H 26.22(2) (2d ed. 1969)). Considering that a lack of confidentiality would destroy the “constructive professional criticism” that is “essential to the continued improvement in the care and treatment of patients,” the court concluded that “there is an overwhelming public interest in having those staff meetings held on a confidential basis so that the flow of ideas and advice can continue unimpeded.” Id. The “self-critical” privilege has also been recognized in a variety of actions in which confidentiality is “essential to the free flow of information and ... the free flow of information is essential to promote recognized public interests.” Note, The Privilege of Self-Critical Analysis, 96 Harv.L. Rev. 1083, 1087 (1983). See, e.g., Richards v. Maine Cent. R.R., 21 F.R.D. 590 (D.Me.1957) (<HOLDING>); O’Connor v. Chrysler Corp., 86 F.R.D. 211
holding railroad rate exempt from state regulation holding that in a personal injury action against a railroad a report containing the conclusions of a hearing examiner of the public utilities commission regarding an alleged hazardous railroad crossing was obvious hearsay holding railroad regulation requiring random drug testing without particularized suspicion to be reasonable in light of connection to public safety recognizing a selfevaluative privilege to railroad companys investigation of an accident in light of the publics stake in the improvement of railroad safety holding that reinstatement of the grievant a railroad employee terminated for drug and alcohol use violated the welldefined and dominant public policy against a railroads employment of individuals whose impaired judgment due to the use of drugs or alcohol could seriously threaten public safety and placed the railroad at risk of violating the federal railroad administration regulations