Compliance matters! PSM solves your Code problems

This months field challenge:
Ive just moved to a new company as a regional manager, and got a bit of a scare during my first week. At a PCT meeting we were sponsoring, I found the representative setting up the stand and unpacking various leave pieces I didnt recognise. I made sure they were removed before anyone saw them which was very fortunate as, although some were simply old pieces from the last cycle, one should have been withdrawn after being ruled in breach of the Code. How can I make sure this near miss doesnt happen again?

DR JOAN BARNARD and IAN HALE respond:

This cannot be tackled effectively at regional level it is a company issue. So the first thing to do is to alert your management to the problem.

It is essential that your company has a mechanism for timely and complete withdrawal from the field of any material that is in breach of the Code. It is also good housekeeping to routinely withdraw any items that are no longer in use. Both of these objectives can be met by a standard operating procedure (SOP) for company withdrawal.
The withdrawal SOP should ensure that:

1. Clear instructions are given to the field force (and to any storage facility) about what should be withdrawn, with a required timescale.
2. Confirmation is required from every representative of:

receipt of withdrawal instructions

compliance with withdrawal instructions.
3. Confirmations are tracked and any nonresponders chased account must be taken of holidays, sick leave, maternity leave etc.
4. Returned items are logged:

large or single-issue items should be counted

small multiple items can be logged simply as returned, without reconciling numbers.
5. The method of return is convenient for the representative and does not, for example, require them to wait in all day for a courier.

It is sensible to use the same procedure for routine withdrawal (e.g. at the end of a cycle) and required withdrawal (i.e. when an item is in breach of the Code). However, the timing may be different. Code breaches require withdrawal within five days, but a longer period could be allowed for routine withdrawal.

Implementing the SOP should start with an amnesty. Representatives should be given a list of active items and told to return any items not on the list. The Active Item List should be updated as required, and should be available to all field staff.

As a regional manager, you can ensure maintenance of the SOP with ongoing routine checks and audit of:

materials in use by representatives

car boots

any stores of material.

Use of an item that should have been withdrawn is considered an extremely serious breach of the Code, almost always resulting in a ruling that Clause 2 has been breached and often the requirement for an audit of company procedures by the PMCPA.

The importance of this, and the consequences for any individual who does not comply, must be made clear to all staff.

Do you have a management Code challenge? If so, e-mail PSM at chris.ross@healthpublishing.co.uk to receive advice from Joan and Ian. Their unique combination of experience means they are well placed to provide highly realistic advice to companies on Code compliance, based on their conviction that good compliance and good business go hand in hand.

Joan Barnard has extensive experience of the ABPI Code of Practice. She is the author of The Code in Practice and The Code in the Field, both widely used in the industry. Contact: www.codeinpractice.co.uk.

Ian Hale has over ten years experience in the industry, including sales, training, management and compliance. He is a qualified lead auditor (BSI standard) and helps many companies to develop effective and efficient internal procedures that meet all the Codes requirements. Contact: www.ibhconsultancy.com.