Background and Incidents Denials and Coverups Investigation and Action Technical Causes Organizational Causes Stakeholder R.

Size: px
Start display at page:

Download "Background and Incidents Denials and Coverups Investigation and Action Technical Causes Organizational Causes Stakeholder R."

Transcription

1 The Therac-25 Alice E. Fischer October 22, 2010 The Therac /34

2 I. Background and Incidents The Therac /34

3 Background The Therac 25 was a Canadian product... A medical linear accelerator used to treat cancer Put on the market in 1983 Preceded by Therac-6 and Therac-20 (pre-1981) Designed by AECL (Atomic Energy Commission Limited) Bimodal use: Electron beam and X-ray modes. Earlier models were not bimodal. Completely dependent on software for operation. Safety analysis excluded an analysis of software. Eleven machines were installed, 6 in Canada and 5 in the U.S. The Therac /34

4 The Cast of Characters (Stakeholders) AECL, the manufacturer and distributor The programmer who wrote the code Eleven medical centers that purchased Therac-25 Several Therac-25 operators 11 Radiation MDs in charge of the treatments 11 Hospitals, medical physicists and technicians Many patients receiving treatments The U.S. Food and Drug Administration Canadian Radiation Protection Bureau (CRPB), later merged into the Bureau of Radiation and Medical Devices The Therac /34

5 The Six Accidents June 1985, Georgia, severe radiation burns (front and back), swelling, great pain, skin sloughing off, shoulder paralyzed. July 1985, Ontario, patient lost hip, then died of cancer. Would have needed hip replacement. December 1985, Yakima WA, burns in a grid pattern. Chronic skin ulcer, pain, necrosis under skin. Damage was repaired surgically, has a minor disability and scarring. March 1986, Texas, patient died from complications after 5 months of pain April 1986, Texas, patient died from overdose 3 weeks later January 1987, Yakima, patient died in April from complications related to overdose. The Therac /34

6 II. Denials and Coverups The Therac /34

7 Marietta Georgia: July, 1985 Kennestone Regional Oncology Center The patient was severely burned and ended up with a paralyzed arm and shoulder. Hospital and technician denied any wrongdoing. They continued to send the patient for more treatments. The patient filed a lawsuit. AECL denied knowledge of incident and said it was impossible for the equipment to operate in the wrong mode. Nobody notified the FDA. Other Therac users were not notified. The Therac /34

8 Hamilton, Ontario: July, 1985 Ontario Cancer Foundation The patient lost a hip, then died soon from an aggressive form of cancer. The hospital contacted AECL. AECL sent a service engineer to investigate. The FDA and Canadian Radiation Protection Bureau (CRPB) were informed. Hospitals were told to visually confirm the treatment parameters until further notice. AECL could not replicate the malfunction. Suspected a microswitch. Looked for problems in the turntable positioning. AECL announced they had improved safety by 5 orders of magnitude. The hospital hired an independent investigator. The Therac /34

9 Canadian Investigation: 1985 As a result of the Hamilton accident, the head of advanced X-ray systems in the CRPB, Gordon Symonds, wrote a report that analyzed the design and performance characteristics of the Therac-25 with respect to radiation safety. Besides citing the flawed microswitch, the report faulted both hardware and software components of the Therac s design. It concluded with a list of four modifications to the Therac-25 necessary for minimum compliance with Canada s Radiation Emitting Devices (RED) Act (which gave government officials power to ensure the safety of radiation-emitting devices). The Therac /34

10 Yakima, Washington: December, 1985 Yakima Valley Memorial Hospital Treatment left burns in a grid pattern, leading to a chronic skin ulcer, pain, necrosis under skin. Damage was repaired surgically, has a minor disability and scarring. Hospital contacted AECL, spoke to a technical support supervisor. AECL replied that the damage could not have been caused by the machine or by an operator. Its claim was supported by 2 pages of details why such an accident was impossible. AECL claimed that there were no other similar incidents. The Therac /34

11 Tyler, Texas: March, 1986 East Texas Cancer Center The patient died from complications after five months of pain. The video monitor was unplugged and the audio unit was broken. The Therac commonly had glitches and delays. After the first treatment, the machine displayed an error code and showed a severe under-dose. The operator (as usual) hit the proceed button. The patient went to the door and pounded on it. He was immediately examined by a physician. The machine was examined next day by AECL, ETCC AECL again claimed there were no other incidents. They thought an electrical glitch had caused the problem. The Therac /34

12 Tyler, Texas: April 1986 East Texas Cancer Center, one month after the previous incident. The patient died 3 weeks later from the radiation overdose. The hospital physicist recognized the seriousness of the problem immediately and gathered information. ETCC took the machine out of service. Called AECL. The physicist and technician documented the procedure. ETCC Informed AECL that speed was necessary to cause the trouble. AECL admitted to previously discovering a cursor-up problem but thought they had fixed it. The FDA was notified, and notified other users. The Therac /34

13 Yakima, Washington: January, 1987 Yakima Valley Memorial Hospital 9 months after the nature of the problem was understood! The patient died in April from complications of the overdose. After 5 or 6 seconds of treatment, the machine paused and displayed an error message that may have disappeared quickly. The operator was not sure. The treatment console displayed no dose. The operator pressed the proceed button. The machine shut down again displaying the error message Flatness. The operator went to check on the patient, who reported burning. Four days later, the skin showed burns in a striped pattern. The Therac /34

14 III. Investigation and Action The Therac /34

15 AECL report: April 1986 The AECL issued a report following their investigation at ETCC The frying sound heard by patients happened when the ion chamber became saturated. Effective immediately, and until further notice, the key used for moving the cursor back through the prescription sequence (i.e. cursor UP, inscribed with an upward pointing arrow) must not be used for editing or any other purpose. To avoid accidental use of this key, the key cap must be removed and the switch contacts fixed in the open position with electrical tape or other insulating material. Disabling this key means that, if any prescription entered is incorrect, then a Reset command must be used and the whole prescription reentered. The Therac /34

16 FDA Response: May, 1986 We have reviewed AECL s April 15 letter to purchasers and have concluded that it does not satisfy the requirements for notification to purchasers of a defect in an electronic product. Specifically, It does not describe the defect nor the hazards associated with it. The letter does not provide any reason for disabling the cursor key and the tone is not commensurate with the urgency for doing so. In fact, the letter implies the inconvenience to operators outweighs the need to disable the key. We request that you immediately renotify purchasers. The Therac /34

17 Resolution: July, 1987 The software race condition was understood. AECL agreed to fix it and make a number of other modifications to the machine. Those changes included safety interlocks. Operator error messages were to be written in clear English instead of cryptic codes. Up-to-date documentation was to be provided. The Therac /34

18 IV. Technical Causes The Therac /34

19 Rapid editing of an error. Every incident involved a skilled and experienced Therac operator. The prescription was initially entered incorrectly, and the cursor reached the final position that signals completion of the prescription. This triggers the machine to start the setup process. Then the operator noticed an error and used the up-cursor key to revisit the wrong field and correct it, then used cursor-down to get back to the done position. If the correction task was fast enough, the control process would not be aware that anything had changed. However, the concurrent setup had already begun. The incorrect data was used to set one of the radiation parameters. Later, the corrected data was used to set the other. The Therac /34

20 The second Yakima accident Bad programming practice: It was a one-byte variable ( ) was used for indicating whether the upper collimator was in position. It was incremented every time its parent process was rescheduled. It eventually overflowed and wrapped to 0. A non-zero value indicated setup was not complete. A 0 indicated that the positioning was complete. Instead of incrementing the variable, it should have been set to some fixed non-zero value. The Therac /34

21 Contributing Factors: Design and Construction The system was developed over a span of several years without adequate structure. There was no overall specification and no documented test plan. The model behind the software did not take concurrency and timing issues into account. No redundancy was designed into the system. The code was written by a single developer with no significant software review. There was no software audit trail. Code was written in assembly code (probably avoidable in 1983). The Therac /34

22 Contributing Factors: Code Reuse The software for Therac-25 was ported from the Therac-20 without a new analysis and without consideration of the changes in the hardware. Hardware interlocks on the Therac-20 were removed and replaced by software checks on the Therac-25. The Therac /34

23 Contributing Factors: Concurrency Extensive use was made of concurrent programming with shared variables. Synchronization was not implemented well, so the system was prone to race conditions. The code relied on status flags that were set and reset by multiple subsystems for more than one reason. It used phantom tables for getting dosage values if too low a value was entered. The Therac /34

24 Contributing Factors: Testing, Usability, and Operation Simulation and unit testing were inadequate. The user interface was bad, error messages were cryptic and poorly documented. As a consequence of common software glitches and hiccups, operators were desensitized and ignored error comments. Standard operating procedure was to keep pressing Proceed. The machine was operated with safety systems disabled: broken audio and video. Errors were not reproduced easily because half-trained people did the testing. The Therac /34

25 V. Organizational Causes The Therac /34

26 Problems at AECL No software quality assurance procedures were in place. In a letter to the FDA, AECL erroneously or falsely claimed a lawsuit notification was received in March 1986 instead of November 1985, as was the case. After the second accident (Hamilton), overexposure was blamed on faulty microswitch. AECL misrepresented facts and did not assume responsibility for its product after the first death. AECL failed to replicated the error but, after minor hardware and software modifications, they claimed five orders of magnitude safety improvement. The Therac /34

27 More Problems at AECL AECL ignored Symonds and CRPBs recommendations to modify the data entry procedure. Number of retries allowed changed from five to three. After accident #3, AECL claimed that no operator error or system malfunction could have caused the overexposure. In March, 1986, after the fourth incident, AECL s engineer completed inspections in one day. Their quality assurance manager told the ETCC Physicist that AECL knew of no accidents involving radiation overexposure by the Therac-25. AECL s first recall notification letter to users was inadequate and confusing. The Therac /34

28 Organizational Problems Elsewhere One of the accidents occurred when audio and video monitoring of patients was broken/turned off. The FDA (June 1987) gave the AECL a Class II recall, meaning the risk of serious consequences is remote, or injuries are reversible. Nine months after the problem was diagnosed, another accident happened. The Therac /34

29 VI. Stakeholder Responsibilities The Therac /34

30 Manufacturer of Safety-Critical Equipment Responsibilities: Taking away the hardware locks was a false economy. Train programmers and engineers that safety comes first. Thoroughly check and test software and hardware before release. Use a responsible design, development, and testing process. But if your model is wrong, testing won t detect the problem. One guy. No code review. Were there unit tests? There should have been reviews at different levels, all should have been documented. Keep track of code reviews and equipment design changes. For customers, provide high-quality documentation and descriptions of error conditions. The Therac /34

31 Manufacturer Responsibilities (Continued) Respond in a truthful, competent, appropriate and timely manner to problems. Announce recalls promptly and clearly. Establish good communication among departments within the company. Make sure there are proper checks and balances on responsibilities of departments. Coders, legal staff, managers, complaint desk Follow best practices for customer support and complaints The Therac /34

32 Programmer / Programming Department Responsibilities Use a responsible design and development process including Use peer review during coding. Do code review between versions of the machine. Use modular design. Implement a commit step before using a life-critical machine. Create unit tests and a test suite. Do regression testing over a long period of time. Synchronize the concurrent processes properly. Document and comment the code. Design a user interface that is clear, especially with respect to errors. The Therac /34

33 Hospitals Responsibilities: Make the environment safe for the patients (Yakima, video broken) Don t use the equipment if the safety systems are not functional. (Intercom) Contact the manufacturer in case of problems ( The GA hospital didn t think problem was serious) Make sure that maintenance checks are timely. ( Safety equipment) Follow-up on treatments. (Might have prevented later incidents.) The Therac /34

34 Regulatory Agencies Be prompt if it is a life-threatening problem. Do not minimize the severity of a problem that has caused a death. Issue a warning even if a full investigation is not complete. Follow the rules about recalls. The Therac /34

CPSC 310 Software Engineering. Quality

CPSC 310 Software Engineering. Quality CPSC 310 Software Engineering Quality Learning Goals By the end of this unit, you will be able to: Describe aspects that affect software quality other than code quality Explain the benefits of high quality

More information

Incident [Accident] Investigations

Incident [Accident] Investigations Incident [Accident] Investigations 1. Preserve/ Document Scene 2. Collect Information 3. Determine Root Causes 4. Implement Corrective Actions Objectives for Today Discuss the importance of why all incidents,

More information

Engineering systems to avoid disasters

Engineering systems to avoid disasters Critical Systems Engineering Engineering systems to avoid disasters Adapted from Ian Sommerville CSE 466-1 Objectives To introduce the notion of critical systems To describe critical system attributes

More information

Owner s Manual & Safety Instructions

Owner s Manual & Safety Instructions Owner s Manual & Safety Instructions Save This Manual Keep this manual for the safety warnings and precautions, assembly, operating, inspection, maintenance and cleaning procedures. Write the product s

More information

Incident Investigation Process

Incident Investigation Process Incident Investigation Process Introduction An incident is an unplanned or undesired event that adversely affects a company s work operations. Incidents include work-related injuries, occupational illnesses,

More information

The 5 Building Blocks of a CAPA Solution. Managing Corrective Actions/Preventive Actions for the Consumer Products Industry

The 5 Building Blocks of a CAPA Solution. Managing Corrective Actions/Preventive Actions for the Consumer Products Industry The 5 Building Blocks of a CAPA Solution Managing Corrective Actions/Preventive Actions for the Consumer Products Industry 1 Table of Contents 3 Introduction 5 Tackling Quality Issues & Incidents 8 Five

More information

MRCI. MRCI-CDS Electronic Timesheets Training Manual. M R C I W o r k S o u r c e

MRCI. MRCI-CDS Electronic Timesheets Training Manual. M R C I W o r k S o u r c e MRCI MRCI-CDS Electronic Timesheets Training Manual M R C I W o r k S o u r c e MRCI-CDS Electronic Timesheets Training Manual 2017 ABOUT THE ELECTRONIC TIMESHEETS MODULE 3 ELECTRONIC TIMESHEETS AGREEMENT

More information

Quality Concepts. Slide Set to accompany. Software Engineering: A Practitioner s Approach, 7/e by Roger S. Pressman

Quality Concepts. Slide Set to accompany. Software Engineering: A Practitioner s Approach, 7/e by Roger S. Pressman Chapter 14 Quality Concepts Slide Set to accompany Software Engineering: A Practitioner s Approach, 7/e by Roger S. Pressman Slides copyright 1996, 2001, 2005, 2009 by Roger S. Pressman For non-profit

More information

Requirement Analysis Document

Requirement Analysis Document Requirement Analysis Document For A police vehicle command and control system Group Members: Barbara Anne Fernandiz (Group Leader) Girubalani a/p Garnarajan Patricia a/p Arokiasamy Subhashini a/p Ramalinggam

More information

Today, we will discuss the importance of accident investigation, how to talk to witnesses, what questions to ask when evaluating an accident scene,

Today, we will discuss the importance of accident investigation, how to talk to witnesses, what questions to ask when evaluating an accident scene, Today, we will discuss the importance of accident investigation, how to talk to witnesses, what questions to ask when evaluating an accident scene, how to determine causal factors, and how to identify

More information

Important Operating Instructions and Warranty Information On Your New Electronic AMSEC Safe

Important Operating Instructions and Warranty Information On Your New Electronic AMSEC Safe Important Operating Instructions and Warranty Information On Your New Electronic AMSEC Safe MODELS: EST712, EST813, EST914, EST916, EST149, EST1014, EST1814, EST2014, WEST149, WEST2114 Read Contents Carefully

More information

Owner s Manual & Safety Instructions

Owner s Manual & Safety Instructions Owner s Manual & Safety Instructions Save This Manual Keep this manual for the safety warnings and precautions, assembly, operating, inspection, maintenance and cleaning procedures. Write the product s

More information

Safety Precautions. 3. Cabinet Assembly 4. Operating buttons / functions.5-6. Machine Operation

Safety Precautions. 3. Cabinet Assembly 4. Operating buttons / functions.5-6. Machine Operation USER MANUAL Contents Safety Precautions. 3 Cabinet Assembly 4 Operating buttons / functions.5-6 Machine Operation...7-11 Convert from Inches to Millimeters / Millimeters to Inches.. 7 Programming in Manual

More information

A Systems Approach to Risk Management Through Leading Indicators

A Systems Approach to Risk Management Through Leading Indicators A Systems Approach to Risk Management Through Leading Indicators Nancy Leveson MIT Goal To identify potential for an accident before it occurs Underlying assumption: Major accidents not due to a unique

More information

Sub-Part I Implementation. Bill Byrnes Champion Enterprises, Inc.

Sub-Part I Implementation. Bill Byrnes Champion Enterprises, Inc. Sub-Part I Implementation Bill Byrnes Champion Enterprises, Inc. The Sub Part I Process Purpose What is Sub-Part I from the grass roots perspective Topics How do we teach Champion plants to implement Sub-Part

More information

This topic focuses on how to prepare a customer for support, and how to use the SAP support processes to solve your customer s problems.

This topic focuses on how to prepare a customer for support, and how to use the SAP support processes to solve your customer s problems. This topic focuses on how to prepare a customer for support, and how to use the SAP support processes to solve your customer s problems. 1 On completion of this topic, you will be able to: Explain the

More information

ILAC-G20:2002. Guidelines on Grading of Non-conformities

ILAC-G20:2002. Guidelines on Grading of Non-conformities Guidelines on Grading of Non-conformities Copyright ILAC 2002 ILAC encourages the authorised reproduction of its publications, or parts thereof, by organisations wishing to use such material for areas

More information

9. Verification, Validation, Testing

9. Verification, Validation, Testing 9. Verification, Validation, Testing (a) Basic Notions (b) Dynamic testing. (c) Static analysis. (d) Modelling. (e) Environmental Simulation. (f) Test Strategies. (g) Tool support. (h) Independent Verification

More information

Critical Systems Specification. Ian Sommerville 2004 Software Engineering, 7th edition. Chapter 9 Slide 1

Critical Systems Specification. Ian Sommerville 2004 Software Engineering, 7th edition. Chapter 9 Slide 1 Critical Systems Specification Ian Sommerville 2004 Software Engineering, 7th edition. Chapter 9 Slide 1 Objectives To explain how dependability requirements may be identified by analysing the risks faced

More information

MEASURE FOR MEASURE: QUALITY METRICS

MEASURE FOR MEASURE: QUALITY METRICS MEASURE FOR MEASURE: QUALITY METRICS PDA Midwest Chapter Dinner Meeting, Northbrook, IL-9 November 2017 Felicia Ford-Rice, Director, Strategic Compliance 2017 PAREXEL INTERNATIONAL CORP. AGENDA Robust

More information

Medication errors: Development of prevention strategies for medicines and medical devices

Medication errors: Development of prevention strategies for medicines and medical devices Medication errors: Development of prevention strategies for medicines and medical devices Laurent Auclert Chairman of the PharmacoVigilance Committee EFPIA 1 Medication errors defined as occurring while

More information

Dependability requirements. Risk-driven specification. Objectives. Stages of risk-based analysis. Topics covered. Critical Systems Specification

Dependability requirements. Risk-driven specification. Objectives. Stages of risk-based analysis. Topics covered. Critical Systems Specification Dependability requirements Critical Systems Specification Functional requirements to define error checking and recovery facilities and protection against system failures. Non-functional requirements defining

More information

Ticketing Terms and Conditions

Ticketing Terms and Conditions Ticketing Terms and Conditions These Terms explain how you can purchase Tickets from our Site. Please read these Terms carefully before purchasing Tickets from us. When purchasing any Tickets you agree

More information

Identity and Access Management

Identity and Access Management Chapter 2 Identity and Access Management There are many configurations of identity and access management (IAM) systems, and to some extent, each organization s IAM system will be unique, developed and

More information

Field Inspection Manual Part: 2-ASTP Section: 3 - DTWS Page: 1 of 18. Automatic Weighing Devices Issued: Revision Number: Original

Field Inspection Manual Part: 2-ASTP Section: 3 - DTWS Page: 1 of 18. Automatic Weighing Devices Issued: Revision Number: Original Field Inspection Manual Part: 2-ASTP Section: 3 - DTWS Page: 1 of 18 REFERENCE Weights and Mesures Regulations, NAWDS & the National Technical Training Bulk Weigher Training Module. PURPOSE The following

More information

LC-1000/ LC Loadout. Manual

LC-1000/ LC Loadout. Manual LC-1000/ LC-2000 Loadout Manual ********************************************************************************************* All equipment is tested for proper operation before shipping from the factory.

More information

6 SAFETY CULTURE ESSENTIALS

6 SAFETY CULTURE ESSENTIALS 6 SAFETY CULTURE ESSENTIALS Many organizations want to improve their safety culture in order to reduce injury rates, save money, and increase productivity. But how does a company begin to foster a culture

More information

Health Spectrum Pharmacy Services succeeds in a fast-growing market with a range of pharmacy management solutions.

Health Spectrum Pharmacy Services succeeds in a fast-growing market with a range of pharmacy management solutions. Health Spectrum Pharmacy Services succeeds in a fast-growing market with a range of pharmacy management solutions. Health Spectrum Pharmacy Services is a hospitalbased outpatient retail pharmacy with four

More information

SAMM POLICY 10 (SP 10) GRADING OF NON- CONFORMITIES Issue 2, 28 February 2007 (Amd.1, 11 August 2014)

SAMM POLICY 10 (SP 10) GRADING OF NON- CONFORMITIES Issue 2, 28 February 2007 (Amd.1, 11 August 2014) SKIM AKREDITASI MAKMAL MALAYSIA (SAMM) LABORATORY ACCREDITATION SCHEME OF MALAYSIA SAMM POLICY 10 (SP 10) GRADING OF NON- CONFORMITIES Issue 2, 28 February 2007 (Amd.1, 11 August 2014) JABATAN STANDARD

More information

Risk-Based Approach to SAS Program Validation

Risk-Based Approach to SAS Program Validation Paper FC04 Risk-Based Approach to SAS Program Validation Keith C. Benze SEC Associates, Inc. 3900 Paramount Parkway, Suite 150 South Morrisville, NC 27560 ABSTRACT SAS is widely used throughout the FDA

More information

Nuclear Power Plant Incidents

Nuclear Power Plant Incidents Nuclear Power Plant Incidents Find out what could happen to you. If there is a nuclear power plant in your area, contact the plant s community relations officials or contact local, state, or federal emergency

More information

SOFTWARE FAILURE MODES EFFECTS ANALYSIS OVERVIEW

SOFTWARE FAILURE MODES EFFECTS ANALYSIS OVERVIEW SOFTWARE FAILURE MODES EFFECTS ANALYSIS OVERVIEW Copyright, Ann Marie Neufelder, SoftRel, LLC, 2010 amneufelder@softrel.com www.softrel.com This presentation may not be copied in part or whole without

More information

IT S ALL ABOUT PROTECTING PEOPLE

IT S ALL ABOUT PROTECTING PEOPLE IT S ALL ABOUT PROTECTING PEOPLE Over 2000 times a year, workers are admitted to burn centers for extended injury treatment. Although many types of injuries can result from exposure to arcing faults, one

More information

BillQuick-QuickBooks Advanced Integration Guide 2016

BillQuick-QuickBooks Advanced Integration Guide 2016 BillQuick-QuickBooks Advanced Integration Guide 2016 CONTENTS INTRODUCTION 1 HOW TO USE THIS GUIDE 1 SOFTWARE EDITIONS SUPPORTED 2 HOW INTEGRATION WORKS 2 MODES OF SYNCHRONIZATION 3 INTEGRATION RULES 4

More information

Health and Safety Policy

Health and Safety Policy Health and Safety Policy Policy statement Brunk is committed to meeting our health and safety goals for all processes, and to maintaining a safe and healthy workplace. It is Brunk s policy to provide a

More information

Safety Critical Software Engineering. Safety Critical Software Engineering

Safety Critical Software Engineering. Safety Critical Software Engineering Safety Critical Software Engineering Safety Critical Software Engineering As software is used more widely, safety has become an important issue. Safety aspects of software are poorly understood at the

More information

GUIDE TO INSPECTIONS OF QUALITY SYSTEMS

GUIDE TO INSPECTIONS OF QUALITY SYSTEMS FOOD AND DRUG ADMINISTRATION GUIDE TO INSPECTIONS OF QUALITY SYSTEMS 1 1 August 1999 2 Guide to Inspections of Quality Systems This document was developed by the Quality System Inspections Reengineering

More information

SaaS Maintenance & Customer Support Terms

SaaS Maintenance & Customer Support Terms SaaS Maintenance & Customer Support Terms The following terms and conditions apply for Actiance SaaS Hosted Services Solutions. Maintenance Actiance shall offer product upgrades to Customers hosted environment

More information

Scanning Devices Label Counting Table Operations Manual

Scanning Devices Label Counting Table Operations Manual Scanning Devices Label Counting Table Operations Manual This document describes the functions performed by counting table components and suggests procedures for setting up and operating the counting table.

More information

THE INDEPENDENT PHARMACIST S GUIDE TO THE ON-SITE AUDIT Amanda C. Fields, General Counsel for American Pharmacies (APRx) American Pharmacies 2011

THE INDEPENDENT PHARMACIST S GUIDE TO THE ON-SITE AUDIT Amanda C. Fields, General Counsel for American Pharmacies (APRx) American Pharmacies 2011 THE INDEPENDENT PHARMACIST S GUIDE TO THE ON-SITE AUDIT Amanda C. Fields, General Counsel for American Pharmacies (APRx) American Pharmacies 2011 Introduction As the Texas pharmacists know, audits by insurance

More information

Machine Guarding and Maintenance

Machine Guarding and Maintenance 1. Identification of Workplace Hazard Machine Guarding and Maintenance The exposed moving parts of machinery can cause serious injuries to an employee who is inadvertently caught by the machine. Hazardous

More information

RetuRn to WoRk h a n d b o o k

RetuRn to WoRk h a n d b o o k Return to Work h a n d b o o k Return to Work h a n d b o o k Contents 1 > Introduction Definition, Purpose and Benefits of a Return-To-Work Program pg.2 2 > Creating and Implementing a Return-To-Work

More information

SERIOUS ADVERSE EVENTS

SERIOUS ADVERSE EVENTS EVENTS Introduction Timely reporting of Serious Adverse Events (SAEs) is required by regulations of the Food and Drug Administration (FDA) and the National Cancer Institute (NCI). Such reporting is not

More information

Accommodation and Compliance Series

Accommodation and Compliance Series Accommodation and Compliance Series Employees Practical Guide to Requesting and Negotiating Reasonable Accommodations Under the Americans with Disabilities Act Preface The Job Accommodation Network (JAN)

More information

ERP IMPLEMENTATION RISK

ERP IMPLEMENTATION RISK ERP IMPLEMENTATION RISK Kari Sklenka-Gordon, Director at RSM National ERP Risk Advisory Leader March 2017 2015 2016 RSM US LLP. All Rights Reserved. Speaker Kari Sklenka-Gordon National RSM ERP Risk Advisory

More information

MSC Software Standard Software Maintenance & Technical Support Usage Guide

MSC Software Standard Software Maintenance & Technical Support Usage Guide MSC Software Standard Software Maintenance & Technical Support Usage Guide About this document: Technical Support Usage Guide is written to educate and help customers in: Clarifying the extent of technical

More information

Dealing with chance Four strategies. Simple, direct Absolutes. Persuasion Top management support. Training. Corruption Alienation. 3 lines of defense

Dealing with chance Four strategies. Simple, direct Absolutes. Persuasion Top management support. Training. Corruption Alienation. 3 lines of defense Hazard avoidance overview Concepts of Hazard Avoidance Dealing with chance Four strategies Enforcement Psychological Engineering Analytical ١ ٢ Enforcement approach Simple, direct Absolutes Judgment Corruption

More information

What Deming Saw. Keywords: quality management, control of variation, zero defects, process volatility

What Deming Saw. Keywords: quality management, control of variation, zero defects, process volatility What Deming Saw Abstract What Deming Saw: The late W. Edwards Deming did not believe in zero defects it was not economically viable he wrote. But he strongly promoted on-going business process improvement

More information

Privacy Incident Response & Reporting: Pre and Post HITECH

Privacy Incident Response & Reporting: Pre and Post HITECH Privacy Incident Response & Reporting: Pre and Post HITECH Erika Riethmiller-Bol, Director, Corporate Privacy-Incident Program, Anthem, Inc. HCCA Managed Care Compliance Conference February 16, 2015 Objectives

More information

This Installation Guide uses the following symbols to indicate important information. Always observe the instructions indicated by these symbols.

This Installation Guide uses the following symbols to indicate important information. Always observe the instructions indicated by these symbols. VIGO INDUSTRIES INSTALLATION GUIDE FOR STANDING SHOWER CABIN (MODEL VG06062) SAFETY PRECAUTIONS This Installation Guide uses the following symbols to indicate important information. Always observe the

More information

Why ChartLogic Medical Billing Services?

Why ChartLogic Medical Billing Services? OVERVIEW GUIDE Why ChartLogic Medical Billing Services? The differentiators and benefits of choosing ChartLogic as your billing partner. Beyond Standard eeligibility There is more to the story for eeligibility

More information

ACTIVANT ACCLAIM LOGISTICS MANAGEMENT. Version 16.0

ACTIVANT ACCLAIM LOGISTICS MANAGEMENT. Version 16.0 ACTIVANT ACCLAIM Version 16.0 This manual contains reference information about software products from Activant Solutions Inc. The software described in this manual and the manual itself are furnished under

More information

Slides copyright 1996, 2001, 2005, 2009 by Roger S. Pressman. For non-profit educational use only

Slides copyright 1996, 2001, 2005, 2009 by Roger S. Pressman. For non-profit educational use only Chapter 14 Quality Concepts Slide Set to accompany Software Engineering: A Practitioner s Approach, 7/e by Roger S. Pressman Slides copyright 1996, 2001, 2005, 2009 by Roger S. Pressman For non-profit

More information

Nox DoD. User Guide. Version 3.0.x. Nox for DoD User Guide! Page 1

Nox DoD. User Guide. Version 3.0.x. Nox for DoD User Guide! Page 1 Nox DoD User Guide Version 3.0.x Nox for DoD User Guide! Page 1 Contents Overview! 3 Shipment Manager -- Nox Administrator Roles! 3 Floor Manager / Packaging -- Nox User Roles! 4 Helpful Notes! 5 Creating

More information

HAZARD IDENTIFICATION AND RISK ASSESSMENT Revision Date: 04/2017

HAZARD IDENTIFICATION AND RISK ASSESSMENT Revision Date: 04/2017 HAZARD IDENTIFICATION AND RISK ASSESSMENT 23.1 PURPOSE 23.1.1 The purpose of this policy is to help employees identify, analyze and apply control strategies to eliminate or reduce hazardous conditions

More information

MD Power Supply -48Vdc +Bias Tee

MD Power Supply -48Vdc +Bias Tee 215988-001MD Power Supply -48Vdc +Bias Tee Operation and Maintenance Manual Mitec Telecom Inc. Designers and manufacturers of telecom and wireless products 9000 Trans Canada, Pointe-Claire, Quebec, Canada

More information

AXIS II RC DRONE WITH CAMERA

AXIS II RC DRONE WITH CAMERA AXIS II RC DRONE WITH CAMERA THANK YOU. Thank you for your purchase of Protocol s Axis II RC Drone With Camera. You are about to experience the best of what remote control flight has to offer. We strongly

More information

d. Bands hidden by overexposure with chemiluminescence become clear when imaged with Odyssey.

d. Bands hidden by overexposure with chemiluminescence become clear when imaged with Odyssey. Core Equipment ID: 15922 Description: LI COR Biosciences, Odyssey Infrared Imaging System Room: B446 (Molecular & Biochemical Core) Champion: 1.0 Purpose Standardize the process for control, maintenance,

More information

MRI Safety Overview - Quench

MRI Safety Overview - Quench MRI Safety Overview - Quench Zachary W. Friis, Ph.D., DABR Quench What is a Quench? Quench is term we give to the situation that occurs (accidentally or purposefully) in which a super conducting magnet

More information

Target Management through Hour by Hour reporting for a Continuous Coating Environment

Target Management through Hour by Hour reporting for a Continuous Coating Environment Target Management through Hour by Hour reporting for a Continuous Coating Environment 2013 Aimcal Web Coating & Handling Conference Charleston, South Carolina Josh Rauen Tim Buntrock Jeff Hammes Background

More information

NUCLEAR SAFETY REQUIREMENTS BSR

NUCLEAR SAFETY REQUIREMENTS BSR NUCLEAR SAFETY REQUIREMENTS BSR-1.8.2-2015 APPROVED BY Order No. 22.3-99 of The Head of State Nuclear Power Safety Inspectorate, of 7 October 2011 (as amended by Order No. 22.3-57 of the Head of State

More information

DJ Switch 10F V2 ORDERCODE 50365

DJ Switch 10F V2 ORDERCODE 50365 DJ Switch 10F V2 ORDERCODE 5035 Congratulations! You have bought a great, innovative product from Showtec. The Showtec DJ Switch brings excitement to any venue. Whether you want simple plug-&-play action

More information

SOCIAL MEDIA AND THE WORKPLACE

SOCIAL MEDIA AND THE WORKPLACE SOCIAL MEDIA AND THE WORKPLACE Presented By: Ronni M. Travers, SPHR, President Public Sector HR Consultants LLC Office: (518) 399-4512 Email: rtravers@publicsectorhr.org Quick Survey of Attendees 1. Who

More information

TF20 Tray Feeder. Instruction Manual. for JEDEC and IEC Standard Trays

TF20 Tray Feeder. Instruction Manual. for JEDEC and IEC Standard Trays for JEDEC and IEC Standard Trays Instruction Manual 096-0243-003 Data I/O assumes no liability for errors, or for any incidental, consequential, indirect, or special damages, including, without limitation,

More information

By Michael J. Major. Safety Is Expensive

By Michael J. Major. Safety Is Expensive By Michael J. Major Safety Is Expensive But Accidents Are Even More Expensive Safety is expensive, but accidents are even more expensive. This is the lesson that the Lenexa, Kan.-based Performance Contracting,

More information

Controlling the Costs of Absenteeism

Controlling the Costs of Absenteeism Controlling the Costs of Absenteeism The CFO Perspective by Angelo Carofano, CPA, CMA, MBA Table of Contents The CFO: The missing link in getting absence management results?... 2 First, some background

More information

Performance and Contract Management Committee 1 September 2015

Performance and Contract Management Committee 1 September 2015 Performance and Contract Management Committee 1 September 2015 Title Members Enquiries service a review Report of Customer Services Operations Director Wards All Status Public Urgent No Enclosures Key

More information

2017 PMF Application Guide

2017 PMF Application Guide 10 general steps that you should follow as you prepare, work on, and complete the PMF application The timeline for this cycle is as follows: Friday, November 18, 2016 Application for the PMF Class of 2017

More information

Invisible Ink in GLP and GCP Research

Invisible Ink in GLP and GCP Research http://www.colginconsulting.com/invisible-ink-in-glp-and-gcp-research/ Invisible Ink in GLP and GCP Research What follows is more or less a transcript of my presentation at the annual meeting of the Pacific

More information

Product safety and conformity in the automotive supply chain in the case of product nonconformities 1 st Edition, February 2018 Online-Download-Docume

Product safety and conformity in the automotive supply chain in the case of product nonconformities 1 st Edition, February 2018 Online-Download-Docume Quality Management in the Automotive Industry Product safety and conformity in the automotive supply chain in the case of Product nonconformities 1 st Edition, February 2018 Online-Download-Document Product

More information

SK3600 Push Back System

SK3600 Push Back System SK3600 Push Back System Safe Operating Procedures User Handbook This handbook contains important information for the safe and efficient use of push back rack systems. All operators must review and understand

More information

MWF Advanced Floor. User Guide. Last Updated on July 27 th 2015

MWF Advanced Floor. User Guide. Last Updated on July 27 th 2015 MWF Advanced Floor User Guide Last Updated on July 27 th 2015 2 Table of contents 1. Introduction... 3 1.1 Before starting... 3 2. Project Configuration... 5 2.1 Code Requirements - Analyses Configuration...

More information

Year-End Close Checklists

Year-End Close Checklists Sage Master Builder Year-End Close Checklists Calendar-year, Fiscal-year, Combined NOTICE This document and the Sage Master Builder software may be used only in accordance with the accompanying Sage Master

More information

KNOW YOUR ENERGY RIGHTS. Information and advice to help you solve your energy complaints.

KNOW YOUR ENERGY RIGHTS. Information and advice to help you solve your energy complaints. 1 KNOW YOUR ENERGY RIGHTS Information and advice to help you solve your energy complaints. Many older people are suffering in silence 2 Over half (55%) feel that companies take advantage of older people,

More information

Dependable Systems. Dr. Peter Tröger

Dependable Systems. Dr. Peter Tröger Dependable Systems Dr. Peter Tröger Dependable Systems Course Introduction into theoretical foundations, common building blocks and example implementations for dependable IT components and systems Recommend

More information

Case Study College of American Pathologists. All rights reserved. cap.org

Case Study College of American Pathologists. All rights reserved. cap.org Case Study How to Reduce Clerical Errors Mark Shearer, MCLT, MT(ASCP) Director of Chemistry, CompuNet Clinical Laboratories Clerical errors represent the single largest source of errors on proficiency

More information

Achieving World Class Safety Performance Through Metrics

Achieving World Class Safety Performance Through Metrics Session No. 710 Achieving World Class Safety Performance Through Metrics Introduction John W. Russell, MS, PE, CSP, CPE, CPEA, ARM, PCMH Technical Director Liberty Mutual Group Irving, TX Metrics are a

More information

The Top Dangers of Undetected Fault Codes

The Top Dangers of Undetected Fault Codes The Top Dangers of Undetected Fault Codes Fleet safety impacts an entire organization. Insurance rates, liability risk, CSA scores, and even retaining good drivers are dependent on having well-maintained,

More information

Magner /35-3 Series Currency Counter. Operator's Manual

Magner /35-3 Series Currency Counter. Operator's Manual Magner 35-2003/35-3 Series Currency Counter Operator's Manual Magner 35-2003 / 35-3 Series Introduction. The MAGNER 35-2003 / 35-3 is the most advanced Currency Counter available today. MAGNER's Design

More information

Workplace Health & Safety

Workplace Health & Safety Workplace Health & Safety Legislation March 2000 The Occupational Health and Safety Act: A Worker s Guide Purpose of this Safety Bulletin Health and safety in the workplace doesn t stop and start with

More information

Health & Safety at Work.

Health & Safety at Work. Ministry of Labour. Supervisor. Health & Safety at Work. Prevention Starts Here. Supervisor Health and Safety Awareness in 5 Steps. This workbook belongs to: Contents 01 INTRODUCTION. 03 STEP 1: MAKE A

More information

Precision Automatic Vacuum Control (PAVC+)

Precision Automatic Vacuum Control (PAVC+) USER GUIDE UGE105-1216 www.conairgroup.com Precision Automatic Vacuum Control (PAVC+) Corporate Office: 724.584.5500 l Instant Access 24/7 (Parts and Service): 800.458.1960 l Parts and Service: 814.437.6861

More information

Océ DFS10. Operator Manual

Océ DFS10. Operator Manual Océ DFS10 Operator Manual Océ-Technologies B.V. All rights reserved Id: 7241873 Approvals and certifications Safety Europe Approved by Underwriters Laboratories Inc. North America This equipment is listed

More information

Fall-Back Mode Operation on Remotely Controlled Railway Lines

Fall-Back Mode Operation on Remotely Controlled Railway Lines TRANSPORT Fall-Back Mode Operation on Remotely... Fall-Back Mode Operation on Remotely Controlled Railway Lines Attila Cseh, Balázs Sághi, Géza Tarnai Budapest University of Technology and Economics, Hungary

More information

imark Mobile Ordering System

imark Mobile Ordering System imark Mobile Ordering System Locate the switch, generally located in the back office Plug the green Ethernet cable into PORT 6, if 6 is in use then use PORT 2 Plug the other end of the cable into the imark

More information

Summary of TL 9000 R4.0 Requirements Beyond ISO 9001:2000

Summary of TL 9000 R4.0 Requirements Beyond ISO 9001:2000 This summary identifies the additional TL 9000 Release 4.0 requirements beyond those stated in ISO 9001:2000. See the TL 9000 R4.0 Handbook for the actual TL 9000 R4.0 requirements. ISO 9001:2000 section

More information

CashierPRO Retail Systems Inc. Release Note

CashierPRO Retail Systems Inc. Release Note Version 4.0.9.3-02/17/16 MAJOR ENHANCEMENTS: Moneris Integration for Home Hardware Stores. Includes processing of Debit and Credit transactions communicating directly with a Moneris Pinpad. Allows for

More information

User Guide For Dealer Associate Shippers

User Guide For Dealer Associate Shippers User Guide For Dealer Associate Shippers MOTOR SALES, U.S.A. Last Updated May 2014 User Guide for Dealer Associate Shippers 2014 Bureau of Dangerous Goods, Ltd. All Rights Reserved Introduction 1 S hiphazmat

More information

Understanding and Mitigating IT Project Risks BY MIKE BAILEY AND MIKE RIFFEL

Understanding and Mitigating IT Project Risks BY MIKE BAILEY AND MIKE RIFFEL Understanding and Mitigating IT Project Risks BY MIKE BAILEY AND MIKE RIFFEL Technology projects can present organizational challenges, and the associated risk is one of the finance officer s primary concerns

More information

DISTRIBUTION AND SUPPLY OF PLASMA DERIVED FRACTIONATED BLOOD PRODUCTS AND RECOMBINANT PRODUCTS IN NEW ZEALAND

DISTRIBUTION AND SUPPLY OF PLASMA DERIVED FRACTIONATED BLOOD PRODUCTS AND RECOMBINANT PRODUCTS IN NEW ZEALAND REASON FOR CHANGE: Wholesaler s licences are now issued by the Ministry of Health rather than Medsafe; clarify the approval process for the supply of products only to authorised facilities and healthcare

More information

MDSAP AUDIT PROCESS. A Manufacturer s Perspective. Connie Hoy EVP Regulatory Affairs Cynosure, Inc.

MDSAP AUDIT PROCESS. A Manufacturer s Perspective. Connie Hoy EVP Regulatory Affairs Cynosure, Inc. MDSAP AUDIT PROCESS A Manufacturer s Perspective Connie Hoy EVP Regulatory Affairs Cynosure, Inc. Cynosure Located in Westford, MA Largest manufacturer of Medical Lasers Second location in Hicksville,

More information

SMART GLASS ADOPTION IN THE ENTERPRISE

SMART GLASS ADOPTION IN THE ENTERPRISE WHITEPAPER SMART GLASS ADOPTION IN THE ENTERPRISE Manufacturing, field service, training and compliance departments are looking to smart glasses for new efficiencies. Research by Modern enterprises are

More information

Conducting an Internal Investigation

Conducting an Internal Investigation Conducting an Internal Investigation Delaware Valley Employment Conference Kurt A. Miller March 6, 2014 TOPICS TO BE COVERED Recognizing the need for an investigation Reasons for conducting investigations

More information

Request for Proposal (Sample Language) For a. Fire Station Alerting System

Request for Proposal (Sample Language) For a. Fire Station Alerting System Request for Proposal (Sample Language) For a Fire Station Alerting System Copyright 2014 US Digital Designs, Inc. Rights reserved under the copyright laws of the United States (revised 8/2014) PROJECT

More information

Health & Safety at Work

Health & Safety at Work Ministry of Labour Worker Health & Safety at Work Prevention Starts Here Worker Health and Safety Awareness in 4 Steps This workbook belongs to: Table of Contents Introduction 4 Step 1: Get on Board 5

More information

Risk. Risk Categories. Project Risk (aka Development Risk) Technical Risks. Business Risk. Example: Project Risk. Lecture 5, Part 1: Risk

Risk. Risk Categories. Project Risk (aka Development Risk) Technical Risks. Business Risk. Example: Project Risk. Lecture 5, Part 1: Risk Risk Lecture 5, Part 1: Risk Jennifer Campbell CSC340 - Winter 2007 The possibility of suffering loss Risk involves uncertainty and loss: Uncertainty: The degree of certainty about whether the risk will

More information

USER MANUAL. WCM WEB Warranty Claim Management

USER MANUAL. WCM WEB Warranty Claim Management USER MANUAL WCM WEB Warranty Claim Management Issue May 2014 Type WCM Release Version V2.6.1 updated May 13 st Pages 127 We accept your updates and proposals for the document with pleasure. Please send

More information

FCX Department of Occupational Health and Safety Policy

FCX Department of Occupational Health and Safety Policy FCX Department of Occupational Health and Safety Policy Lockout/Tagout/Tryout (LOTOTO) (Control of Hazardous Energy Sources) Approval Date: 08/29/2014 Original Date: 03/09/2009 Policy # FCX-04 Revision

More information