DebbieL

I have been there. There is probably a template that your laboratory uses. Look at your current P/P book in your area or in other areas of the lab and see if there is a pattern to all the P/P. Some regulatory agencies require specific things in all the procedures so you don't want to have to rewrite it.
 
You want to write it so that a person could follow along and be able to do what is required but you don't want it to be so specific that you get dinged because the techs don't follow the steps as written. Do what you say, say what you do. Slightly vague, slightly specific. I tend to be specific and I have to pull myself back.
 
We are CAP inspected. I look at the standards and find anything that may relate to the P/P I am writing and try to include the points to hit. Don't forget about Commons and General standards.
 
Write it, then put it aside for a few days. when you come back to it, it may sound totally dumb. Give it to the people in your department and have them critique it. Can they follow the steps as written?
 
I copied and pasted my procedure for checking the blood storage temps. Hope this helps. Cutting and pasting caused it to lose it's format but you will get the gist of it.
 
PRINCIPLE AND CLINICAL SIGNIFICANCE:
All Temperature Dependent Equipment (TDE) in the Blood Bank are continually monitored to ensure that blood products are maintained within proper temperature ranges.
 
POLICY:
The Blood Bank equipment in which blood products are stored must maintain temperatures in the following ranges:  
                        Blood Bank Refrigerator        2-6° C                         
FFP Freezer                             -18° C or colder
                        Platelet Incubator                    20-24° C                                 
 
If the continuous automated monitoring chart system is not operational, temperatures must be taken and documented every 4 hours to ensure that products are maintaining the correct temperatures.  
 
Equipment and Materials:  Refrigerator, freezer or platelet incubator to be checked Refrigerator, freezer or platelet incubator temperature chart.  
 
Safety Precautions:  All blood products should be treated as potentially infectious. Use universal precautions.
 
 
PROCEDURE: Daily Checking of Continuous Monitored Chart System:
Temperatures of TDE are documented daily at about the same general time of day. Document the temperature of each TDE on Blood Bank Temperature Check form. Assess that the chart is turning properly, is within the temperature guidelines, and is currently at the appropriate day and time on the chart. The person taking the daily temps should initial the chart each day when it is checked.  This verifies the proper day/time setting was checked  
Weekly Chart Change –
Temperature charts are changed weekly at about the same general time.  Information listed on the back of each chart should include the equipment identification number and the date, time the chart is placed on the equipment and initials of the person replacing the chart. Completed charts should have the date and time removed and should be initialed. Weekly charts are paper-clipped together and placed in the file for review.  
Procedure for Abnormal Results: Audible Alarm Sounds – The audible alarm for the refrigerators and platelet incubator is set to sound before the upper and lower temperature range is reached.  If refrigerator or freezer temperature reaches unacceptable limits at any time, an alarm sounds in the blood bank and the power plant. When this situation occurs, the following steps should be taken:
Compare Chart and Thermometer Readings- If these are within range, the probable cause is prolonged door opening. Limit entrance into the refrigerator or freezer and monitor the temperature which should begin to return to normal range shortly. The tech noting the alarm and deviation of temperature should initial and make a note on paper chart to reflect the cause of the alarm. Temperature of Equipment Does Not Return to Normal Range- Carefully monitor temperature of equipment so that products will remain within acceptable range. Call Maintenance Department for STAT assessment of equipment. If equipment temperature stays the same or continues to increase, blood products must be removed to prevent loss. It is not necessary to seek Lead Technologist approval before removing blood products to safer conditions.  RBC units and reagents should be moved to another monitored refrigerator in the Blood Bank. The blood center should be called to provide insulated boxes and dry ice for frozen products before the freezer temperature reaches unacceptable temperatures. Frozen products should be placed in blood center insulated boxes with dry ice placed on top of the units. Platelets may be placed in RT platelet shipping boxes for up to 24 hours without agitation.      
Remove products when temperatures of equipment approach the following sustained temperatures:
            Refrigerator    ≥6.0° C            FFP                 above -18° C         
            Platelets           ≥24° C             Surgery           above -65° C
           
Actions if System is Inoperable             Power Failure- In the event of a power failure, make sure that auxiliary power is functioning.  If this cannot be ascertained, call Maintenance.  In the event of a complete power equipment failure, our current blood supplier or other area hospital facilities may be called to provide help with red cells.  With an area power failure, red cells would be maintained in boxes with bags of wet ice placed on top.  FFP would be maintained in boxes with dry ice placed on top of units.  Platelets can be maintained in platelet shipping boxes for up to 24 hours without agitation. Reagents should be placed in insulated boxes with bags of wet ice placed on top.
 
Refrigerator/Freezer/Platelet Alarm Inoperable – If blood products must be stored under unmonitored conditions, the temperature will be checked every four hours and documented on Manual Temperature Recording Log form. This will document that proper storage temperature has been maintained.
 
            If the Ultra-low Freezer in Surgery is Not Functional- The Surgery department is responsible for maintaining the temperature of the tissues stored in the ultra-low freezer. Blood Bank may help by obtaining insulated blood boxes from the local blood supplier and Surgery may obtain dry ice to pack around the tissues. Space may be available in the laboratory ultra-low that is located in Chemistry, however, this freezer generally does not have free space.  
 
When the Refrigerator /Freezer/Incubator is Back in Service- Before blood products and/or reagents are placed back into the TDE once it is repaired, the equipment must be temperature stable for at least 4 to 24 hours. Temperature and alarm checks on the TDE must be satisfactorily performed and recorded. Reagents and antisera should be inspected for quality concerns and must pass QC before patient testing is performed. Reagents and/or antisera that does not pass quality inspection must be discarded.  
 
SOURCES:
AABB Technical Manual, Current Edition
 
RELATED DOCUMENTS:
Blood Bank Temperature Check form (QC002)
Manual Temperature Recording Log (QC005)

Things I have listed in my procedure:
1. If we have discovered an antibody on a patient who is about to go to surgery, we call the nurse in charge of the patient in Surgery Holding to let the physician know blood may not be available. The doc needs to know before the patient goes under the knife. Sometimes they delay the surgery and sometimes they proceed with caution.  (This issue can be avoided with a pretesting process that not all physicians use)
2. If we have a serious transfusion reaction due to ABO incompatibility, we would contact the patient physician and our pathologist immediately. 
3. We can't ID the antibody and the physician has requested RBC transfusion. Depending on the condition of the patient, they may still proceed with incompatible or least incompatible blood and sign a Medical Release or will probably wait until we can ID. It is up to the physician to make the call based on the patient. 
4. When we had babies, we considered a positive DAT as a critical result from the BB side and would call L/D.

Things I have listed in my procedure:
1. If we have discovered an antibody on a patient who is about to go to surgery, we call the nurse in charge of the patient in Surgery Holding to let the physician know blood may not be available. The doc needs to know before the patient goes under the knife. Sometimes they delay the surgery and sometimes they proceed with caution.  (This issue can be avoided with a pretesting process that not all physicians use)
2. If we have a serious transfusion reaction due to ABO incompatibility, we would contact the patient physician and our pathologist immediately. 
3. We can't ID the antibody and the physician has requested RBC transfusion. Depending on the condition of the patient, they may still proceed with incompatible or least incompatible blood and sign a Medical Release or will probably wait until we can ID. It is up to the physician to make the call based on the patient. 
4. When we had babies, we considered a positive DAT as a critical result from the BB side and would call L/D.

We have an Extended T/S form used in Pretesting. The nurse will ask the patient if they have been transfused or pregnant in the last 3 month. Nurse signs the form and answers Yes or No.  The form along with T/S specimen is sent to BB. We do the testing that day and indicate on the form if the patient has a BB history. If not, we will need an ABO Recheck specimen collected the morning of surgery. We put a round sticker on top of the specimen so we don't discard accidently. We place a comment in the computer that the patient has an Extended T/S for our info on the day of surgery.
Two days before scheduled surgery, we fax the forms to Surgery Holding. Holding wants these early so they can make up the charts the afternoon before surgery when it is not so hectic.
Day of surgery-Nurse asks the transfusion and pregnancy questions again, signs the form and collects the ABO Recheck specimen if needed and faxes the signed form to us. We also send a list to Surgery Holding of all the patients we know needs an ABO Recheck collected while IV is being placed so we can be sure they get the message before the patient is rolled away
The BB will find the preadmit specimen in storage & test the ABO Recheck, if needed. We have a special BB order we place in the computer to answer some of the questions about the pretesting. The XM now gets 3 days and the preadmit specimen has the sticker pulled off the top and is placed in storage with all of today's specimens. In this process, we remove the comment from the computer.
We will extend up to a month, so 30/31 days so we don't have to count on our fingers. LOL. If the patient comes in for surgery past the 30/31 days, we request a new  order and specimen. 
If the patient turns out to have an antibody, we will ID and write the info on the form and hang the form up for all BB to see.  We will scan for Ag- neg units prior to surgery. We write a BIG note on the form that we want a FULL pink top collected on the day of surgery and redo the T/S and crossmatch the units. We don't redo the AB panel as long as the screen appears as expected, plus the patient hasn't been transfused.
It takes 3 departments completing their tasks but it works like a charm after the initial learning curve.  We do not use BB armbands so I'm not sure how that would work. I don't see people wearing an armband for a month or requiring a patient to bring the armband with them on the day of surgery. Maybe some of this info can help you.
 

Blood bank methods aren't expected to correlate perfectly.  We use their differences to avoid rouleaux, clinically insignificant, and weak warm auto reactivity so we can better detect any significant alloantibodies. No method will detect 100% of significant antibodies. I am going to tweak the above to say we can "better detect' antibodies so it works better with the next sentence and doesn't imply that we can detect "any" significant antibodies. 

I think that is still in effect. The last time I ordered rolls of 4x4 labels for modified products, the description stated they were acceptable for placing on blood products. 

We use a paper tag with a pre-attached sticky label. The tag has all kinds of info printed on it for the nurses edification, such as transfusion rxn info, only use saline, etc. The computer prints all the patient/donor info on the tag and also on the sticky label which we place on the unit at issue. The tag is primarily used at the bedside for the required checks but the unit itself is scanned into the computer and completed in the computer.  If the computer is down or goes down, the nurse will revert back to the paper tag to complete the transfusion. The label stays on the unit throughout the transfusion. That has been beaten into their heads over the years.
The tags are a specialty type print and are expensive but it is what it is. It took months of committee meetings to approve the tag we have now and every nurse had an opinion about what should be on the tag. 

We use a paper tag with a pre-attached sticky label. The tag has all kinds of info printed on it for the nurses edification, such as transfusion rxn info, only use saline, etc. The computer prints all the patient/donor info on the tag and also on the sticky label which we place on the unit at issue. The tag is primarily used at the bedside for the required checks but the unit itself is scanned into the computer and completed in the computer.  If the computer is down or goes down, the nurse will revert back to the paper tag to complete the transfusion. The label stays on the unit throughout the transfusion. That has been beaten into their heads over the years.
The tags are a specialty type print and are expensive but it is what it is. It took months of committee meetings to approve the tag we have now and every nurse had an opinion about what should be on the tag. 

I'm annoyed! Yes, there are differences in results between automation, GEL and tube testing. Automation is the most sensitive and tube testing is the least sensitive (but the BB gold standard method), with GEL in-between. I wrote that bit of information in my procedure so an inspector would know I am aware of the possible differences.   We are doing this exercise to make sure the methods compare, if the specimen is positive in automation, it should also be positive in GEL and tube testing and should appear to be the same antibody on the antigrams. If I am doing an antibody screen and an AB ID, I am using the same METHOD whether I am testing using 3 screening cells or a panel of 10 or more cells. 
Yes, we have the rare antibody screen that gives wonky results in automation and and is stronger in GEL. That tells me we need to do the ID in GEL so we can actually get an answer we trust. Different antibodies work differently in different methods but the screen and AB ID should be the same within the same method. Our screening cell method in tube is the exact same method as our panel tube testing. If I am doing the comparability testing, I am using a strong antibody that has a 3-4+ result so I can be assured I will get similar results across all 3 methods. I'm not going to use a weak or wonky antibody that would give shady results an inspector could question when they view my forms at an inspection.
This is Method Comparability, not Test Result Comparability. Does CAP have to have a quota of standard changes they have to meet? I'm on a soap box and I am sorry to rant but this seems unnecessary and extra work for the same AB screen results across the different methods. 

Our window opens in October. I will not budge! If our inspector gives a deficiency for this item I will take my fight to CAP. If I do not win, then I will make the change. I am hoping by then they get their collective heads out of their posterior waste removal orifices and accept the rational and logical process.

I'm annoyed! Yes, there are differences in results between automation, GEL and tube testing. Automation is the most sensitive and tube testing is the least sensitive (but the BB gold standard method), with GEL in-between. I wrote that bit of information in my procedure so an inspector would know I am aware of the possible differences.   We are doing this exercise to make sure the methods compare, if the specimen is positive in automation, it should also be positive in GEL and tube testing and should appear to be the same antibody on the antigrams. If I am doing an antibody screen and an AB ID, I am using the same METHOD whether I am testing using 3 screening cells or a panel of 10 or more cells. 
Yes, we have the rare antibody screen that gives wonky results in automation and and is stronger in GEL. That tells me we need to do the ID in GEL so we can actually get an answer we trust. Different antibodies work differently in different methods but the screen and AB ID should be the same within the same method. Our screening cell method in tube is the exact same method as our panel tube testing. If I am doing the comparability testing, I am using a strong antibody that has a 3-4+ result so I can be assured I will get similar results across all 3 methods. I'm not going to use a weak or wonky antibody that would give shady results an inspector could question when they view my forms at an inspection.
This is Method Comparability, not Test Result Comparability. Does CAP have to have a quota of standard changes they have to meet? I'm on a soap box and I am sorry to rant but this seems unnecessary and extra work for the same AB screen results across the different methods. 

I'm annoyed! Yes, there are differences in results between automation, GEL and tube testing. Automation is the most sensitive and tube testing is the least sensitive (but the BB gold standard method), with GEL in-between. I wrote that bit of information in my procedure so an inspector would know I am aware of the possible differences.   We are doing this exercise to make sure the methods compare, if the specimen is positive in automation, it should also be positive in GEL and tube testing and should appear to be the same antibody on the antigrams. If I am doing an antibody screen and an AB ID, I am using the same METHOD whether I am testing using 3 screening cells or a panel of 10 or more cells. 
Yes, we have the rare antibody screen that gives wonky results in automation and and is stronger in GEL. That tells me we need to do the ID in GEL so we can actually get an answer we trust. Different antibodies work differently in different methods but the screen and AB ID should be the same within the same method. Our screening cell method in tube is the exact same method as our panel tube testing. If I am doing the comparability testing, I am using a strong antibody that has a 3-4+ result so I can be assured I will get similar results across all 3 methods. I'm not going to use a weak or wonky antibody that would give shady results an inspector could question when they view my forms at an inspection.
This is Method Comparability, not Test Result Comparability. Does CAP have to have a quota of standard changes they have to meet? I'm on a soap box and I am sorry to rant but this seems unnecessary and extra work for the same AB screen results across the different methods. 

I'm annoyed! Yes, there are differences in results between automation, GEL and tube testing. Automation is the most sensitive and tube testing is the least sensitive (but the BB gold standard method), with GEL in-between. I wrote that bit of information in my procedure so an inspector would know I am aware of the possible differences.   We are doing this exercise to make sure the methods compare, if the specimen is positive in automation, it should also be positive in GEL and tube testing and should appear to be the same antibody on the antigrams. If I am doing an antibody screen and an AB ID, I am using the same METHOD whether I am testing using 3 screening cells or a panel of 10 or more cells. 
Yes, we have the rare antibody screen that gives wonky results in automation and and is stronger in GEL. That tells me we need to do the ID in GEL so we can actually get an answer we trust. Different antibodies work differently in different methods but the screen and AB ID should be the same within the same method. Our screening cell method in tube is the exact same method as our panel tube testing. If I am doing the comparability testing, I am using a strong antibody that has a 3-4+ result so I can be assured I will get similar results across all 3 methods. I'm not going to use a weak or wonky antibody that would give shady results an inspector could question when they view my forms at an inspection.
This is Method Comparability, not Test Result Comparability. Does CAP have to have a quota of standard changes they have to meet? I'm on a soap box and I am sorry to rant but this seems unnecessary and extra work for the same AB screen results across the different methods. 

I'm annoyed! Yes, there are differences in results between automation, GEL and tube testing. Automation is the most sensitive and tube testing is the least sensitive (but the BB gold standard method), with GEL in-between. I wrote that bit of information in my procedure so an inspector would know I am aware of the possible differences.   We are doing this exercise to make sure the methods compare, if the specimen is positive in automation, it should also be positive in GEL and tube testing and should appear to be the same antibody on the antigrams. If I am doing an antibody screen and an AB ID, I am using the same METHOD whether I am testing using 3 screening cells or a panel of 10 or more cells. 
Yes, we have the rare antibody screen that gives wonky results in automation and and is stronger in GEL. That tells me we need to do the ID in GEL so we can actually get an answer we trust. Different antibodies work differently in different methods but the screen and AB ID should be the same within the same method. Our screening cell method in tube is the exact same method as our panel tube testing. If I am doing the comparability testing, I am using a strong antibody that has a 3-4+ result so I can be assured I will get similar results across all 3 methods. I'm not going to use a weak or wonky antibody that would give shady results an inspector could question when they view my forms at an inspection.
This is Method Comparability, not Test Result Comparability. Does CAP have to have a quota of standard changes they have to meet? I'm on a soap box and I am sorry to rant but this seems unnecessary and extra work for the same AB screen results across the different methods. 

This is awesome! As many times as our freezer has gone done over the years, we never thought of putting dry ice in the freezer. Your dad is awesome!!!
 

We have an ECHO that is also not interfaced and we must print the results and manually enter. We do not keep our printouts for very long. My reasoning is that we download all the results to DVDs that we have kept since the instrument rolled in here. If someone wanted a result from 5 years ago, I could produce it.
I contacted Immucor about getting the info from the DVDs. There is not proprietary software involved in being able to see the results. The DVDs can be put on any computer and read on Notebook, which I tested to make sure. Do you think the DVDs are good enough?
I did start making my people print the daily QC results because I could see an inspector asking for 2 years of QC records. I wanted to be able to place a box in their hands and not have to shuffle thru DVDs.

This is awesome! As many times as our freezer has gone done over the years, we never thought of putting dry ice in the freezer. Your dad is awesome!!!
 

All, I am about to blow your mind....
Our plasma freezer is down and so is our backup. The freezer will not get colder than -18 C. I was preparing to move all the products into boxes with dry ice until I had a conversation with my 87 year old dad, a retired blood banker from University of Chicago. He said to me, do not take the plasma out of the freezer and put it in boxes, PUT THE DRY ICE IN THE FREEZER, IT IS THE BEST STORAGE BOX YOU HAVE!!!!
MIND=BLOWN!!!!
I did that. Our freezer is currently reading -25.1C and getting colder. Furthermore, the probes in the freezer continually monitor the temp in the freezer so you don't have to record temps every 4 hours, the chart is doing that for you!!!
Isn't that cool? That perfectly illustrates the difference between wisdom and knowledge there. I wish we could hire my dad.
I just had to share this here.
PS. Freezer is now at -26.4C.
 

There was a FAQ on the CAP site a few years ago that basically said BB did not have to do lot to lot testing, that our regular QC was sufficient. I know the exception was fetal kits or other kits that had positive and negative controls as part of the kit.  I was concerned about this standard regarding our regular reagents after it was revised so I wrote to CAP so I could get an understanding if things had changed so we did have to start doing lot to lot. This was my answer for my question about COM.30450

The way I read this we do not have to do lot to lot except for something like a fetal kit. You can perform QC on the day of use. Part of our QC is to check the shipment upon arrival, is the appearance normal, did it arrive at the proper temp, was the shipping container damaged, etc. 
I like having an answer in writing with the CAP logo if an inspector seems like they are going to site me. I can whip the email out and show them. Might help, also might make them mad.

I get so annoyed when CAP "experts" give different answers to different people. It seems to me they also bring in their own personal opinion on things, like some inspectors we have to deal with. She stated she "suggests" doing ID on all methods
I would have to argue they we are testing the "method." If you get a positive AB screen using automation, do you also get a comparable positive AB screen using GEL and tube? Does the antigram for the same antibody across the 3 methods appear to be the same antibody. It shouldn't look like an anti-E on automation, a anti-K in Gel and an M in tube. They are not going to match in strength because the different methods vary in sensitivity. I would include the antigrams of each method to show it appears to be the same antibody across all methods. 
A set of screening cells is just a mini AB panel. If you feel like you must do an antibody panel using each method, I would just do an extra cell or two on each method and say it is not a set of screening cells but a mini selected panel. If we find a patient with a good, strong, clear antibody it is sometimes hard to come up with lots of extra plasma to do unnecessary testing. (My opinion only)
Gr-r-r-r-r!

I get so annoyed when CAP "experts" give different answers to different people. It seems to me they also bring in their own personal opinion on things, like some inspectors we have to deal with. She stated she "suggests" doing ID on all methods
I would have to argue they we are testing the "method." If you get a positive AB screen using automation, do you also get a comparable positive AB screen using GEL and tube? Does the antigram for the same antibody across the 3 methods appear to be the same antibody. It shouldn't look like an anti-E on automation, a anti-K in Gel and an M in tube. They are not going to match in strength because the different methods vary in sensitivity. I would include the antigrams of each method to show it appears to be the same antibody across all methods. 
A set of screening cells is just a mini AB panel. If you feel like you must do an antibody panel using each method, I would just do an extra cell or two on each method and say it is not a set of screening cells but a mini selected panel. If we find a patient with a good, strong, clear antibody it is sometimes hard to come up with lots of extra plasma to do unnecessary testing. (My opinion only)
Gr-r-r-r-r!

I get so annoyed when CAP "experts" give different answers to different people. It seems to me they also bring in their own personal opinion on things, like some inspectors we have to deal with. She stated she "suggests" doing ID on all methods
I would have to argue they we are testing the "method." If you get a positive AB screen using automation, do you also get a comparable positive AB screen using GEL and tube? Does the antigram for the same antibody across the 3 methods appear to be the same antibody. It shouldn't look like an anti-E on automation, a anti-K in Gel and an M in tube. They are not going to match in strength because the different methods vary in sensitivity. I would include the antigrams of each method to show it appears to be the same antibody across all methods. 
A set of screening cells is just a mini AB panel. If you feel like you must do an antibody panel using each method, I would just do an extra cell or two on each method and say it is not a set of screening cells but a mini selected panel. If we find a patient with a good, strong, clear antibody it is sometimes hard to come up with lots of extra plasma to do unnecessary testing. (My opinion only)
Gr-r-r-r-r!

I get so annoyed when CAP "experts" give different answers to different people. It seems to me they also bring in their own personal opinion on things, like some inspectors we have to deal with. She stated she "suggests" doing ID on all methods
I would have to argue they we are testing the "method." If you get a positive AB screen using automation, do you also get a comparable positive AB screen using GEL and tube? Does the antigram for the same antibody across the 3 methods appear to be the same antibody. It shouldn't look like an anti-E on automation, a anti-K in Gel and an M in tube. They are not going to match in strength because the different methods vary in sensitivity. I would include the antigrams of each method to show it appears to be the same antibody across all methods. 
A set of screening cells is just a mini AB panel. If you feel like you must do an antibody panel using each method, I would just do an extra cell or two on each method and say it is not a set of screening cells but a mini selected panel. If we find a patient with a good, strong, clear antibody it is sometimes hard to come up with lots of extra plasma to do unnecessary testing. (My opinion only)
Gr-r-r-r-r!

We do not perform repeat antigen typing on units sent from the reference lab. If it says historical antigen type, we are OK with that. We enter the extra Ag typing into the computer when we receive the unit.
We do not waste the time and antisera to retype units the techs type here at our BB. If I did that then why not go back and repeat everything else they did. The units would be AHG XM and should catch it if the antigen is showing up. If a tech did mislabel an Ag, they would be written up when it was found for causing patient harm.
We once had a sickle cell frequent flier with an anti-E. Her antibody couldn't be detected after several years. Then she came in a few weeks later with a roaring 4+ ant-E. My first thought was we has mistyped a unit we had given her. After investigating, it seems she went to a wedding out of state and while she was there, she popped into a hospital to get juiced up. She neglected to tell them she had an antibody, even though we give out antibody cards. They didn't see the anti-E so just transfused her. That is the closest we have ever come to thinking we mistyped someone.
I agree with Exlimey about repeating the ABO/Rh. I have worked for over 40 years and not once have I ever had a mistyped unit or even heard about a mistyped unit. I am guessing blood centers probably have multiple people type each unit to prevent labeling with the wrong type. It has always seemed like a waste of time to me. But it is a rule and we follow rules. 

My previous boss always said they had to come up with new rules to justify their jobs.
When they can't find the "low hanging fruit" because we all try hard to do the right things and follow the rules, they start digging deeper and come up with stupid stuff. As long as they keep coming up with new rules, they keep their jobs.