronic Equipment ...................................................................124

Figure 5.3: Vendor Representatives Policy ....................................................................................................126

Figure 5.4: Safe Medical Device Reporting Policy .......................................................................................127

Chapter 6

Figure 6.1: Construction Risk Assessment Form .........................................................................................153

Figure 6.2: Risk Criteria for Individual Types of Equipment .....................................................................160

Figure 6.3: Sample Emergency Generator Test Log/Report ........................................................................161

Chapter 9

Figure 9.1: Employee Environment of Care Survey .....................................................................................188

Figure 9.2: Hazard Surveillance Discrepancy Checklist ..............................................................................189

Figure 9.3: Hazard Surveillance Discrepancy Report ..................................................................................191

Figure 9.4: Safety Inspection Report .............................................................................................................192

Figure 9.5: Annual EOC Committee Reporting Grid .................................................................................193

viii Environment of Care Compliance Manual, Fourth Edition© 2008 HCPro, Inc.

To Ray, gone but not forgotten;

and to my wife, Linda, for her support and understanding

T.J.H.

Dedication

Environment of Care Compliance Manual, Fourth Edition ix© 2008 HCPro, Inc.

Thomas J. Huser, MS, CHSP

Thomas J. Huser, MS, CHSP, brings more than 23 years of experience to bear on his position as safety coor-

dinator, Emergency Management and Hazardous Materials, with Clarian Health in Indianapolis. With expe-

rience ranging from hospital management to emergency preparedness planning to fire safety instruction,

Huser brings both administrative and real-world knowledge to his work in healthcare safety.

A certified master-level Certified Healthcare Safety Professional (CHSP), Huser is well versed in Environ-

ment of Care chapter sections, including safety, security, hazardous materials and wastes, fire prevention,

medical equipment, and the functional environment. Huser also has expertise in Emergency Management

and Life Safety chapters of The Joint Commission’s (formerly JCAHO) Comprehensive Accreditation Manual

for Hospitals.

Before joining Clarian Health, Huser worked for St. Vincent’s Hospital in Indianapolis as the manager of

health and safety for the hospital’s organizational safety department and was a consultant for the St. Vincent

Health affiliated facilities. A volunteer firefighter for the past 25 years, Huser is a certified National Fire

Protection Association (NFPA) fire instructor II/III and a state-certified hazardous materials instructor. He

is the healthcare representative on the Marion County, IN, Local Emergency Planning Committee and

serves as a hospital representative on numerous other planning groups.

Huser writes for Briefings on Hospital Safety (HCPro, Inc.) and the Journal of Healthcare Security. He has

given presentations at such gatherings as the Ascension Health Safety Conference, the NFPA World Fire and

Safety Conference, and the National Earthquake Conference.

Huser holds a master’s degree in health and safety management from Indiana State University, a bachelor’s

degree in business administration from Indiana Wesleyan University, and an associate’s degree in applied

fire science from Ivy Tech State College of Indiana.

About the author

Environment of Care Compliance Manual, Fourth Edition xi© 2008 HCPro, Inc.

In 2002, when I set out to write the first edition of this book, my goal was to help safety directors, plant

managers, security managers, accreditation managers, The Joint Commission (formerly JCAHO) survey

coordinators, operations managers, and others in facility management to assess where they stood in compli-

ance with the Environment of Care (EC) chapter set out by The Joint Commission. I wanted to help you

better understand The Joint Commission’s expectations and to obtain support for fulfilling these obligations.

I reviewed all of the sections of the EC, including safety, security, hazardous materials and wastes, fire pre-

vention, medical equipment, utilities, and the functional environment, a relatively new chapter requiring

that facilities prove they have put into practice all of the aforementioned sections and that they are working

for continuous improvement. To comply with the EC, responsible personnel also must be familiar with rec-

ommendations and regulations from the National Fire Protection Association (NFPA) and the Occupational

Safety and Health Administration (OSHA). As such, the book also discussed how the NFPA and OSHA

requirements have become part of The Joint Commission requirements. I talked about the history of the EC

and how it had evolved since 1995, and I structured the book so that it was as easy to read and understand

for the veteran safety officer as for the novice newly involved with the EC.

I set out plans and tools meant not only to help you improve your compliance but also to help you attain

compliance in areas where your facility might be deficient. In writing the book, I called upon experiences I

gained in the military and in the fields of firefighting, law enforcement, and healthcare.

With this fourth edition, my goals are the same. I will:

• Deliver a plain-English interpretation of The Joint Commission requirements for the EC

• Provide sample management plans for each of the six sections (available on the accompanying

CD-ROM, courtesy of Safety Management Services, Inc.)

• Update information to reflect changes in 2009

Preface

xii Environment of Care Compliance Manual, Fourth Edition© 2008 HCPro, Inc.

Preface

The Purpose of this Book

The intent of this manual is to assist the leaders of an organization, as well as those who are responsible for

compliance with the EC chapter. Depending upon the size of your organization, this audience could include

anyone from the CEO to any employee responsible for compliance. This manual is to be shared among

members of the organization to help them both understand the expectations of The Joint Commission and

obtain support in procuring funds to fulfill those obligations.

As you review this manual, you will notice that aspects of this chapter affect everyone within the facility.

The safety of patients, visitors, and employees rests upon compliance with this section. Indeed, compliance

with this chapter can be a matter of life and death.

Remember, the foundation of each program is the management plan discussed in Chapter 1.

How to Use this Book

As a safety officer, I know that managers need a guide to The Joint Commission standards that will serve as

a sourcebook for up-to-date EC information while also functioning as a signpost toward future changes.

Today, this preparation must be done as the facility also prepares for unannounced surveys. The EC process

is a team effort that requires support from everyone, from the board of directors to the employees. The EC

also extends past the walls of the hospital to all locations the hospital owns, including those that do not

involve inpatient care.

As I present commentary on the revisions to the management plans, I also talk about what I think The Joint

Commission expects facilities to do regarding management drills and, if the changes are approved, I offer

advice on how the changes will affect facilities.

Chapter 1 offers an overview of the EC.

Chapters 2–6 detail each EC management plan, from planning through implementation.

Chapter 7 discusses the environment in which the patient actually stays. The Joint Commission is taking a

more subjective look at this area to ensure that patient care extends beyond just medical aspects to include

the environment in which patients will be staying.

Environment of Care Compliance Manual, Fourth Edition xiii© 2008 HCPro, Inc.

Preface

Chapter 8 details the requirements for compliance as they relate to your staff and licensed independent

practitioners who work within your EC.

Chapter 9 reviews methods for providing documentation that your organization has implemented the five

management plans. This chapter also discusses how your organization can measure outcomes and use this

information to show continuous performance improvement.

Chapter 10 assesses the latest “hot spots” in the EC chapter, including the pitfalls suffered by other organi-

zations and what surveyors will be looking for when they call. This chapter, as well as the “survey hot spots”

listed at the end of each chapter, has been updated to reflect changes in survey emphasis.

Your challenge: Create a solid EC program, facilitywideCreating an effective EC program can be challenging. Given that, it should not be undertaken by just one

or two staff members.

My hope is that this book will make the EC process easier to understand so that you can comply with

The Joint Commission’s standards. I wish you the best of luck with your next survey.

Those of you who read the earlier editions of this book may note a similarity in wording.

As this is a guidebook, such similarity is expected; however, do not assume that the

information is unchanged. Facts and conditions regarding the standard or news may have

been altered slightly, and it is up to you to note every detail (your surveyor will!).

TIP

Environment of Care Compliance Manual, Fourth Edition �© 2008 HCPro, Inc.

In the evolution of the Environment of Care (EC) chapter, The Joint Commission is taking a closer look at

methods of survey preparation and reporting, as well as the integration of personnel in meeting accredita-

tion imperatives. Recent changes affect standards for patient safety, peer and performance reviews, and staff

competency. In this fourth edition, I have renamed this chapter to include the word strategies to acknowl-

edge how The Joint Commission’s (formerly JCAHO) changes to the EC serve as a strong function in help-

ing readers create a plan of action.

The goal of EC management, according to The Joint Commission, is to “provide a safe, functional, support-

ive, and effective environment” to ensure quality, safety, and care of buildings, equipment, and people. As

you read through this manual, you will see that this is the most aggressive overhaul of the EC chapter since

its creation in 1995. Not only has the numbering changed to reflect that used by other code organizations,

but the life safety portion of the fire safety section has been removed from the EC chapter, as has emergency

management. Both have been placed into their own chapters within the accreditation manual to demon-

strate their importance to leadership. These chapters are covered in HCPro, Inc.’s upcoming Life Safety

Compliance Manual and Emergency Management Compliance Manual, respectively. You will note that there is

still a fire prevention section of the EC manual; however, compliance also will be tied to elements of the new

life safety chapter.

CH

APT

ERStrategies for the Environment of Care1

Chapter 1

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A Brief History of PTSM and EC Function

Before 1995, The Joint Commission separated the Plant Technology Safety Management (PTSM) require-

ments into four sections: utilities and preventive maintenance; fire prevention; disaster preparedness (now

known as emergency management); and safety, which included the subcategory of hazardous materials and

infectious waste. These standards were independent of each other and could function in silos, or indepen-

dent units. Thus, the person in charge of the utility program did not necessarily have to share information

with the person heading the safety program.

This changed in 1995, under the new direction of Ode Keil, The Joint Commission’s PTSM director. Keil’s

responsibilities involved overseeing and creating surveys and standards, which comprised standards devel-

opment, survey process development, and surveyor education. Under Keil, The Joint Commission imple-

mented a radical change: the alteration of the PTSM to the EC chapter. The changes included the following:

Expansion of EC sectionsThe four PTSM chapters were expanded to eight sections: safety, security, hazardous materials and wastes,

emergency management (formerly disaster preparedness), fire prevention, medical equipment, utilities man-

agement, and the newest section, functional environment (formerly appropriate environment). That final

chapter requires facilities to document adherence to the aforementioned requirements and demonstrate

efforts toward continuous improvement. This would include employee orientation and education, drills (to

ensure knowledge and readiness), and testing and maintenance of operational components. The new section

requires regular reporting, such as a comprehensive annual report to the board of directors, and the board’s

approval of performance improvement (PI) initiatives.

Continued emphasis on emergency managementThe EC’s continued emphasis on emergency management came at a time when these issues were brought to

mainstream attention. Although it is generally understood that hurricanes Katrina and Rita did not initiate

the revision of EC.4.20—the prevailing belief is that changes were in development for years—the catastrophic

damage and subsequent controversy surrounding response certainly contributed to a new examination of

the emergency management section and, to a lesser degree, utilities management. Because of the increasing

importance of emergency preparedness in our world today, The Joint Commission has completely removed

the emergency management section from the EC chapter and placed it in its own chapter of the compliance

manual. Because of this change, I will not discuss the expectations for emergency management in this manual.

Strategies for the Environment of Care

Environment of Care Compliance Manual, Fourth Edition �© 2008 HCPro, Inc.

Continued emphasis on patient safetyThe hurricanes also brought to the fore concerns about patient safety from all sides and from all sources—

from extreme natural disasters to the more common train derailments, bus crashes, and subway fires.

Adding to these enduring threats are threats of infectious diseases that were thought to have been either

eliminated or reduced, such as tuberculosis (in 2005, a surgical intern at a Boston hospital treated patients

for months after testing positive for tuberculosis); community-acquired methicillin-resistant Staphylococcus

aureus (CA-MRSA) infections; healthcare-associated infections (HAI); recent outbreaks of mumps; and the

fear of avian flu. The increase in domestic manufacturing of illegal drugs has resulted in injuries and fires

related to the manufacturing of methamphetamine. The new imperative is safety. Its corollary is constant

improvement, which is one reason for the creation of the fourth edition of this manual.

Changes in method of surveyWith the implementation of the EC in 1995, a major shake-up occurred in the way hospitals were surveyed.

Higher expectations were placed on medical facilities to meet EC demands. Cooperation with other areas of

the hospital became necessary to ensure that the required training was completed and to determine the com-

petency of the staff. Traditional requirements, such as fire drills, disaster drills, and compliance with stan-

dards and codes set out by the Occupational Safety and Health Administration (OSHA) and the National

Fire Protection Association (NFPA), remained in place. Added to the new and updated requirements is a

new treatment of “voluntary” as mandatory, in areas involving, for example, workplace antiviolence pro-

grams and the filing of the Statement of Conditions (SOC). The SOC requires hospitals to conduct a thor-

ough inventory regarding their compliance with the NFPA Life Safety Code®, as well as documentation of

their deficiencies and repairs. Both the NFPA and OSHA codes and standards have become part of The Joint

Commission’s requirements.

The Joint Commission Today: What to Expect in the Upcoming Year

With the 2009 overhaul of the EC chapter and the addition of the life safety and emergency management

chapters, there is a lot to keep an eye on in the coming year, including the following:

Change in requirements for emergency generator tests: EC.6.04.07 (previously EC.7.40), which deals with test-

ing of emergency power systems, underwent revisions on January 1, 2007. The big change was a new

requirement that hospitals test their generators for a four-hour run at least once every 36 months.

Chapter 1

� Environment of Care Compliance Manual, Fourth Edition© 2008 HCPro, Inc.

Surveyors’ continued crackdown on EC.2.01.04 (previously EC.1.10): Last year, according to The Joint Com-

mission, one out of every 10 hospitals received a citation under the old EC.1.10, the standard mandating

that hospitals should respond to safety risks.

Expansion of The Joint Commission’s National Patient Safety Goals: The addition of this section will affect the

EC directly. It is important for the safety committee to remain up to date on these goals and to coordinate

with other departments to ensure continuous compliance. Look for this section to change as The Joint

Commission continues to add new requirements to this program.

Continuation of unannounced surveys established in 2006: Facilities received no notice of their survey date

prior to the start of the survey, as The Joint Commission said in the 2006 Comprehensive Accreditation

Manual for Hospitals. Exceptions included initial surveys (for organizations undergoing their first Joint

Commission survey) and locations in which it would not be logical or feasible to conduct an unannounced

survey, such as prisons and Department of Defense facilities.

Tracer surveying: The last change in the current evolutionary trail is the advent of the tracer method of sur-

veying. Previously, units were surveyed methodically and individually. In 2004, however, surveys began to

use the tracer method, in which the surveyors chose patient records and traced a patient’s stay through the

facility. If a patient arrived in the emergency department (ED), had surgery, and was then admitted, the sur-

veyor would begin in the ED and follow the data flow right on through to the facility’s discharge of the

patient. During the tracer, the surveyor also would look for other problems—including any that were part of

the EC. With the new tracer method, you never know where a surveyor will go, so it is vital that the entire

facility be prepared for a visit. However, patient care is not the only place tracers can be used; for example,

tracers can also track a system, such as tracing hazardous materials from the loading dock, through staff

use, and then disposal.

Performance improvement: PI is the cornerstone of The Joint Commission survey, including the EC. The

Joint Commission wants to see not only that you are meeting the basic requirements of the chapter but also

that you are improving upon them. The entire PI section in The Joint Commission accreditation manual

guides you through what is required. (Read more on how this is done in Chapter 9 of this manual.)

Strategies for the Environment of Care

Environment of Care Compliance Manual, Fourth Edition �© 2008 HCPro, Inc.

The Key to EC Compliance: Strong Team, Strong Plan

Successful EC compliance hinges on a well-planned, well-executed team approach that has the support of

the administration and the staff.

The planEach section of the EC requires a management plan, which gives the surveyor an overview of the way the

facility is addressing the requirements of each standard. All management plans need to be identical in format

to show the surveyor that the people responsible for the EC chapter perform as a team and communicate

well with each other. This also shows the surveyor what processes your facility uses to ensure compliance

with each section of the EC chapter. On the CD-ROM accompanying this manual are completely updated

management plans for each of the sections.

The teamThe EC chapter should not be administered by only one or two people, especially with the advent of the

unannounced survey. One facility I know of has chapter facilitators who are responsible for ensuring com-

pliance with the chapter. The facility also has support personnel who assist in ensuring compliance. For

example, the director of facilities and security is responsible for the utilities management section. He has

support from various managers and supervisors and is also co-facilitator for the chapter. Another example

is the director of clinical engineering. Numerous staff members support the reporting and activities in the

maintenance of this section. Because of the size of this facility, 15 people directly assist the chapter facilita-

tors. And this overview does not begin to encompass members of the support staff, who conduct the day-

to-day activities related to the EC.

The number of people on your team will vary depending upon the size of your facility. Some suggested team

members might include people from senior management, facilities/engineering services, safety, security (if

applicable), clinical engineering/biomedical, infection control, nursing administration, and off-site loca-

tions, along with any “facilities” within your facility.

Make sure that all players come together on a regular basis, not just before a survey. They must be familiar

with their roles during a survey and be comfortable discussing issues and processes with the surveyor.

Holding regular meetings also allows new members to become familiar with the survey process and to see

how your facility responds to survey questions. The week before a survey is not the time to get everyone

together for the first time—rather, such meetings should be part of the ongoing EC process.

Chapter 1

� Environment of Care Compliance Manual, Fourth Edition© 2008 HCPro, Inc.

The supportThe team can’t make it happen without support from the top brass. The success of the EC program depends

upon the support of senior management, up to and including the board of directors. This support is needed

for many reasons, the most important being financial support—when compared with other Joint Commission

chapters, the EC chapter is likely the most expensive with which to comply. However, it is not an overstate-

ment to say that lives depend upon compliance with this chapter.

If you have any doubts as to the potential for disaster if compliance is not maintained, simply look at recent

history. People are still dying in fires in healthcare facilities; people still die from inhalation of improper

gases through the central gas distribution system. Imagine what would happen to patients on life support if

your facility lost power and the emergency generators failed. Likewise, the ramifications of improper main-

tenance of a defibrillator could be devastating. The Joint Commission requires that the board of directors be

informed of all such deficient areas and of all actions being taken to correct them.

It is sometimes difficult to garner the support of leadership, especially in today’s healthcare environment.

Funds are tight, and it is often difficult to justify spending money for a new generator when you have never

had one fail—especially when a physician requests funding for a revenue-producing project.

The EC chapter deals in the area of “what-ifs”—what if something goes wrong? You might have a plan in

place to deal with the what-ifs of the world, but such projects are extremely hard to get approved—even if

your facility has experienced similar failures or disasters. The “lightning never strikes twice” mindset shows

itself here.

There is no clear-cut formula that will guarantee funding for your projects. It takes a time-proven, well-

established working relationship between senior management and your EC team working on all levels to

make your program succeed.