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https://sm.asisonline.org/Pages/Preserving-Precious-Property.aspxPreserving Precious PropertyGP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a43444652018-07-01T04:00:00Zhttps://adminsm.asisonline.org/pages/holly-gilbert-stowell.aspx, Holly Gilbert Stowell<p>​In late 2011, Ricardo Sanz Marcos received a disturbing phone call. As a consultant with the cultural properties firm PROARPA Security Asset Protection and Cultural Heritage, he was used to receiving security inquiries about cultural properties, but he dreaded this type of news the most. An ancient Roman villa known as the Villa of Santa Cruz, in the province of Burgos, Spain, had been robbed.</p><p>Thieves had carelessly removed tiles from a centuries-old mosaic, called "The Return of Bacchus of India," situated in the middle of the house. The 5th century floor mosaic, which depicted a Roman god, was one of the largest and best preserved in Europe and was rare for its size of 66 square meters. </p><p>"The mosaic was destroyed when they stole it," Sanz Marcos recalls. "It was a pity because it was a beautiful mosaic." </p><p>Normally, art thieves who rob archaeological sites are careful to preserve the works they steal, but Sanz Marcos notes that the economic crisis in Spain has left many thieves desperate to make off with precious artifacts. </p><p>Thankfully, the artwork was restored to match the original as closely as possible. "Now there is a replica of the mosaic at the site," he notes. "The art technicians are very talented." </p><p>After the incident, which occurred in December 2011, Sanz Marcos was called to evaluate security measures at the Roman villa and assess how they could be improved. He says that visit was when he "fell in love" with an ancient archaeological site in Spain, known as the site of Colonia Clunia Sulpicia, not far from the villa. </p><p>Just a few years later, Sanz Marcos and a fellow cultural properties expert would complete a comprehensive site and survey risk assessment for the ancient archaeological site, one of only a few such assessments ever conducted.  ​</p><h4>Cultural Properties</h4><p>For ASIS Cultural Properties Council member James Clark, CPP, bringing value to the international membership around cultural properties security was a challenge he wanted to solve. "We were trying to increase our own knowledge base and our own body of knowledge, because we really needed that," he says of the council. "Things are going on in Europe that haven't been going on in the United States—there's the whole business of terrorism at sites in Syria, and a few years ago in Iran." </p><p>Threats. Clark, managing partner of Clark Security Group, LLC, an independent security consultancy in Cleveland, Ohio, notes that terrorism has had a destructive effect on cultural properties worldwide. Many headlines have been dedicated to Syria, where the Islamic State has purposefully destroyed countless ruins and artifacts.</p><p>But warfare is not the only threat to these historic sites. People who simply pick up relics, not understanding or knowing their value, can be a major threat to site preservation, he says. Lack of preventative measures, such as onsite security and technology systems, puts cultural properties at risk as well. </p><p>"My experience in South America and Central America—in Mexico in particular—is that there are varying degrees of security," he says. "There are some really fabulous sites in Mexico where there is no security. There are sites all over Central America—even Machu Picchu in Peru—that have periodic security. It's a challenge in all these places." </p><p>So, when Clark met fellow council member Ricardo Sanz Marcos, they immediately connected over their joint desire to bring more recognition and security to international cultural properties. </p><p>"We hit it off pretty quickly, and we started talking about how we could bring benefit to what he's been practicing in Europe, and particularly in Spain," Clark says. </p><p><strong>CRISP Grant.</strong> Sanz Marcos was passionate about creating a standard of protection for smaller cultural properties around the world that didn't draw the same level of attention as larger sites like the Mayan Ruins, or other locations designated as World Heritage Sites by the United Nations Educational, Scientific, and Cultural Organization (UNESCO). </p><p>"South of the Mexican border, down to South America, the south of Africa, the southwest of Asia—they are developing countries and they don't have the same level of industry or economy as developed nations, but they have cultural properties in the middle of the jungle or the middle of the desert," Sanz Marcos says. "That was the cornerstone of the Clunia report, to make a standard of protection for cultural properties in developing countries."</p><p>He and Clark worked with then council chair Robert Carotenuto, CPP, PCI, PSP, associate vice president of security at the New York Botanical Garden, to write a CRISP (Connecting Research in Security to Practice) grant proposal to the ASIS International Foundation. Carotenuto says that he hoped the grant would give the council a way to produce a document of critical significance for the field and international members. </p><p>Carotenuto credits former ASIS Foundation Board member Dr. Arthur Kingsbury, CPP, who had extensive experience in archaeological security, and Gary Miville, another former Cultural Properties Council chair, with helping them put together the grant. </p><p>After submitting the proposal, they were awarded the CRISP grant, and chose to do several site surveys and a security risk assessment at the place near and dear to Sanz Marcos's heart—Clunia. </p><p>"The grant was helpful because it gave us the ability to pick a topic, a subject, and a location that were nonthreatening," Clark says, referring to the lack of terroristic threat in Spain. "But there were some challenges because it was in a remote location, it's a huge property, and nobody was really taking care of it to a great degree." They began their research in November 2016, and published their findings in a CRISP report in January 2018. </p><p>Clark and Sanz Marcos conducted a four-day site survey, assessed the threats and risks to the property, and provided recommendations for increasing security at Clunia. They paid visits to nearby historic sites as well, and conducted meetings with stakeholders, including employees working on-site, cultural ministries, mayors of surrounding towns, and a security advisor in charge of the site's contract with Securitas. </p><p>Based on their findings, the authors provided detailed recommendations to the stakeholders, which they hoped would increase tourism, community involvement, and overall prosperity at Clunia. </p><h4>Challenges</h4><p>Clunia is situated on a plateau in the Province of Burgos in the Castilla y León region of North Central Spain, approximately 150 miles north of Madrid. The location is all but remote, nestled next to the town of Peñalba de Castro, which has a population of fewer than 85 people. Excavation of the site began in 1915, and archeologists found over the following decades that the colony was once a significant Roman city of the Iberian Peninsula, known as Hispania. </p><p>Clunia, which dates to the first century BC, is believed by scholars to be "the most representative of all the archaeological ruins that have been found from the Roman period in the Northern Iberian Peninsula," according to the site survey. The site includes a forum with a basilica, a temple, Roman baths, an aqueduct, and one of the largest theaters on the peninsula. Pottery, mosaics, sculptures, Roman coins, glass, and pieces of jewelry have been discovered at the site, as well as Christian symbols that indicate one of the first Christian communities in Hispania may have lived in Clunia. </p><p>The inhabitants were skilled, Clark says, as evidenced by the colony's remains. "They had farms, they had grain, they grew grapes, they made wine, they had hot and cold running water, and they were phenomenal engineers," he notes. "They could do whatever they wanted because they had those skills."</p><p>Still, only about 15,000 visitors a year come to see Clunia. Limited financial resources were found to be a major factor contributing to the site's poor security, with most funds coming from public administration budgets.</p><p><strong>Threats.</strong> Clunia's remote location, Clark explains, contributes to the property's security challenges. "The police response is an hour away," Clark notes, based on information he received from the Spanish Ministry of Culture. He adds that the threat of fire, as well as fire response, is another obstacle. The area is mostly dry grassland, making it prone to brushfires, and departments have limited resources to fight blazes in large remote areas. </p><p>"Those are the primary issues: fire, theft, and then just damage to the site," Clark notes. "When the grasslands are destroyed, the rains just wash away the soil which takes away the protection of the yet-to-be uncovered ruins." </p><p>While terrorism was not found to be a significant risk to Clunia, one of the biggest challenges was theft of material over time from the site. Security around the 6-kilometer (3.5 mile) perimeter and within the site was severely limited, leaving precious artifacts exposed to potential theft and the fragile ruins unguarded. </p><p>"The town right next to the site has homes and buildings adorned with all kinds of artifacts from Clunia, and anybody can go to the site and pick something up," Clark says. "Fortune seekers who bring their metal detectors in are able to find Roman coins and other objects that were obviously not excavated." </p><p>With limited security patrols, intruders were often able to dig large numbers of holes in search of artifacts. "On a single day in 2015, site personnel discovered more than 165 holes dug into the ground by unknown intruders who had sufficient time to render such destruction without discovery," they write in the report. "It is unknown what, if anything, was removed during these incidents."</p><p>While there was a lock on the gate that guarded the site entrance, several keys had been given out to members of the community, and to shepherds who needed to pass through with their flocks to graze.</p><p><strong>Resources.</strong> Clark and Sanz Marcos found in their assessment that security personnel and technologies at Clunia were severely limited. During public hours, a staff member who sold tickets at the gate and a guide who explained the history of the site were the only people consistently on the property. Additionally, a contract guard worked between 11:00 p.m. and 6:15 a.m., but the guard had no patrol vehicle to make tours. </p><p>The visitor center and artifact building, plus specific high-value artifacts inside, had alarm systems, but no one was monitoring video in real time. And with slow law enforcement response times, even if an alarm was triggered, the bad actors would have time to get away. ​</p><h4>Recommendations</h4><p>Based on their assessment, Clark and Sanz Marcos made several recommendations to increase both security and community involvement at Clunia. Their final recommendation was a holistic security approach with three components. The approach aimed to get the community on board with a sense of ownership of Clunia, provide policies and practices that complement the security technology and officers in place, and provide those officers with tools and technology that allow them to deter or stop bad actors from accessing the site. </p><p><strong>Intrusion detection.</strong> The authors recommended several security technologies, providing a detailed summary of costs for each specific purchase, such as re-keying the perimeter gates, adding thermal cameras, and purchasing an all-weather, all-terrain vehicle for the security guard. </p><p>Re-keying the gate would solve the issue of several missing keys that had been given out over the years. But the authors recommended that shepherds could continue grazing on the property, because it turned out the sheep helped prevent fire outbreaks by eating the dry brush. </p><p>Strategically placed cameras would notify security staff when someone penetrates the fence or trespasses on the site. "One of the technologies that we recommended were thermal imaging cameras mounted on poles, which can detect movement or motions up to a mile," Clark says. "We recommended four or five of those on the site."</p><p>Establishing a full-time security presence during all hours Clunia is closed to the public was suggested, which would include two officers: one to staff a control center within the visitor center, and another to perform patrols.</p><p>Clark adds that a new visitors center currently under construction could house a new video monitoring location and would serve as a further deterrent to people trying to desecrate the site. "This would allow people to park their vehicles, go through a pedestrian gate, go through the visitors center, pass a small museum there, then go up on the site," he says. "They wouldn't be able to bring metal detectors and shovels—and things of that nature—where they could desecrate the site." </p><p><strong>Community awareness.</strong> Because the Spanish Cultural Ministry has limited financial resources, Clark and Sanz Marcos determined that increasing community buy-in around Clunia could generate more revenue for protecting it. By educating surrounding communities about the history and significance of the site, the authors indicated the value that Clunia could bring to restaurants, hotels, and other nearby merchants. </p><p>"This process should begin by first working with community leaders such as mayors, legislative representatives, and business people, followed by focused community meetings, informational brochures, and regular communications from the cultural ministry," they write in the report. </p><p>They suggested a training program to educate schools, neighborhood associations, and other institutions about Clunia, and recommended a marketing strategy in conjunction with nearby properties to draw tourism. </p><p>Sanz Marcos iterates the importance of community buy-in for the success of any historic site. "If you transform the cultural property into a sustainable industry that creates jobs, health, wealth, and a better life for the population around it, you can preserve the property," Sanz Marcos notes. "We have to leave our cultural properties for our children in better condition than we received them."</p><p>While Clunia was Clark's first archaeological site survey, he has performed risk assessments at museums, libraries, and other cultural properties throughout his career. He says he found that the basic principles of effective physical security applied to Clunia. "The biggest surprise to me was how relatively simple the solutions are," he says. "You really need to do vulnerability assessments on all these sites. There's a lot of common ground here. but there are also a lot of idiosyncrasies about each individual site."</p><p>Carotenuto echoes the importance of paying attention to the uniqueness of each cultural property and says it's a best practice for any risk assessment. "As security professionals, we don't just go in and tell someone, 'Well, this is what you need,'" he says. "It has to be tailored to that environment, it has to fit with the culture of that place, and that to me is the most interesting thing about the Clunia report—they realized they needed to embrace the culture of that site." </p>

Public/Private Partnerships

 

 

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https://sm.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://sm.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. 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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. 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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