Inside the Current Issue

Cover Story
Track, trace care quality via instrument reliability, safety
Self Study Series
Purchasing Connection
Resources
Show Calendar
HPN Hall of Fame
HPN ProductLink
Classifieds
Issue Archives
Advertise
About Us
Home
Subscribe

Email Newsletter icon, E-mail Newsletter icon, Email List icon, E-mail List icon Sign up for our Email Newsletter

For Email Marketing you can trust
Special Event Photos
Contact Us
KSR Publishing, Inc.
Copyright © 2012

People, Places, Processes & Products that Influence the Supply Chain

 
 

INSIDE THE CURRENT ISSUE

August 2010

CS Solutions

Questions can be sent to:jakridge@hpnonline.com
called in to Jeannie Akridge at HPN:(941) 927-9345 ext.202 or mailed to:
HPN CS Questions, 2477 Stickney Point Road, Suite 315B, Sarasota, FL 34231
Names and hospital identification will be withheld upon request.

Reprocessed single use devices; cleaning verification QA

by Ray Taurasi

Q We have been utilizing an outside third party source to reprocess some of our single use devices (SUDs).While I have been keeping a log of all devices that we send out for reprocessing to date we have not been notifying our patients that a single use medical device may be used on them. Should patients be informed when a SUD is used on them? Doesn’t using a new device on some patients and a reprocessed SUD on another constitute a double standard of care?

A The reprocessing of single use devices is classified as a manufacturing activity and the process is regulated by the US Food and Drug Administration (FDA). Any source that reprocesses SUDs in the eyes of the legal system is deemed to be the manufacturer of that device. Manufacturers of medical devices including "third party reprocessors" or hospitals that choose to do this practice must comply with very rigid FDA manufacturing standards and regulations. To be certain that the SUDs you are having reprocessed meet the FDA’s strict requirements it is critical that you contract with a reprocessing company that is registered and regulated by the FDA with the appropriate clearances to reprocess the devices you are sending to them.

Assuming that you are indeed utilizing the services of a reprocessing company regulated by FDA and the devices being reprocessed have been cleared by FDA there is no need to inform patients that reprocessed devices are being used on them, nor is it considered a dual standard of care to use a new device versus an FDA cleared reprocessed device on patients. To obtain FDA clearance the reprocessor must demonstrate and prove that the reprocessed device is equivalent in performance, safety and quality as it was when originally manufactured by the OEM (original equipment manufacturer). The reprocessor must validate amongst other things the device’s effective functionality, cleaning, and sterilization. Once the FDA has cleared a reprocessed SUD it means that the device has proven to be equivalent in all regards to the original or new device. In such, there is no considerable difference between the two products and thus no dual standard exists.

Q Over the past year there have been countless media headlines of virtually thousands of patients who have been potentially exposed to harmful pathogens, HBV, HIV and the like following endoscopic procedures where it was discovered scopes were not adequately cleaned. I find this extremely alarming yet I recognize that failures in processing equipment or protocols could occur at any time in any hospital. As the manager of sterile processing I have implemented a cleaning verification QA program for all items and processes conducted in SPD, however the nurse manager of our endoscopy unit does not believe there is a need to institute such a program in the Endo unit. She feels that her staff is very attentive and feels confident that the AER, manual cleaning processes and standards she enforces are superior. She blatantly stated she would not add another step such as cleaning verification into the protocol until it was required by regulations. Do you have any advice on how I could possibly influence her on the importance of implementing a QA cleaning verification process in the GI unit?

A Having the best of facilities, equipment, and staff are indeed critical but as you noted equipment and processes can still fail and often without detection. I have heard from hospitals that have implemented cleaning verification testing for their endoscopes, that they discovered that 20 – 40%, and in one case as high as 75%, of "cleaned" processed scopes tested positive for blood residuals. A Quality Assurance program provides confidence and proof on the efficacy of procedures and protocols. The cleaning verification testing of the endoscopes made the invisible visible, and allowed these hospitals to make moderate adjustments in processing procedures to render quality results which could be documented by the testing results. There are very simple endoscope testing tools available, such as a swab probe test that can detect residual blood and/or protein soil in the scope’s channels (figure 1), or a dip strip test which can detect residuals of protein, hemoglobin or carbohydrates from water that is flushed through the scope’s channels (figure 2). You may share the following information with the nurse manager of your endoscopy unit which supports the monitoring of the cleaning process of flexible endoscopes.

Figure 1 Figure 2

• Multi-Society Guideline position paper on Reprocessing flexible GI scopes states: "Healthcare facilities should develop protocols to ensure that users can readily identify whether an endoscope is contaminated or is ready for patient use." (Gastrointestinal Endoscopy, Volume 58 No.1; page 5)

• SGNA (Society of Gastrointestinal Nurses and Associates) states: "Each setting where gastrointestinal endoscopy is performed must have an effective quality assurance program with special emphasis on cleaning and high level disinfection of flexible endoscopes."

• AAMI ST 79 states: "Some types of mechanical cleaning equipment are designed to clean and/or disinfect specific kinds of medical devices, such as endoscopes… Mechanical cleaning equipment should be tested upon installation, weekly (preferably daily) during routine use, and after major repairs." (7.5.3.3)

• Section 10.2 and AAMI ANNEX D states "… processing personnel are increasingly aware of the need to control and standardize the steps taken to ensure the sterility of devices for patient use. Because disinfection and sterilization cannot be assured unless the cleaning process is successful, professionals in the field ought to seek out whatever means are available and practical to verify this function. A quality system would call for monitoring and documenting decontamination processing parameters, whether the process is accomplished by hand or mechanically…." (Section 7.7.5)

Ray Taurasi is Eastern Regional Director of Clinical Sales and Services for Healthmark Industries. His healthcare career spans over three decades as an Administrator, Educator, Technologist and Consultant. He is a member of AORN, AHA, SGNA, AAMI and a past president of IAHCSMM and has served on and contributed to many national committees with a myriad of professional organizations, manufacturers, corporations and prestigious healthcare networks. Taurasi has been a faculty member of numerous colleges teaching in the divisions of business administration and health sciences. In addition to this column he has authored several articles and has been a featured speaker on the international scene.