Public/Private Partnerships

 

 

https://adminsm.asisonline.org/Pages/An-Expert-Partnership.aspxAn Expert PartnershipGP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a43444652018-02-01T05:00:00Zhttps://adminsm.asisonline.org/pages/megan-gates.aspx, Megan GatesMegan Gates and Laura Meyers, PSP<p>​It was a monumental task. The Ontario Provincial Police (OPP) needed to conduct security assessments of all the courthouses in the province it polices—approximately 100 locations—with only three people to carry out the work.</p><p>In an unprecedented move, Security Assessment Unit Sergeant Laura Meyers, PSP, proposed bringing in outside help from the private sector. Senior executives approved of the idea, and Meyers reached out to the ASIS Toronto Chapter to bring on Michael Thompson, CPP, PCI, PSP, and Gregory Taylor, CPP, PSP. </p><p>Both had public sector experience—Taylor was former military and Thompson a former Toronto police officer. Meyers thought those qualifications, along with their extensive security backgrounds, would not only help them conduct the assessments OPP needed, but also gain the respect of OPP officers they would be working with in the field.</p><p>Her predictions were correct. Taylor and Thompson were well received, and the project was completed on time without exhausting OPP's resources—funding or personnel—to complete. It also marked a new era with OPP in bringing security professionals in-house to assist law enforcement in addressing security threats.​</p><h4>The Mandate</h4><p>In 2007, the province of Ontario issued the Ontario Public Service Physical Operating Policy, which required all public service facilities within the province to complete a physical security threat risk assessment. </p><p>The OPP, which polices more than 1 million square kilometers of land and waterways in Ontario, was subject to this mandate. It's one of North America's largest deployed services with more than 5,800 uniformed officers, 2,400 civilian employees, and 830 auxiliary officers. </p><p>To comply with the mandate, the OPP's four-member Security Assessment Unit was assigned to carry out threat assessments of more than 200 facilities across the province. The four members went to each region and trained OPP staff at the facilities on crime prevention through environmental design (CPTED) strategy and the Royal Canadian Mounted Police's (RCMP) Harmonized Threat Assessment Methodologies. </p><p>"It was like a mass attack for the four-person unit to do that within a couple of years," Meyers says. "By 2011, all [facilities] were visited and threat assessments completed." </p><p>During that time frame, Staff Sergeant Rob Fournier was placed in charge of the newly created OPP Justice Officials Protection and Investigations Section (JOPIS). The section was created in 2009 to ensure the safety and protection of justice officials and to address threats, harassment, and intimidation directed at justice officials.</p><p>The Security Assessment Unit and JOPIS regularly began working together to address threats, and in 2015, JOPIS was instructed to complete physical security threat risk assessments on all justice facilities in the province.</p><p>Meyers and Fournier both knew it would be a major task to carry out the assessments, especially if they had to train additional OPP staff to conduct them. </p><p>"In the police world, when you're building your team you're looking for an individual with a ton of experience," Fournier says. "In the security aspect, we have to use that same premise. Why would you want to be retraining someone in security work, when you can get someone who's been involved for years?"</p><p>Meyers and Fournier were both active in the ASIS Toronto Chapter, so they pitched the idea of contracting out the justice facility assessments to a few security professionals they knew through the chapter.</p><p>The idea was approved, and Meyers and Fournier recruited two security professionals with certifications and backgrounds in the public sector—Thompson and Taylor. ​</p><h4>Justice Site Visits</h4><p>After Thompson and Taylor were brought on board, they traveled to 92 different sites across the province—ranging from remote areas to urban settings, with everything from historic courthouses to courtrooms in mini plazas.</p><p>Their job was to review each site, evaluate the training protocols, and identify any gaps that might pose vulnerabilities, Fournier says. </p><p>Thompson's and Taylor's recommendations were critical at one site in particular following a series of events over a six-month period that impacted the security of the facility in eastern Ontario. </p><p>During that six-month period, a local individual murdered three former lovers. Law enforcement launched an extensive manhunt to locate the person. During that same time frame, an OPP officer was threatened and forced to temporarily relocate for personal safety. And there was another unrelated high-risk threat to an officer at the facility. </p><p>"There were obviously a bunch of people at that older facility, and it needed attention," Fournier says. Thompson and Taylor were able to take the previous threat assessment of the facility and suggest specific actions to take to address the new vulnerabilities due to the heightened threat environment.</p><p>The facility then improved its exterior parking lot lighting, and made other changes that Fournier could not disclose due to security concerns. </p><p>This process of going back to reassess facilities has helped the province distribute its funds to better address security concerns, Fournier says. </p><p>"It's helped paint the picture when we're earmarking where limited funds are going, to say, 'This might not be on your list but it's on ours,' and that helps get things done sooner," he adds.​</p><h4>OPP Sites Revisited</h4><p>While Thompson and Taylor were wrapping up the justice site assessments, the OPP decided to update its original threat assessments that were completed in the wake of the 2007 mandate. </p><p>"Some of the recommendations from that set were dated, not the best security practices," Meyers says. "So, we came up with a criticality schedule—how often we should revisit them…looking at it as a continual working project."</p><p>To carry out this work, OPP once again reached out to the Toronto Chap­ter; this time to Chapter President Patrick Ogilvie, CPP, PSP. Meyers knew that Ogilvie was looking to both build his personal brand as a professional and give back to the community. </p><p>Ogilvie is currently conducting this second round of threat assessments, using the RCMP methodology that was established during the initial round. Having that first set of assessments has been a useful benchmark, Ogilvie says, to score threats and vulnerabilities and then make actionable recommendations for the facilities. </p><p>"Even before I step foot onto a facility, I communicate with commanders that I'm looking for documented evidence or stories of different threats and occurrences," he adds. "I get them thinking not as police officers, but essentially as security people who can identify different threats and vulnerabilities that they have experienced."</p><p>This is because sometimes a security threat hasn't been identified by law enforcement because it is not a deliberate act—such as vandalism—that is intended to harm the facility.</p><p>For instance, Ogilvie says he found that most facilities did not identify building structure or leaks as vulnerabilities.</p><p>"What I found in getting out and talking to [people] was that accidents were happening, natural hazards that could have an impact on our business, and our business is policing," he explains. But because these threats weren't identified, nothing was being done to address or mitigate them.</p><p>Ogilvie has made it a point to educate OPP personnel at the facilities that he's looking at all threats—deliberate acts, accidents, and natural hazards—that could harm the organization. For instance, a leak in the facility could cause structural decay and ultimately become a hazard for personnel inside. </p><p>Thus far, Ogilvie says the OPP officers he's interacted with have been receptive to his suggestions, and Meyers adds that the feedback she's received has been highly positive—including that security deficiencies have been pointed out in a respectful manner.</p><p>Due to the success of the program, Fournier says that several First Nation police services across the province have reached out to OPP for assistance on conducting similar threat assessments. </p><p>Many of these facilities, especially in the northern part of Ontario, are in remote locations and have deteriorated or don't adhere to the same standards as other facilities in Ontario. To address this, OPP is working with the police programs to conduct threat assessments of approximately 15 different sites. </p><p>The Security Assessment Unit has also been called on to provide assistance to Ontario government facilities—overviews, recommendations, and security advice—because they have proved themselves in the field. </p><p>It has also showcased how civilian personnel can be brought in to a law enforcement agency to help in addressing security concerns. </p><p>Ogilvie, Thompson, and Taylor are all under contract right now using existing funding that OPP secured. Down the road, Fournier says he hopes to change a few positions in the Security Assessment Unit to hybrid roles that either a police or civilian security professional could fill.  </p><p><em>Laura Meyers, PSP, is a Sergeant in the Ontario Provincial Police. ​</em><br></p>

Public/Private Partnerships

 

 

https://adminsm.asisonline.org/Pages/An-Expert-Partnership.aspx2018-02-01T05:00:00ZAn Expert Partnership
https://adminsm.asisonline.org/Pages/A-Day-Devoted-to-Education.aspx2017-09-26T04:00:00ZA Day Devoted to Education
https://adminsm.asisonline.org/Pages/Greipp-Scholarship-Recipients-Named.aspx2017-09-25T04:00:00ZGreipp Scholarship Recipients Named
https://adminsm.asisonline.org/Pages/FEMA,-CSOs-Assess-Dynamic-Situation-in-Houston.aspx2017-08-29T04:00:00ZFEMA, CSOs Assess Dynamic Situation in Houston
https://adminsm.asisonline.org/Pages/Interoperability-for-the-Safe-City-.aspx2017-08-21T04:00:00ZInteroperability for the Safe City
https://adminsm.asisonline.org/Pages/Houston’s-Game-Day-Solutions.aspx2017-07-01T04:00:00ZHouston’s Game Day Solutions
https://adminsm.asisonline.org/Pages/The-Road-to-Resilience.aspx2017-02-01T05:00:00ZThe Road to Resilience
https://adminsm.asisonline.org/Pages/Silencing-False-Alarms.aspx2016-12-06T05:00:00ZSilencing False Alarms
https://adminsm.asisonline.org/Pages/Playing-Clean.aspx2016-12-01T05:00:00ZPlaying Clean
https://adminsm.asisonline.org/Pages/First-Ever-U.S.-Outstanding-Security-Performance-Awards-Held-at-ASIS-2016.aspx2016-10-25T04:00:00ZFirst-Ever U.S. Outstanding Security Performance Awards Held at ASIS 2016
https://adminsm.asisonline.org/Pages/Book-Review---Emergency-Management.aspx2016-10-24T04:00:00ZBook Review: Emergency Management
https://adminsm.asisonline.org/Pages/Terrorism-Trends.aspx2016-09-01T04:00:00ZTerrorism Trends
https://adminsm.asisonline.org/Pages/Industry-News-August-2016.aspx2016-08-01T04:00:00ZIndustry News August 2016
https://adminsm.asisonline.org/Pages/-Wanted---Private-Sector-Help.aspx2016-02-12T05:00:00ZWanted: Private Sector Help
https://adminsm.asisonline.org/Pages/Rising-Resilience.aspx2015-10-05T04:00:00ZRising Resilience
https://adminsm.asisonline.org/Pages/Book-Review--The-Business-of-Counterterrorism.aspx2015-09-01T04:00:00ZBook Review: The Business of Counterterrorism
https://adminsm.asisonline.org/Pages/Communication-in-Crisis.aspx2015-09-01T04:00:00ZCommunication in Crisis
https://adminsm.asisonline.org/Pages/SM-Online-August-2015.aspx2015-08-01T04:00:00ZSM Online August 2015
https://adminsm.asisonline.org/Pages/A-New-Cyber-Nucleus.aspx2015-07-06T04:00:00ZA New Cyber Nucleus
https://adminsm.asisonline.org/Pages/60-Years---July.aspx2015-07-01T04:00:00Z60 Years: July

 You May Also Like...

 

 

https://adminsm.asisonline.org/Pages/Book-Review---The-Handbook-of-Security.aspxBook Review: The Handbook of Security<p><span style="line-height:1.5em;">Editor Martin Gill has collected essays from more than 50 well-credentialed and respected authors to create a superb holistic catalog of security.  The Handbook of Security, Second Edition, builds upon the first edition with a wider array of subject matter and a greater diversity of topics, resulting in a more exciting study of the field and profession of security.  </span><br></p><p>Beginning with a comprehensive historical look at the security industry, the book goes on to answer fundamental questions about the range of threats facing today’s world. It looks at how current economic conditions—far different from when the previous edition was first published—have affected the profession and agencies responsible for predicting and reacting to crime, and to what degree technological advances have impacted our world. The overall result is that security has become a dominant feature in our lives, whether we know it or not.</p><p>Although, at more than 1,000 pages, The Handbook of Security can appear daunting, this is indeed essential reading for all those involved with the security world. Both the student of security and the security professional will become engaged in the content, from the historical study of security as a discipline to the long-range issues impacting the profession. Among other things, it addresses crimes by offense and by industry, risk management, security processes, research in the field, and ethical issues. One shortcoming of the book is that it does not provide many charts or graphs to illustrate and support the material, though the flow of the text sufficiently covers the information.  </p><p>This book has significant value to security professionals at all levels as well as being a valuable research tool for the academic world of security management. It will soon be dog-eared and filled with bookmarks as are the invaluable resources in any professional’s library.</p><p><em><strong>Reviewer: Terry L. Wettig, CPP</strong>, is director of security risk management for Brink’s Incorporated and is based in Richmond Virginia. A retired U.S. Air Force chief master sergeant, he is studying for a Ph.D. in organizational psychology.  </em></p>GP0|#28ae3eb9-d865-484b-ac9f-3dfacb4ce997;L0|#028ae3eb9-d865-484b-ac9f-3dfacb4ce997|Strategic Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465
https://adminsm.asisonline.org/Pages/Training-Your-Team.aspxTraining Your Team<p>​</p><p>Whether the action is on the battlefield or the basketball court, you can be certain that the winning team owes its success in large measure to extensive training. Recognizing the importance of training to any team’s performance, the Cincinnati Children’s Hospital Medical Center set out to makes its own training program better. </p><p>The existing training program, which the director of protective services felt lacked specificity, consisted of one of the shifts’ veteran officers sitting with the new security employees and covering several department and hospital-specific policies along with administrative topics. Additionally, the new officers would be given several commercially produced security training videotapes to view, after which they were required to complete the associated tests. Following the completion of the tapes and review of the policies and administrative procedures, officers would go through brief hands-on training for certain subjects such as the use of force and pepper spray.</p><p>Once they completed these tests and training sessions, the officers would then begin their on-the-job training. Officers have historically stayed in the on-the-job phase of training between three and five weeks, depending on how quickly the officers learned and were comfortable with command center operations. When the officers completed their training program, they had to pass the protective services cadet training test as well as a test on command center procedures.</p><p>Training council. To help devise a better training program, the security director chose several members of the staff to sit on a training council. The group, which included the director, three shift managers, and the shift sergeants, met to discuss the current training program and what could be done to enhance it.</p><p><br>Through discussions with new employees, the council learned that the existing program was boring. The council wanted to revitalize the training to make it more interesting and more operationally oriented. The intent was to emphasize hands-on, performance-oriented training. The council also wanted to improve the testing phase so that the program results could be captured quantitatively to show the extent to which officers had increased their knowledge and acquired skills. <br> <br>Phases. The council reorganized training into four phases: orientation, site-specific (including on-the-job), ongoing, and advanced. Under the new program, the officers now take a test both before training, to show their baseline knowledge, and after the training, to verify that they have acquired the subject matter knowledge; they must also successfully demonstrate the proper techniques to the instructors.</p><p>Orientation training. The orientation training phase begins with the new employees attending the hospital’s orientation during their first day at the facility. The security department’s training officer then sits down with the new officers beginning on their second day of employment. This training covers all of the basic administrative issues, including what the proper clock-in and clock-out procedures are, when shift-change briefings occur, and how the shift schedules and mandatory overtime procedures function.   </p><p>The training officer also administers a preliminary test to the new officers that covers 12 basic security subjects including legal issues, human and public relations, patrolling, report writing, fire prevention, and emergency situations. New employees who have prior security experience normally score well on the test and do not need to view security training tapes on the subjects. The officers must receive a minimum score of 80 percent to receive credit for this portion of the training. If an officer receives an 80 percent in most topics but is weak in one or two subjects, that officer is required to view just the relevant tapes, followed by associated tests.</p><p>All officers, regardless of the amount of experience, review the healthcare-specific tapes and take the related tests for the specific subjects including use of force and restraint, workplace violence, disaster response, bloodborne pathogens, assertiveness without being rude, and hazardous materials. Also included in the orientation training phase are classes covering subjects such as pepper spray, patient restraint, defensive driving, and the hospital’s protective services policies.</p><p>Site-specific training. During site-specific training, officers learn what is entailed in handling specific security reports. The shift manager, shift officer-in-charge, or the training officer explains each of the reports and has the new employee fill out an example of each. Examples of reports covered in site-specific training include incident reports, accident reports, field interrogation reports, fire reports, motorist-assist forms, ticket books, safety-violation books, broken-key reports, work orders, bomb-threat reports, and evidence reports.</p><p>On-the-job training is also part of the site-specific training phase. The new employee works with a qualified security officer for a period of two to three weeks following the first week of orientation training with the departmental training officer. The new employee works through all of the various posts during this time. At least one week is spent in the command center. The site-specific phase of training culminates with both the security officer cadet training exam and the command center exam, which were also given in the original program.</p><p>Ongoing training. The ongoing training includes refresher training in which shift managers have their officers review selected films covering healthcare security and safety subjects. The training occurs during shift hours. The officers also receive annual refresher training covering topics such as using pepper spray and employing patient-restraint methods.</p><p>Another type of ongoing training, shift training, is conducted at least weekly. Managers conduct five-to ten-minute meetings during duty hours to refresh the security staff on certain subjects, such as customer service. These sessions are not designed to deal with complex topics. Managers can tie these sessions to issues that have come up on the shift.</p><p>Advanced training. Advanced training includes seminars, management courses, and sessions leading to professional designations and certifications. Qualified personnel are urged to attend seminars sponsored by several professional societies and groups such as ASIS International, the International Healthcare Association for Security and Safety, and Crime Prevention Specialists. Staff members are also encouraged to attain the Crime Prevention Specialist (CPS) certification, the Certified Protection Professional (CPP) designation, and the Certified Healthcare Protection Administrator (CHPA) certification.</p><p>Staff members are urged to pursue special interests by obtaining instructor certification such as in the use of pepper spray or the use of force. This encouragement has already paid off for the hospital. For example, the department’s security systems administrator has trained officers on each shift in how to exchange door lock cylinders, a task that would previously have required a contractor. Officers are currently being trained to troubleshoot and repair CCTV, access control systems, and fire alarm equipment problems.</p><p>Training methods. A special computer-based training program was developed to help quantify and track the success in each of the training modules. Additionally, a program was developed to present training subjects during shift changes.</p><p>Computer training. Security used off-the-shelf software to create computer-based training modules and included them in the site-specific training and ongoing training phases, both of which occur during shift hours. The training council tasked each shift with creating computer-based training modules for the various security officer assignments on the hospital’s main campus and off-campus sites. These training modules cover life safety, the research desk, the emergency department, exterior patrols, foot and vehicle patrols, and the command center.</p><p>The training council asked officers to participate in the creation of the computer-based training modules. The officers produced the training modules during their respective shifts when it did not interfere with other responsibilities.  </p><p>The group participation paid off. For example, the officers who created the command center and the emergency-department training modules not only spent several hours discussing what information should be included in the modules, but then allowed their creativity to flow by using the software to make these modules interactive. These particular modules include test questions of the material, and the program will respond appropriately to the employees as they answer the questions correctly or incorrectly. The volunteers also created tests for before and after an officer goes through each of the computer modules to track the effectiveness of the training.</p><p>Shift-change training. A major question with ongoing training is how to fit it into the officer’s routine. For most industries using shift work, difficulties arise when trying to carve out enough training time without creating overtime. The training council decided to take advantage of downtime that occurs as officers come to work ready for their shift to begin. They are required to show up six minutes before the shift. This time is now used for training.</p><p>The shift-change training is used to cover specific topics—already covered in some of the training phases—that can be easily encapsulated into a six-minute program. For example, some topics include departmental policies, radio communication procedures, command center refresher sessions, self-defense subjects, confronting hostile people, proper report writing, and temporary restraint training. By implementing the shift-change training sessions on a weekly basis, the department created an additional five hours of training per year for each officer.</p><p>One of the security supervisors created a six-minute training binder to house all of the lesson plans. Each shift supervisor uses the same lesson plan so that the training is consistent across the shifts. As with all other training, the before-and-after tests are given to quantitatively document changes in subject knowledge or skills.</p><p>Results. After implementing the training program, the training council wanted to check the initial results to see whether the training was effective. There were numerous quantifiable measurements that the council could use to evaluate the new training program, such as tracking the rate of disciplinary actions from the previous year to the current year. However, since the council desired to have a quick assessment of the training program changes, it decided to compare the after-training test scores to the before-training test scores for the computer-based training modules as well as the scores of the six-minute training tests. </p><p>To the council’s surprise, the initial tabulated scores resulted in an average before-training test score of 93 percent and an after-training test score of 95 percent. The council also found in many of the officers’ tests that they missed the same questions on both the before and after tests.</p><p>Based on these results, the council decided to make several changes. First, the test questions were reviewed and tougher questions were added. Based on the preliminary test score, the council felt that the questions were not challenging enough and might not indicate how competent the officers were with the subject matter. </p><p>The training council assigned each shift the task of revising the tests for their computer-based training modules as well as the six-minute training tests. The goal was to make the tests more challenging and to obtain more accurate assessments of the effectiveness of the training program. </p><p>The training council also reviewed how the different shifts were conducting the six-minute lessons. Managers noted that the shifts initially followed the schedule of the six-minute subjects from week to week, but then they began to conduct their own lessons without an accepted lesson plan or to forgo training altogether. </p><p>To avoid this problem, the training council determined that the training program needed to be more structured. The group created a schedule to indicate which class would be covered each week. One of the shift supervisors volunteered to take over the six-minute training program and formally structure it so that each shift would conduct training in a consistent manner.</p><p>The training council has plans to further hone the training program in the near future. The council plans to analyze the program us­ing other quantitative evaluative instruments such as an employee survey and a comparison of disciplinary action data from previous years. </p><p>In battle, it is said that an army fights as it has trained. Thus, commanders know the value of training. In the businessworld, though the stakes are different, training is no less critical to the success of the mission.</p><p>Ronald J. Morris, CPP, is senior director of protective services at Cincinnati Children’s Hospital Medical Center. Dan Yaross, CPP, is manager of protective services. Colleen McGuire, CPS (crime prevention specialist), is sergeant of protective services. Both Morris and Yaross are members of ASIS International.</p>GP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465
https://adminsm.asisonline.org/Pages/The-Dirty-Secret-of-Drug-Diversion.aspxThe Dirty Secret of Drug Diversion<p>​Controlled substances were going missing at Hennepin County Medical Center (HCMC), and the hospital’s security investigator, William Leon, was determined to get to the bottom of it. So, at 11 p.m. on a Friday, Leon settled in for a night of observation at the Level I trauma center in Minneapolis, Minnesota. He kept a trained eye on one registered nurse who was suspected of stealing hydromorphone, an opioid pain medication, for her personal use.</p><p>HCMC has cameras set up in the medication room to monitor controlled substances, and Leon watched as the nurse began gathering prescribed medication for a patient in the emergency department. The process, called wasting, requires the healthcare worker to take a fresh vial or syringe full of medication and then dispose of the excess, leaving only the correct dosage—all with a witness present. Leon observed the nurse dispense a syringe of hydromorphone from the medicine cabinet, and, while a fellow nurse was signing off on the withdrawal, she placed the syringe in her pocket and pulled out an identical syringe, which Leon later learned contained saline. The nurse held up the saline syringe and wasted the required amount, tricking her fellow nurse, and left the room.</p><p>At this point, Leon knew exactly what was going on, and watched with increasing alarm as the nurse headed to a patient’s room in the orthopedic area of the hospital. “In that area, I knew immediately, this patient could have a broken bone—they were in intense pain and requiring this medication,” Leon says. “I see a lot of doctors standing around and I’m thinking ‘uh oh, this patient is going to get saline.’”</p><p>Leon raced to the room and saw that the doctors had given the patient the saline the nurse had brought up. “The patient was still screaming in pain and the doctor was frantically asking the nurse, ‘Are you sure you got the right dosage? Are you sure it was hydromorphone?’ and she was insisting she had,” Leon says. He called the doctor and the nurse into the hall and explained that the patient had just gotten saline and still needed the proper pain medication because the nurse had diverted the hydromorphone in the medication room. The doctor went to properly treat the patient and Leon called the nurse manager and the local sheriff’s detective in to begin an official investigation into the nurse’s actions.</p><p>Drug diversion in the United States is a nebulous problem that is widespread but rarely discussed, experts say. Whether in manufacturing plants, retail pharmacies, hospitals, or long-term care facilities, healthcare workers are stealing drugs—typically for their own personal use—and putting themselves, patients, and coworkers at risk. </p><p>“I hate to tell you, but if you have controlled substances and dispense narcotics, you’ve got diversion going on,” says Cherie Mitchell, president of drug diversion software company HelioMetrics. “It’s just a question of whether you know it or not.”</p><p>The scope and frequency of drug diversion is almost impossible to grasp, due in large part to how diversion cases are addressed. A facility that identifies a diversion problem might bring in any combination of players, from private investigators and local law enforcement to state accreditation boards or the U.S. Drug Enforcement Agency (DEA). There is no overarching agency or organization that records every instance of drug diversion in the United States.</p><p>Controlled substance management is dictated by a number of laws, including the U.S. Controlled Substances Act of 1971, which classifies substances based on how they are used and the potential for abuse. It also dictates how the substances are dispensed, and a facility may be fined if it does not comply. </p><p>The closest estimates of drug diversion rates come from people or organizations who dig up the numbers themselves. The Associated Press used government-obtained data in its investigations on drug diversion at U.S. Department of Veterans Affairs (VA) medical centers. Reported incidents of diversion at about 1,200 VA facilities jumped from 272 in 2009 to 2,926 in 2015, the data revealed, and the VA inspector general has opened more than 100 criminal investigations since last October. John Burke, president of the International Health Facility Diversion Association, extrapolated data he obtained from facilities in Ohio to estimate the presence of 37,000 diverters in healthcare facilities across the country each year. </p><p>Mitchell points out that any statistic derived from officially collected data still wouldn’t accurately reflect the extent of drug diversion in the United States. “There’s a lot of people investigators really suspected were diverters but had to be chalked up to sloppy practice due to a lack of concrete evidence, so any statistic is talking about known diverters who are fired for diversion,” she tells <i>Security Management</i>. “Even if you did have a statistic, it would be off because how do you incorporate those so-called sloppy practicers, or diverters who thought they were about to get caught so they quit on you and left? No matter what number you come to, it’s probably bigger in reality.”​</p><h4>Addiction and Diversion</h4><p>Although more people are paying attention to drug diversion due to recent high-profile cases and the current opioid epidemic in the United States, experts say they have been dealing with the same problems their entire careers. </p><p>“I can personally tell you that I dealt with the same issues 15 or 20 years ago that the healthcare arena is facing today, specifically in the drug abuse and diversion by their own hospital healthcare employees,” says Charlie Cichon, executive director of the National Association of Drug Diversion Investigators (NADDI) and a member of the ASIS International Pharmaceutical Security Council. “There are different drugs today, of course, than there were 20 years ago.”</p><p>Susan Hayes has been a private detective for healthcare facilities for more than a decade and says the opioid epidemic has magnified the drug diversion problem in recent years. “The opioid addiction in America has lit my practice on fire,” she says.</p><p>It’s no secret that opioid addiction has reached epidemic levels in the United States. In 2010, hydrocodone prescriptions were filled 131.2 million times at retail pharmacies alone, making it the most commonly prescribed medication, according to the Mayo Clinic. However, those are just the numbers that were legally prescribed—about 75 percent of people who take opioids recreationally get them from a friend or family member. According to the U.S. Centers for Disease Control and Prevention (CDC), approximately 52 people in the United States die every day from overdosing on prescription painkillers.</p><p>Healthcare workers are not immune to the draw of opioids. In fact, up to 15 percent of healthcare workers are addicted to drugs or alcohol, compared to 8 percent of the general population, according to the Mayo Clinic. </p><p>“Healthcare providers are in very stressful jobs,” Hayes says. “They all have problems. Nurses have emotional attachments to patients that they see die. Even orderlies have very stressful physical jobs, they’re lifting patients. Pharmacists can make mistakes that mean life or death. You have people that are already in very stressful situations, and now you give them access to drugs…. I think the combination is almost deadly.”</p><p>While a bottle of 30mg oxycodone tablets can sell on the street for up to 12 times its price in the pharmacy, most drug diverters are addicts using the drugs themselves. Because of this, diversion shouldn’t be considered just a security concern but a patient safety concern, Cichon says. He references several high-profile diversion cases in which the diverters used the same syringe full of medicine on both themselves and their patients, spreading bacterial infections and hepatitis. In one especially egregious case, a traveling medical technician with hepatitis C would inject himself with his patients’ fentanyl and refill the same syringe with saline, ultimately spreading the virus to at least 30 people in two states.</p><p>Unfortunately, experts acknowledge that most diverters don’t get caught until they have been diverting for so long they start to get sloppy. “The people who are your real problem are the people who are hiding in the weeds, not doing enough to get caught, and those are the ones you want to find,” Mitchell says. “The people they are finding now are the people that have the needle in their arm or somebody has reported them. You want to try to find them before that.”​</p><h4>Out of the Loop</h4><p>Hayes details the path of drugs through a hospital: a pharmacy technician orders the medication from a wholesaler, who will deliver them to the hospital pharmacy. The drugs are sorted and stocked in the pharmacy, where they will remain until they are brought up to the patient floors and stored in various types of locking medicine cabinets. When a patient needs medication, a nurse goes to the medicine cabinet and dispenses the drug for the patient. </p><p>Another ASIS International Pharmaceutical Council member—Matthew Murphy, president of Pharma Compliance Group and former DEA special agent—describes this as the closed loop of distribution. “Once a drug is outside of the closed loop, when it gets dispensed from a pharmacy or administered by a doctor, it’s no longer in the purview of DEA rules and regulations,” he explains. Drugs are most likely to be diverted during those times when they are in transit or exchanging hands, outside of the closed loop.</p><p><strong>Wholesalers.</strong> When fulfilling a pharmacy’s request for medication, wholesalers have just as much of a responsibility to notice if something is amiss as the pharmacy does. Whether it’s a retail pharmacy or a hospital pharmacy, wholesalers are responsible for cutting them off if they start to request unusually high amounts of opioids. </p><p>In 2013, retail pharmacy chain Walgreens was charged $80 million—the largest fine in the history of the U.S. Controlled Substances Act—after committing record-keeping and dispensing violations that allowed millions of doses of controlled substances to enter the black market. Cardinal Health, Walgreens’ supplier, was charged $34 million for failing to report suspicious sales of painkillers. One pharmacy in Florida went from ordering 95,800 pills in 2009 to 2.2 million pills in 2011, according to the DEA. </p><p>Hayes says the fine against the wholesaler was a wake-up call, and now suppliers use algorithms to identify unusual spikes in orders of opiates. Wholesalers can even stop the flow of medication to pharmacies if they believe diversion is occurring—which can be disastrous to a trauma center, Hayes notes.</p><p><strong>Pharmacies.</strong> To restock the shelves, pharmacy technicians compile lists of what medications they are low on to send to the wholesalers at the end of each day. Hayes notes that many pharmacies do not conduct a retroactive analysis on what is being purchased—which is why wholesalers must pay attention to any unusual changes in orders. She stresses the importance of constantly mixing up the personnel who order and stock medications. </p><p>“If you’re both ordering and putting away drugs, that’s a bad thing because you can order six bottles when you only need five and keep one for yourself,” Hayes notes. </p><p>Similarly, it is important to rotate who delivers the drugs to the patient floors. “John the technician has been taking the drugs up to the floors for the last 20 years,” Hayes says. “Well gee, did you ever notice that John drives a Mercedes and has two boats and a house on Long Island? He makes $40,000 a year, did you ever do any investigation into why?”</p><p><strong>On the floor. </strong>Experts agree that the most egregious diversion occurs during the wasting and dispensing process in scenarios similar to the incident Leon witnessed at HCMC. Mitchell explains that all hospitals have different wasting procedures—some require nurses to waste the medication immediately, before they even leave the medication rooms, while others may have a 20-minute window. Other hospitals may prohibit nurses from carrying medication in their pockets to prevent theft or switching. ​</p><h4>Investigations</h4><p>Any company involved with controlled substances, whether manufacturing, distributing, or dispensing, must be registered with the DEA and must adhere to certain rules and regulations—which aren’t always easy to follow.</p><p>Murphy, who worked for the DEA for 25 years, now helps companies follow mandates he calls “vague and difficult to interpret.” For example, DEA requires anyone carrying controlled substances to report “the theft or significant loss of any controlled substance within one business day of discovery.”</p><p>“This hospital had 13 vials of morphine that ‘went missing’ and someone called me in to find out why,” Hayes says. “They asked me, ‘Are 13 vials substantial or not? Do I really need to fill out the form?’ I counsel them on what’s substantial because the language is very loose.”</p><p>Depending on the frequency or significance of these or similar forms, the DEA may open an investigation, Murphy explains. “DEA will look at these recordkeeping forms and determine if in fact everything has been filled out correctly, that they have been keeping good records,” he says. “If DEA determines that they are lax or have not been adhering to requirements, there could be anything from a fine to a letter of admonition requiring corrective actions.” In more serious cases, DEA could revoke the registration because the activity or behavior was so egregious that it was determined that the facility is not responsible enough, Murphy explains. If a facility loses its DEA registration, it cannot dispense controlled substances.</p><p>However, DEA does not get involved in every suspected case of diversion. “There are only so many DEA diversion investigators, so they have to prioritize what they get involved with,” Murphy says. “It has to be pretty egregious for them to get involved to seek a revocation or fine.”</p><p>That’s where people like Hayes come in. “They want me to come in instead of DEA or law enforcement,” she explains. “I’m a private citizen, I understand law enforcement procedures, and I can help them get at the root of the problem before they call in law enforcement.” </p><p>After an investigation into a diverter is opened, it is unclear what happens to the offender. Hayes says that she typically gathers evidence and gets a confession from diverters, at which point her client calls in law enforcement to arrest them. Leon, who was in charge of diversion in­vest­igations at HCMC for 20 years before becoming a consultant for HelioMetrics, was able to investigate but not interview suspected diverters. He tells <em>Security Management</em> that he would call in a sheriff’s detective to interview the suspect.</p><p>Although most diverters are fired when their actions are discovered, they are not always arrested—it’s often at the discretion of their employer. Depending on the diverter’s role, state accreditation boards—such as those that license nurses and pharmacists—would be notified and could potentially conduct their own investigations. </p><p>Cichon cautions that some hospitals hoping to avoid bad press and DEA scrutiny may look for loopholes. “We found out through the course of investigations that if someone resigns and was not sanctioned it may not be a reportable action,” he says. “If we allow this person to resign rather than take action against him, then we don’t have to report it.”</p><p>Murphy notes that DEA typically has no role in individual cases of diversion. “If the diverter has a license from one of those state agencies, usually it’s required that they be reported, and then it’s up to the board how they proceed with the personal license of the individual,” he says. The DEA doesn’t regulate the personnel—that’s up to the state and the facility. </p><p>Cichon notes that the lack of standards when addressing diversion makes it more likely that offenders could slip through the cracks and move on to continue diverting drugs at another facility. “Unfortunately, there are different laws and statutes in every state that set up some sort of reporting requirements,” he says. “There are medical boards, nursing boards, pharmacy boards, and not every worker even falls under some sort of licensing board for that state.” ​</p><h4>Staying Ahead</h4><p>Due to the stigma of discovering diverters on staff, many hospitals just aren’t preparing themselves to address the problem proactively, Cichon explains.</p><p>“This is something that is probably happening but we’re not finding it,” he says. “The statistics I’ve seen at hospitals that are being proactive and looking at this are finding at least one person a month who is diverting drugs in their facility. If a 300-bed hospital is finding one person a month, and Hospital B has the same amount of staff and beds and is finding nothing…”</p><p>NADDI has been providing training for hospitals to develop antidiversion policies. Cichon notes that many hospitals throughout the country have no plan in place to actively look for diverters. “As big as the issue is, many of them are still just not being that proactive in looking at the possibility that this is happening in their facility.”</p><p>Cichon encourages a team approach to diversion that acknowledges diversion as a real threat. “Not just security personnel should be involved with the diversion aspect,” he says. “Human resources, pharmacy personnel, security, everyone is being brought into this investigation, because the bigger picture is patient safety. The diverting healthcare worker typically isn’t one who’s going to be selling or diverting his or her drugs on the street, but they are abusing the drugs while they are working.”</p><p>Leon worked hard on diversion prevention at HCMC after discovering a surprising pattern: almost all of the diverters he investigated wanted to be caught. “What got me on this path of prevention was observing the nurses as they would admit to what they did,” he explains. “More often than not the nurses would say, ‘I wanted somebody to stop me. I needed help, didn’t know how to ask for it, and I was hoping somebody would stop me.’ That’s pretty powerful when you’re sitting there listening to this on a consistent basis.”</p><p>Leon implemented mandatory annual training for everyone in the hospital—from food service workers to surgeons—to recognize the warning signs of drug diversion. “If a nurse or anesthesiologist or physician is speaking with you and telling you they are having these issues, then you should say something,” Leon explains. “It’s not doing the wrong thing—you’re helping them, and that’s the message we sent out. Look, these individuals are not bad individuals. Something happened in their lives that led them down this path.”</p><p>Leon also had cameras installed throughout the hospital that allowed him to observe diversion but also kept his investigations accurate. “We had a nurse who was highly suspected of diverting,” he says. “With the cameras I was able to show that she wasn’t diverting, just being sloppy. The employees appreciated the cameras because it showed they weren’t diverting medication, they just made a mistake.”</p><p>Over time, HCMC personnel became more comfortable coming forward with concerns about their coworkers. Before the facility started the annual training, Leon caught at least one diverter a month. Before he retired, he says, that number had dropped to one or two a year.</p><p>“The success of our program at HCMC was the fact that we paid more attention to educating rather than investigating,” Leon says. “You have to keep those investigative skills up, but you have to spend equal amount of time on prevention and awareness.”</p><p>Mitchell points to algorithmic software that can identify a potential diverter long before their peers could. Taking data such as medicine cabinet access, shift hours, time to waste, and departmental access allows software to identify anomalies, such as a nurse whose time to waste is often high, or a doctor who accesses patients’ files after they have been discharged. </p><p>“Most people are using the logs from the medicine cabinets trying to do statistical analysis,” Mitchell explains. “You find out 60 days or six months later, or you don’t see that pattern emerge by just using one or two data sets. That doesn’t help. The goal is to identify these people as quickly as possible so they are no longer a risk to themselves or the patients or anyone they work with.”</p><p>Murphy encourages facilities to be in full DEA compliance to mitigate diversion. “If somebody wants to steal or becomes addicted, they are going to find a way to do it, and sooner or later they are going to get caught, but then there’s a problem because the hospital has to work backwards to determine how much was stolen and reconcile all that,” he says. He also notes the importance of following up internally on each diversion case and figuring out what went wrong, and adjusting procedures to address any lapses. </p><p>“Every entity that has a DEA program should have diversion protocols in place because if they don’t they are playing Russian roulette with theft and loss and their DEA registration,” Murphy says.  ​</p>GP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465