Learn how the AASHTO Accreditation Program addresses falsified records and how labs should handle the situation.
AASHTO re:source Q&A Podcast Transcript
Season 1, Episode 17: FAQ - How should I handle falsified records?
Released: November 10, 2020
Hosts: Brian Jonson, AASHTO Accreditation Program Manager; Kim Swanson, Communications Manager, AASHTO re:source
Note: Please reference AASHTO re:source and AASHTO Accreditation Program policies and procedures online for official guidance on this, and other topics.
Transcription is auto-generated.
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00:00:02 ANNOUNCER: Welcome to AASHTO resource Q & A. We're taking time to discuss construction materials testing and inspection with people in the know. From exploring testing problems and solutions to laboratory best practices and quality management, we're covering topics important to you. Now here’s our host, Brian Johnson.
00:00:21 BRIAN: Welcome to the podcast. Today we are going to do another FAQ episode with our producer Kim Swanson. Kim, what's the frequently asked question today?
00:00:31 KIM: Surprisingly, I've found even I know about them, the falsified records. So that's what we're going to dive deeper into.
00:00:38 BRIAN: OK, well, I'll tell you how we deal with falsified records because, well, first, let me let me back up and say yeah, that happens and it happens so much. So, Kim is the communications manager at AASHTO resource and even she knows. That we run into falsified record issues so it does get discussed around the office, especially in management circles and it's more than a minor problem. I mean, some people would say, wow, I can't believe people are falsifying, but what you really would be shocked at is how many laboratories are falsifying documents. We don't visit the laboratories. That often we only visit once every approximately 2 years, a little bit more. That and just for a few days. And in that time period, sometimes we find these falsified records.
00:01:25 KIM: How do our assessors or quality analysts even realize that it's there's a falsified record?
00:01:31 BRIAN: Well, it's usually easier than you'd think. [KIM: Okay.] So, when we when people are falsifying them, they typically are copying the same value. Use year after year after year one that's commonly falsified are sieve opening check records. There's something they're supposed to be doing regularly. They take dimensional measurements, they write them down on a record and they determine whether that sieve opening or the sieve openings. In conformance with the standard requirements. When you're taking those kind of opening measurements with calipers there, there's always going to be some play in it. So even if the sieve isn't changing over time, it would be highly unlikely for you to measure the same opening time after time after time and get the same exact measurement down to the. Hundredths of a millimeter. But if we see a record where all of the measurements are exactly the same year after year, that is an indication of potential falsification.
00:02:35 BRIAN: Another way we could tell is if we check it ourselves and we come up with different measurements, that is another indication of probable cause. Now, I wouldn't say that that would necessarily be the only thing, but. So I would certainly build the case for falsification if you had the repeated numbers, and then we aren't able to duplicate that. But another way would be a third way would be having the laboratory check it for you. If you're the assessor, and if they somehow, let's say this is the fifth time in a row that you would expect to see those same numbers based on the records you've seen and all of a sudden they can't reproduce any of those values with their same equipment, same person. And that's pretty much a dead giveaway that. That record was falsified.
00:03:20 KIM: We take this very seriously. We don't accuse falsified records just and a whim, correct?
00:03:25 BRIAN: We have to be pretty sure about it because it's a serious accusation. You don't want to. You don't want to accuse somebody of deliberately falsifying something. And even. When we find them to be falsified or highly likely to be falsified, we have to be careful about how we address that with the laboratory, because there always is a possibility that there's some other explanation. We see all sorts of responses from laboratories when they get in this situation and I don't want to lay out a road map for how to get around this. So, I don't want to give all the ideas that have been accepted, but I will say one of the most common things that happens is lack of training with the technician that is performing the work. They might say, OK, well, we've got this responsibility to check this equipment. Hey, assign this to somebody who is not busy right now. The person may not know what they're doing and they may not have been trained and their arrangement with management may be such that they're just expected to get the job done, no questions asked.
00:04:28 BRIAN: So, they look at the last record and they say. OK, well, these are the values. How do I come up with similar value? Well, one way is to try to figure out how they came up with them and then duplicate the effort another way the quick way that some choose in the wrong way is to just copy those values down again, which is a falsified record, but they may not see it as a falsification issue. They may see it as I'm just doing what I was told. So, and we do run into that situation too, where there's a miscommunication about the expectation of what that effort was. And since it's not going to a client, they may not think it's a big deal.
00:05:08 KIM: Well, that was. My question is, it's not always malicious. Falsified records, right? It's not necessarily. I'm going to get away with this. I just don't know. What I'm supposed to do?
00:05:17 BRIAN: I'd say that's the case most of the time. You know, there are times where laboratories they don't care so. So, I would make a distinction between not knowing and not caring the one that I just described is more just not knowing and really it's still a failure of management. In that situation, it's still bad, but it's not an integrity question necessarily as it is a lack of competency or lack of management structure. A weak training program. But we do run into times where a laboratory may falsify just about everything. Because they just want to get through what they you know, they perceive the accreditation process is just a hoop, another hoop they have to jump through to get work. Well, it isn't. They may see it that way, but that's a fundamental failure in their understanding of the process, and it should disqualify them from doing any work in this industry.
00:06:16 BRIAN: We're talking about construction materials, which has a major public safety component to it, if they consider documentation of results to be an administrative hoops, they have to jump through. What do you think they're going to do on a project? It's not easy for a laboratory to fail material. There's a bunch of problems that it could cause construction delays. They could have issues with the supplier, maybe even issues with the inspector if they're really under the gun to get the project completed. So if they can't even handle documenting the internal items correct, which should be relatively easy for them to produce those records in a in a in an honest way, I have very low confidence that they would do the hard work of actually reporting a failing test result when one occurred.
00:07:07 KIM: That brings me to. Another point that there's of course accreditation ramifications when our assessors are quality analysts discover or the potential of falsified records, there's accreditation implications, but what are kind of the real world implications for laboratories that have falsified records in their laboratory?
00:07:27 BRIAN: Well, I'd say the. Well, maybe let me back up and talk about the mechanism for how we deal with this. What happens is let's say that an assessor finds falsified records in the laboratory. They report back to us. We take a look. At them, they usually go to me. I'll look at the records and I'll say OK, well, well, how plausible are these results? What's the back story here? We need to know more detail usually, but let's say we get to the point where we say these are these are we have a very high confidence level that these have been falsified. So first we have the assessor communicate to the laboratory. Management that they have found falsified records or allegedly falsified records in the laboratory and they will be contacted by the Ashton Accreditation Program. Either I or one of the quality analysts will then reach out to that laboratory and say this has happened. You have seven days to send us a preliminary corrective action report.
00:08:26 BRIAN: That means that they have to acknowledge what happened and they have to plan for how they're going to resolve it. It does not mean that they have to go through the entire corrective action process. At that point, within seven days. To resolve this issue, we have found that by getting the preliminary corrective action report so quickly that has put the laboratory on a path for successfully resolving this issue, as long as they acknowledge the fact that it happened, if you have a laboratory that continues to not accept. If that's what happened, even though it's blatant and. Obvious, then, that puts them on a path towards revocation, ultimately because they have shown a lack of integrity. Now all these things, everything we do, gets the laboratory to have due process. So even if we feel that they're being disingenuous, we would still send that to our oversight committee for a decision, and there would be an appeals process.
00:09:26 BRIAN: As well, if they didn't like the outcome, so there is due process, so it's not a matter of just me saying, hey, I think you're lying and you're going to lose your accreditation. But those are the processes they get that preliminary corrective action review. If we and our oversight committee chair feel that that is a reasonable explanation, then we say, OK, go ahead and take that corrective action and we'll follow the normal 60 day deadline that laboratories have following an assessment to resolve everything, to actually enact that corrective action and implement it. So I I'd say that this process has been really successful. And not just identifying it, but helping the laboratory management resolve these issues that were kind of simmering in the background for years at their laboratory. And like I said before, a lot of times it's a training, training implementation. It hasn't been what it should have been at those labs and that helps them improve there and it may lead to other improvements as well.
00:10:32 KIM: So that's how the AASHTO accreditation program and AASHTO resource kind of handle the process of once we found falsified records. What if the laboratory finds falsified records during one of their internal audits? What steps should they take in that scenario?
00:10:50 BRIAN: I think that that is the you have hit the nail on the head for when this should actually all take place. Like I said in the beginning of this conversation, we're not there very often for us to find it. There is a massive problem going on because they're supposed to have internal audits. They're supposed to be reviewing records that are that are being produced in the laboratory regularly. If they aren't uncovering a falsification that that we can uncover, I would say they're not really doing a great job with their internal audit or they're not keying on the right things necessarily. R 18 doesn't say look out for. All spot records. That doesn't mean that they should turn a blind eye to it, though. So, I I'd say that the corrective action should be the same if it's found during an internal audit, as it is for us, except the people are different. In that case, you know if I'm the internal auditor at a laboratory, let's say we're doing it at our office and Tracy goes through and finds that a training record for a new quality analyst.
00:11:55 BRIAN: Was falsified, then, instead of her responding to an external auditor about this, I would be responding to her about this. How did this happen? I'd be doing the investigation well. Well, who documented this? What happened? And how did this happen? What do we need to do to make sure it doesn't happen again once we figure out what the issue is? Let's say we found that one individual was causing an issue and we started looking at and we say, boy, what else was that person doing? And then we start looking at some other things. If we see that it's an individual. And we have to take some other type of corrective actions. You know, we have to. Have a serious conversation with that person about what their responsibilities are, and either try to get them to be rehabilitated, or maybe if that doesn't happen, then of course you have to take a more serious step. We don't want that to be the approach through this process, we're always looking at accreditation through a systems perspective. But there are times where you just have somebody who doesn't care, doesn't isn't diligent about their work, and you have to get them trained up or they shouldn't be there.
00:13:06 KIM: What’s some preventative measures laboratories can do to prevent falsified records.
00:13:11 BRIAN: Training, training and then auditing, I'd say so if people know what they're doing and they've been trained properly, there's really no reason for them to even consider falsification. Like I said, in the very beginning of this, the biggest issue is the training. They're given a task to do and they have no idea how to do. But they're just trying to duplicate similar outcomes to what has been accepted in the past. That's a bad situation to put somebody in, and I suspect that happens with people in all industries for all different kind of tasks because a lot of industries are quality management. That's kind of a foreign concept, but that's one thing I'll say for the engineering industry is that there is care take in regarding training because there are important technical aspects of people's work that needs to be understood before they can actually carry it out and expect some sort of positive outcome or competent outcome. So, I think that's a real testament to the industry and it's one that should be carried on in, in many industries, especially with the training.
00:14:19 BRIAN: So, I'd say look at your training program if you're thinking what training program right now is a great time for you for you to implement. And if you're an AASHTO accredited lab and you're wondering that we've got plenty of resources available on our website where you could learn more. Or, but we've got a policy and guidance document describing what training and evaluation processes are. We'll be covering more about training through these podcasts, and I'm sure we'll have webinars. And of course, we've got technical exchange, so I just jump ahead on your next question, Kim.
00:14:54 KIM: You didn't, but I did want to point out as well. That we currently have a policy and guidance document about falsified records. If you go to our document library and you can see in the policy section we have some more guidance. On what to do with falsified records and how we handle that and things of that nature. So that's a good resource for now. If you want more information on falsified records.
00:15:15 BRIAN: Yeah, this policy and guidance documents have been really helpful because people will look at our processes and they say where's the requirement. They always want to know where the requirement is, which I totally understand. We try to get every requirement out there posted on the website if it's not already embedded in R18 or the Ashton accreditation program Procedures Manual. But the policy and guidance document gives us an opportunity to explain all the details, so there may be a statement in there that could be interpreted different ways or spun a different way. But by us putting the guidance in there, it really clarifies those issues. And we also try to put we're talking about there's a frequently asked question. Episode we try to put some frequently asked questions both on our website and in those policy and guidance documents where we can.
00:16:02 KIM: Do you have any last bits of advice about falsified records and how to handle them?
00:16:07 BRIAN: Yes, if you have any concerns. About the way we handle this issue, please let me know. I feel like our success rate has been incredible for handling it fairly and objectively, but if you're a laboratory and you run into a situation where you feel like you have been identified improperly as having falsified. Records state your case very clearly about why that may be. We haven't really run into any situations like that yet. There are times where laboratories start out that way, but eventually it comes to the conclusion that they actually did falsify it and just weren't aware. The reason why I say this is because. To those laboratories who have not accepted the fact that they had falsified records, it's usually because they didn't do enough digging. You know, they may have just asked someone. Hey, did you falsify this? No, I didn't falsify it, OK.
00:17:06 BRIAN: I'll go back to AASHTO and tell them that they didn't do the right thing and that's not good enough. You really need to go and watch the person perform that activity and I'll give you a great example. Or we had a situation where somebody was. A record for concrete field equipment standardization. And the person told me, yeah, they know what they're doing. I've known the person a long time. They would never do this. This and say OK, well, you're going to have to document that and go back. And forth now. After several conversations with the person, they dug a little deeper, a little deeper, a little deeper. And finally, they got to the point where they said, OK, we're going to have the person do this from now on with supervision so. To me, that is an admission that there was a problem uncovered. Maybe they didn't want to state exactly what the problem was, but from our perspective, we feel like that is going to lead to a continual improvement of their process.
00:18:08 BRIAN: And I'm not totally comfortable with anything short of saying yes, this happened and we've documented it properly. This is what we're going to do. But for a preliminary corrective action, I was pleased to see that there was some, even though it were. It was indirect, some admission that there was an improvement that. Needs to take.
00:18:32 KIM: So it's kind of like the saying that the first step into fixing a problem is to admitting that there is a.
00:18:38 BRIAN: Yeah, exactly. And you and you do have to do that if you're going to make any improvement.
00:18:44 KIM: I think we could go on. For a long time, but. In the spirit of it being a. Podcast I think. Maybe, maybe not. Is there anything else you want to say that I didn't ask?
00:18:53 BRIAN: I would just encourage people to just be forthcoming about what's going on. You may get away with it initially, but eventually it's going to catch up with you and the outcome is going to be way worse than if you just addressed it in a forthcoming way.
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00:19:06 KIM: Thank you for your time today Brian, and thanks for listening to AASHTO re: source Q & A. If you'd like to be a guest or just submit a question, send us an email at firstname.lastname@example.org or call Brian at 240-436-4820. For other news and related content, check out AASHTO re:source's Twitter feed or go to aashtoresource.org.