Archived. DPC: Corrective Action. Quality Manual

Similar documents
Procedure for Corrective Action and Non-conformities

Research Audits PGR. Effective: 12/04/2013 Reviewed: 12/04/2015. Name of Associated Policy: Palmetto Health Administrative Research Review

Corrective and Preventive Action

5/1/2017 THE BEST DEFENSE IS A GOOD OFFENSE OBJECTIVES. Preparing for a Home Health Medicare Recertification Survey

POCKET GUIDE TO THE ACCREDITATION STANDARDS (ISO 15189:2014)

FINANCIAL CONFLICT OF INTEREST POLICY Public Health Services SECTION 1 OVERVIEW, APPLICABILITY AND RESPONSIBILITIES

COMPLIANCE WITH THIS PUBLICATION IS MANDATORY

University of Michigan Policy On Investigating Noncompliance and Animal Welfare Concerns

PART ENVIRONMENTAL IMPACT STATEMENT

Supervisor s Position No New Quality Improvement Lead Director Professional Standards

A GUIDE TO THE CENTRAL BANK S ON-SITE EXAMINATION PROCESS

ORTHODONTIST. Scheduling Coordinator Manual

Clinical Research Seminar

Standard Operating Procedure (SOP) Research and Development Office

SHEC CORPORATE MANAGEMENT SYSTEM STANDARD

St Brendan s College RTO 30349

Study Monitoring Plan Template

CORRECTIVE ACTION REQUEST

EFFECTIVE ROOT CAUSE ANALYSIS AND CORRECTIVE ACTION PROCESS

Procedures and Conditions of Building Consent Authority Accreditation

University of South Carolina. Unanticipated Problems and Adverse Events Guidelines

SOP Problems and Adverse Events, Record and Report

UNIVERSITY OF MISSISSIPPI MEDICAL CENTER PATIENT SAFETY PLAN

UNIVERSITY OF TENNESSEE HEALTH SCIENCE CENTER INSTITUTIONAL REVIEW BOARD REPORTING UNANTICIPATED PROBLEMS INCLUDING ADVERSE EVENTS

BAY-ARENAC BEHAVIORAL HEALTH AUTHORITY POLICIES AND PROCEDURES MANUAL

MANAGEMENT OF PROTOCOL AND GCP DEVIATIONS AND VIOLATIONS

QUALITY POLICY MANUAL. Revision: 05 Author: T. Joseph Issue Date: 6/6/2010 Approved By: Dr S. King

Provider Rights. As a network provider, you have the right to:

NOTE: The first appearance of terms in bold in the body of this document (except titles) are defined terms please refer to the Definitions section.

Workplace Safety and Health Management System Administration

IAF Guidance on the Application of ISO/IEC Guide 61:1996

HIC Standard Operating Procedure. For-Cause Audits of Human Research Studies

Complaint and Appeal Policy

Accreditation Procedure

Request for Proposal PROFESSIONAL AUDIT SERVICES. Luzerne-Wyoming Counties Mental Health/Mental Retardation Program

BIMO SITE AUDIT CHECKLIST

Town of Derry, NH REQUEST FOR PROPOSALS PROFESSIONAL MUNICIPAL AUDITING SERVICES

ED0028 Adverse event, critical incident, serious issue, and near miss procedure

BOARD OF FINANCE REQUEST FOR PROPOSALS FOR PROFESSIONAL AUDITING SERVICES

IACUC Policy 09: Researcher Non-Compliance

Educational Visits Policy

Building Consent Authority Accreditation - Procedures and Conditions

POLICY NAME POLICY # Sentinel, Adverse Event and Near Miss. CSP Reporting and Investigation

Cognitive Level Certified Professional in Patient Safety Detailed Content Outline Recall. Total. Application Analysis 1.

Post-incident actions

A. Occupational Safety and Health Act of 1970 (OSH Act of 1970), Section 19, Federal Agency Safety Programs and Responsibilities.

ADMINISTRATIVE POLICY & PROCEDURE PATIENT SAFETY PLAN

Delegation Agreement Between and. Minnesota Department of Health

REQUEST FOR PROPOSALS: PROFESSIONAL AUDITING SERVICES

UNIVERSITY OF ROCHESTER MEDICAL CENTER BILLING COMPLIANCE PLAN

ALLIED PHYSICIAN IPA ADVANTAGE HEALTH NETWORK IPA ARROYO VISTA MEDICAL IPA GREATER ORANGE MEDICAL GROUP IPA GREATER SAN GABRIEL VALLEY PHYSICIANS IPA

POLICY & PROCEDURE FOR INCIDENT REPORTING

Incident Reporting and Investigations. Mary Bolbrock, RN MSN Ann Marie McDonald, RN EdD

The AASHTO Accreditation Program. Procedures Manual for the Accreditation of Construction Materials Testing Laboratories.

Public Input for Changes to Reportable Events Policy

Londonderry Finance Department

INCIDENT INVESTIGATION AND REPORT PROGRAM

IDENTIFICATION AND MANAGEMENT OF NONCONFORMITIES

SPONSOR-INVESTIGATOR ROLES & RESPONSIBILITIES IN DEVICE TRIALS

TACOMA POLICE DEPARTMENT

Complaints, Feedback and Appeals Management

DOD MANUAL DOD ENVIRONMENTAL LABORATORY ACCREDITATION PROGRAM (ELAP)

PRIVACY BREACH MANAGEMENT GUIDELINES. Ministry of Justice Access and Privacy Branch

CHATS COMMUNITY & HOME ASSISTANCE TO SENIORS POLICIES & PROCEDURES. APPROVED BY: Chief Executive Officer NUMBER: 3-D-24

U.S. Department of Energy Office of Inspector General Office of Audit Services. Audit Report

THIS AGREEMENT made effective this day of, 20. BETWEEN: NOVA SCOTIA HEALTH AUTHORITY ("NSHA") AND X. (Hereinafter referred to as the Agency )

Guideline for the notification of serious breaches of Regulation (EU) No 536/2014 or the clinical trial protocol

SUPERVISION OF CHILDREN POLICY

The Greenville Hospital System Office of Research Compliance and Administration HRPP Policies and Procedures

NAVSEA STANDARD ITEM CFR Part 61, National Emission Standards for Hazardous Air Pollutants

ADVANCED PLASTIC SURGERY, PLLC. NOTICE OF PRIVACY PRACTICES

QMP-LS: A Canadian Regional EQA Program How Labs Get In and Out of Trouble in Ontario

Preventing Medical Errors

Referral Laboratories

2. This SA does not apply if the entity does not have an internal audit function. (Ref: Para. A2)

REQUEST FOR PROPOSALS: AUDIT SERVICES. Issue Date: February 13 th, Due Date: March 22 nd, 2017

Tomoko OSAWA, Ph.D. Director for GCP Inspection Office of Conformity Audit PMDA, Japan

HAEMOVIGILANCE POLICY

THE CDDO SERVING COFFEY, OSAGE AND FRANKLIN COUNTIES Policies and Procedures

ACCOMPLISHMENTS: What was done? What was learned?

Movember Clinician Scientist Award (CSA)

Reaccreditation Introduction to the Requirements and Process. February 9, 2017

Helping physicians care for patients Aider les médecins à prendre soin des patients

POLICY: Conflict of Interest

Problem Solving Tools

LOS ANGELES COUNTY SHERIFF S DEPARTMENT

AGENCY FOR PERSONS WITH DISABILITIES OFFICE OF INSPECTOR GENERAL ANNUAL REPORT JULY 1, 2013 JUNE 30, 2014

ADVANCED MANUFACTURING FUTURES PROGRAM REQUEST FOR PROPOSALS. Massachusetts Development Finance Agency.

BestCare Ambulance Services, Inc.

Office of the Vice Chancellor for Research Supervisory Responsibilities of Clinical Investigators

REQUEST FOR PROPOSALS. For: As needed Plan Check and Building Inspection Services

Midwest Alliance for Patient Safety Patient Safety Organization Getting Started with a PSO. An Illinois Hospital Association Company

NIJ DNA GRANT SUMMIT Grant Progress Assessment Program. Patricia Kashtan Program Operations Specialist

HSQF Scheme HUMAN SERVICES SCHEME PART 2 ADDITIONAL REQUIREMENTS FOR BODIES CERTIFYING HUMAN SERVICES IN QUEENSLAND. Issue 6, 21 November 2017

INJURY AND ILLNESS PREVENTION PLAN (IIPP) October 2015

University of Maryland Baltimore. Radiation Safety Procedure

Event Reporting System Reporter s Guide

Health Management Information Systems: Computerized Provider Order Entry

Successful FDA Inspections at Investigative Sites for Clinical Trials of Drugs and Biologics

NRC INSPECTION MANUAL STSB

Transcription:

actions 4.9.2 Levels of nonconformity 4.9.1.c 4.9.1.d 4.11. Laboratories may experience technical or administrative nonconformities. These occurrences can be adverse to the quality of the work product and/or the integrity of evidence. Nonconformities are defined as Level I or II, depending on the impact. The level of nonconformity will be considered in determining the course of action and root cause analysis. When there is doubt about the laboratory s continued compliance of policies and procedures or that non-conforming work will continue, a action will be initiated. The purpose of the action is to identify the root cause of a problem and implement the best solution to prevent reoccurrence. The ultimate goal of this process is to preserve and improve the level of service to the customer. Level 1 (Major Discrepancy): Appropriate laboratory management must be notified immediately of the problem in order to start the action process and, if necessary notify the customer and recall the work. The action process begins by first identifying the root cause of the problem. Once the root cause is determined the problem can be corrected and a solution established in order to prevent a reoccurrence. Level 1 nonconformities generally: Are unexpected. Require an investigation to determine their root cause. Require an intensive action with extensive documentation. Have compromised the quality of work product and/or the integrity of evidence. Page 1 of 6

Levels of nonconformity (continued) 4.9.1.c 4.11. actions for Level 1 nonconformities 4.9.1.a 4.9.1.e 4.9.1.b Level 2 (Minor Discrepancy): actions in these situations are routine and may occur during the day-to-day laboratory operations. The cause of the nonconformance does not, to any significant degree affect the fundamental reliability of the work product of the laboratory or the integrity of evidence. Level 2 nonconformities generally: Are foreseeable. Have a clear immediate cause. Can be addressed by a simple action, which can be documented within existing records, case notes, or technical/administrative review forms. If addressed properly, will not in any way compromise the quality of work or integrity of the evidence. Any employee who identifies a potential Level 1 nonconformity shall inform their immediate supervisor as soon as possible. If the nature of the nonconformity is severe enough, it will be necessary to verbally notify the Laboratory Director and as soon as possible. If the nonconformity is related to casework or a procedure, the supervisors, the Laboratory Director, and the DNA Technical Lead have the authority to halt (or resume) work, stop the release of reports, issue amended reports, notify customers, request the return of evidence, and implement any necessary short-term response. See DPC: Problems with Procedures and/or DPC: Problems with Casework for additional information. Level 1 actions will typically include a supervisor, the Quality Manager, the Laboratory Director, and the DNA Technical Lead (if appropriate) in addition to other personnel involved when investigating the cause. Page 2 of 6

actions for Level 1 nonconformities (continued) 4.11.2 actions for Level 2 nonconformities Root Cause of a Level 1 nonconformity: Root cause may identify multiple contributing factors for the nonconformity, but there is typically only one underlying cause. In order to define the problem the following will need to be considered: What happened, what equipment, what method? When did it occur-date and time? Where did it occur and during what process or procedure? How much, how often? How many times did the incident occur? How many cases affected? Impact to the laboratory s goals, customer, work product, and performance measures. Who was involved? Disclosure of a Level 1 Non-compliance to ASCLD/LAB-International: The Laboratory Director shall notify the ASCLD/LAB-International Executive Director within 0 calendar days of determining that a Level 1 noncompliance has occurred. The summary report will include a summary of the occurrence(s) and a statement of actions taken or that plan to be taken by the laboratory. The report will also include: Root Cause Analysis of the problem Who may be impacted by the occurrence Information regarding notification of those who are potentially impacted Appropriate action to correct or eliminate the cause of the occurrence Level 2 nonconformities are addressed by staff. These types of nonconformities are minor deviations from protocol or customer requirements. All level of staff members have the responsibility to identify and address this level of action. Once a staff member has identified an issue, they should bring it up to the appropriate Unit Supervisor. Page of 6

Examples of action situations Filling out the action request form Analyst errors or system errors (proficiency/casework/competency) would likely be Level 1 Initiated by the - First Signature Assigned to the supervisor or the DNA Technical Lead (if appropriate) - Second Signature Final Signature by the Laboratory Director Procedural Errors can be level 1 or level 2 Initiated by an analyst, the supervisor, or the First Signature Assigned to the supervisor or the DNA Technical Lead (if appropriate) Second Signature Final Signature by the Laboratory Director Audit can be level 1 or level 2 Initiated by the auditor First Signature Assigned to the unit supervisor or the DNA Technical Lead (if appropriate) Second Signature Final signature by the Laboratory Director The initiator of the Action Request form (CAR) fills out the Finding section of the form. The initiator and assigned individual investigate the cause analysis. The assigned individual fills out the Cause Analysis and Action Plan in the Action Plan section. The Action Plan Approved By and Action Due By are filled out by the or DNA Technical Lead (if appropriate). NOTE: All Action Request forms must be completed within 90 calendar days of the initiation date. The Laboratory Director may extend the due date as necessary and will notify all appropriate parties via email. After the action is implemented, the initiator fills out the Action section. Page 4 of 6

Filling out the action request form (continued) Implementing a course of action 4.11. 4.11.4 After the nonconformance has been addressed and measures are put in place to prevent reoccurrence, the initiator will sign followed by the assigned individual. The Laboratory Director signs the Action Request after all of the steps have been satisfied, the action plan is approved, and the action is complete. A course of action may involve retraining with emphasis on the correct or improved method to be used by the analyst. The retraining process may include input from the supervisor, the trainer, the DNA Technical Lead (if appropriate), and the Laboratory Director. The course of retraining must be broad enough in scope to Encompass the problem at hand Direct the analyst to acceptable levels of quality casework A competency test must be successfully completed by the analyst at the completion of retraining (see AQR: Competency Testing in the Quality Manual). Following a action and for a period of time determined by the supervisor, the supervisor will closely monitor the casework of the analyst. This may entail Observation by the supervisor or a peer analyst Re-examination of work by a peer analyst Page 5 of 6

, Continued Dispute resolution Special audits 4.11.5 There may be times when the analyst and peer group do not agree as to the form or extent of the change in procedure required. If this occurs, the supervisor should attempt to facilitate a resolution. There may be times when those involved in the problem review process do not agree as to the form or extent of the action required. Disputes that cannot be settled are brought by the supervisor to the Laboratory Director for resolution. A special discipline audit may be warranted when the findings of nonconformity or departures from procedures indicates a significant problem within the discipline. The laboratory will ensure that the scope of the audit is within the appropriate areas of activity. Special audits will be conducted as described in Quality Audits, located in the. Page 6 of 6