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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. |
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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.
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| 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.
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