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Corrective
Actions Submitted to OLA
by:
Julie Coffey and Linda Crawford
Introduction
The Ontario Laboratory Accreditation (OLA) program was
implemented in 2003, and to date 114 of Ontario’s 242 licensed
laboratories have been assessed. During a peer assessment visit, a team of
assessors seeks to confirm that laboratories conform to the OLA
requirements, which are based on the ISO 15189:2003 standard known as
CAN/CSA Z-15189-03 Medical laboratories—Particular requirements for
quality and competence. At the conclusion of the assessment, the team
provides a verbal summary of their findings, including all major and minor
non-conformances assessed. Within 30 days of the assessment, the
laboratory receives a final, written summary report that details all
non-conformances. A laboratory has 90 days from the assessment in which to
submit corrective actions planned or implemented to satisfactorily address
all non-conformances. The OLA staff coordinator attending the assessment,
team leader, OLA Advisory Panel and OLA Director, review corrective
actions submitted by laboratories.
The purpose of this article is to explain, in detail,
QMP–LS’ expectations for corrective actions submitted to OLA following
peer assessment visits.
Purpose of Corrective Actions
The reason corrective actions must be submitted to QMP–LS
following a peer assessment visit is simple—a laboratory must
demonstrate that within 90 days of the peer assessment visit, all
non-conformances are resolved or action plans are implemented to address
them. QMP–LS provides a Microsoft Excel spreadsheet to facilitate the
submission of corrective actions, via the secure, password-protected
Document Server of the QMP–LS Web site. Action plans must include
detailed implementation steps, the name of the individual(s) responsible
and timelines for completion. A description of the corrective action must
be provided on this spreadsheet, along with documentation to substantiate
it. Acceptable supporting documentation may include approved policies,
processes and procedures, records providing evidence of implementation,
meeting minutes, receipts of equipment purchase, installation and
verification records, completed forms and patient reports (with patient
identification removed, photographs, etc). When all major non-conformances
are resolved and action plans to address minor non-conformances are
acceptable, QMP–LS issues an accreditation certificate. The following is
a step-by-step guide explaining what information QMP–LS is looking for.
STEP
1: Perform a Laboratory Investigation
For each non-conformance, the laboratory should
determine the extent of the problem considering all areas of the
laboratory, not just the area where the non-conformance was cited.
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Many
corrective actions will require the laboratory to modify or create
new procedures. Copies of those approved procedures should be
provided as documentation. The laboratory must also demonstrate that
where procedures were modified or created, staff were informed of
the change and trained appropriately. Communication means and, if
possible, samples should be included in the submitted corrective
actions. |
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Other
corrective actions may require simple actions, e.g. the removal of
obsolete documents, creation of forms and completing them to create
records, labelling, clearing of cluttered passageways and posting of
signage. Substantiating documentation may include samples or
photographs.
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Where
a problem is deemed to be systemic, the process for corrective
action will include an investigation to determine the underlying
root cause(s) of the problem. Corrective action(s) for systemic
problems should describe immediate remedial actions, but must also
describe ongoing plans to prevent recurrence of similar
non-conformances.
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In
most cases, it will be appropriate to implement a means to monitor
the effectiveness of the corrective action over time. How this will
be done should be explained in the submitted corrective actions.
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The investigation and follow-up of non-conformances is
a critical component of an effective quality management system.
Laboratories should strive to follow their own process for the
investigation of non-conformities and to use the procedures and related
forms they have created for this purpose. The QMP–LS corrective action
form is not intended to replace a laboratory’s own process for quality
improvement, rather, it is a means to facilitate communication.
STEP 2:
Complete the Corrective Action Form
QMP–LS provides laboratories with an electronic
corrective action form for the purpose of explaining the corrective
action(s) taken to address non-conformances. In the case of assessments
involving multiple laboratory sites, a separate form is provided for each.
All non-conformances listed on the summary report will appear on the form.
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Laboratories
are instructed to complete the columns labelled "Corrective
Action" and "Date of Completion," to provide a
contact name and telephone number and to have the completed form
signed by both the Laboratory Director and the CEO/President of
the Organization.
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The
completed form is submitted to QMP–LS in electronic format.
Evidence to substantiate the corrective actions explained on the
form may be submitted by embedding electronic documents and
records into the spreadsheet itself, or by submitting them
separately by e-mail, fax or regular mail (CD-ROM or hard copy).
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STEP 3:
Provide Supporting Evidence
The supporting evidence to substantiate claims made on
the corrective action form is the most important component of the
laboratory submission. It must provide conclusive evidence that actions
taken or planned are sufficient and effective.
For each major non-conformance the laboratory must
provide supporting documentation that substantiates successful correction
of the issue. The type of documentation will vary according to the nature
of the non-conformance. Acceptable supporting documentation may include:
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Approved
policies, processes and procedures. Draft documentation does not
represent successful correction of a non-conformance;
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Records
that provide evidence of implementation including training records;
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Meeting
minutes;
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Receipts
of equipment purchase;
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Installation
and verification records;
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Completed
forms;
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Patient
reports (with patient identification removed);
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Photographs,
etc. and;
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Records
of on-going monitoring of the implemented corrective action.
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For minor non-conformances, QMP–LS requests
documentation that substantiates correction of the minor (as described
above) or a detailed action plan. Action plans must include:
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detailed
implementation steps;
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the
name of the individual(s) responsible and;
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timelines
for completion of each step.
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It is enormously helpful if all documentation is
embedded in the spreadsheet, organized into a binder, or burned onto a
CD-ROM. Each document must be labelled with the non-conformance number and
the QMP–LS laboratory code number. In the case of an assessment
involving multiple laboratory sites, the laboratory should prepare a
separate submission for each laboratory license number.
STEP 4:
Review by QMP–LS
On receipt of the corrective action form and supporting
evidence, the OLA coordinator, team leader, one OLA Advisory Panel member
and OLA Director conduct an initial review. The goal of the review is to
determine if:
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Corrective
actions for major non-conformances are sufficient and effective;
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Action
plans for minor non-conformances not corrected are adequately
documented to provide assurance that the requirement in question
will be fulfilled over time.
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OLA staff will correspond with the laboratory if
further clarification/documentation is needed to provide confidence in the
corrective actions taken. When further information is requested, a
deadline is provided to the laboratory (usually two weeks). In some cases,
additional clarification will be needed but, the total time-frame allowed
for seeking clarification and additional documentation from the facility
is 45–60 days. Following the receipt of follow-up information and
documentation, if any one of the reviewers believes that any major
non-conformance is not corrected, the OLA Advisory Panel conducts an
extensive review. On completion of the review process, three options may
result (see Table 1):
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Five-year certificate
issued.
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Two-year certificate
issued.
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File referred to QMP–LS
Management Committee with intent to not grant accreditation, or
withdrawal of accreditation.
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Table
1: Criteria for Certificate Issue |
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Scenario |
QMP–LS
Action |
Follow-up |
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Laboratory
submits a response within 90 days of assessment. All major
non-conformances are resolved and action plan to address minor
non-conformances is acceptable. |
Issue
Five-year Accreditation Certificate |
Regularly
scheduled self-assessment and peer assessment visit occur. |
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Laboratory
submits a response within 90 days of assessment. Not all major
non-conformances are resolved, but the action plan to address major
and minor non-conformances is acceptable. |
Issue
Two-year Accreditation Certificate |
Within the
two years, a laboratory may apply to have a Two-year certificate
replaced with a Five-year certificate, provided evidence is
submitted substantiating all major non-conformances have been
resolved. In some cases, a repeat peer assessment visit at the
laboratory’s expense may be necessary. |
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Assessment
findings adversely affect patient care and/or laboratory does not
resolve all major non-conformances and/or does not submit an
acceptable action plan for all major and minor non-conformances
and/or there is conclusive evidence that the generally accepted
standard cannot be met. |
Recommend
Intent To Not Issue Certificate or To Withdraw Accreditation |
File
referred to Management and Conjoint Committee. |
The process for
review of laboratory corrective actions was designed to provide confidence
that the responses of the laboratory to resolve non-conformances are
sufficient and effective. Laboratories can increase their chance to
receive a Five-year certificate without undo delay by following three key
steps:
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investigating
the non-conformances; |
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completing the corrective action form
and most importantly; |
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submitting supporting evidence that
provides succinct evidence of actions taken. |
The information
provided in this article is intended to explain the expectations of the
Quality Management Program—Laboratory Services, following the OLA peer
assessment visit.
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