In Elam v. College Park Hospital (1982) 132 Cal.App.3d 332, the appellate court found that a hospital "owes generally a duty to ensure the competency of its medical staff and to evaluate the quality of medical treatment rendered on its premises." (Id. at p. 347.) The Elam appellate court stated further, "a hospital is accountable for negligently screening the competency of its medical staff to ensure the adequacy of medical care rendered to patients at its facility." (Id. at p. 346.) In Elam, the Court of Appeal held that a hospital may be liable under the doctrine of "corporate negligence" for the malpractice of independent physicians and surgeons who were members of hospital staff, and availed themselves of the hospital facilities, but were not agents or employees of the hospital. (Elam, supra, 132 Cal.App.3d at p. 335.) That was because a hospital generally owes a duty to screen the competency of its medical staff and to evaluate the quality of medical treatment rendered on its premises. (Elam, supra, at p. 347.) Thus, a hospital could be found liable for injury to a patient caused by the hospital's negligent failure "to insure the competence of its medical staff through careful selection and review," thereby creating an unreasonable risk of harm to the patient. (Id. at p. 341.) Elam explained that "the term 'corporate negligence' has been commonly used to describe hospital liability predicated not upon vicarious liability ... , but upon its violation of a duty--as a corporation--owed directly to the patient which resulted in injury." (Elam, supra, 132 Cal.App.3d at p. 338, fn. 5.)