          |
|
People and Opinions

TIR 12: The device reprocessor’s bill of rights
by Ralph Basile and Stephen Kovach
In the Spring of 2005 AAMI published a new document, TIR
12, which details the responsibilities of device manufacturers for
designing, testing, and labeling their reusable medical devices for
reprocessing in healthcare facilities. The document also details, by
implication, the expectations Sterile Processing Departments (SPDs)
should have of their medical device suppliers. From the Sterile
Processing Department perspective, TIR 12 is the device reprocessor’s
"Bill of Rights."
The introduction to TIR 12 states, "… this TIR can
also be a resource in identifying the questions health care
professionals should ask manufacturers when considering a product for
purchase or when devising a reprocessing protocol for a product already
being used."
The document stipulates that "Manufacturers of
reusable medical devices have the responsibility to support product
label claims of reusability by providing complete and comprehensive
written instructions for the handling, cleaning, disinfection, testing,
packaging, sterilization, and, if applicable, aeration of their products."
We as reprocessors are not free from obligation,
however. TIR 12 further states, "Health care personnel have the
responsibility to obtain and review manufacturers’ data and
recommendations and to ensure that they have the necessary resources to
follow manufacturers’ instructions thoroughly."
In an ideal world, SPD staff would perform such a review
prior to the purchase of a device. Often, however, SPD is never even
consulted—let alone given a seat at the evaluation table—on the purchase
of a new device. Even so, reprocessing professionals have an obligation
to the patient to have in place a procedure for evaluating both the new
devices and their own ability to properly reprocess them.
TIR 12 is an extensive guideline with in-depth
recommended practices for device manufacturers and for sterile
processing departments. This article will highlight key recommendations
for information that should be provided for decontamination. The authors
strongly suggest that SPDs obtain their own copy of this important
document.
TIR 12 contains six sections and five annexes.
Section 1 defines the
scope of the document; its important message is discussed above.
Section 2 defines terms
useful for SPDs and manufacturers. Many of these terms are quite
familiar and could be defined in similar words by most reprocessing
professionals. For instance, TIR 12 defines a biological indicator as a
"microbiological test system providing a defined resistance to a
specified sterilization process." Disinfection is defined as a "process
that kills pathogenic and other microorganisms by physical or chemical
means."
TIR 12 also defines two important terms, verification
and validation:
"2.38 user verification: Documented procedures,
performed in the user environment, for obtaining, recording, and
interpreting the results required to establish that predetermined
specifications have been met.
2.39 validation: Documented procedures for obtaining,
recording, and interpreting the results required to establish that a
process will consistently yield product complying with predetermined
specifications."
So what does this mean to SPD professionals? Basically
that reprocessors are responsible for verifying in-use what the medical
device manufacturer has demonstrated through validation.
Section 3 of TIR
12, "Design Considerations," details the key issues manufacturers need
to consider in the design and construction of their medical devices. A
great deal of this discussion is clearly aimed at the manufacturer, but
reprocessors should find the following words important:
"A medical device intended for reuse must be designed
to ensure that it will perform safely and effectively throughout its
useful life when it is reprocessed according to the device
manufacturer’s instructions; a poorly designed device is more likely to
be damaged by a cleaning, disinfection, or sterilization process than is
a well-designed product. In addition, the device must be designed so
that health care personnel will be able to thoroughly clean and
effectively disinfect or sterilize the device repeatedly throughout its
useful life."
AAMI’s TIR 12 places the burden squarely on the
manufacturer to consider during the design phase the equipment and
methods that healthcare facilities commonly use to clean and sterilize
instruments. Do manufacturers always do this? They should, and perhaps
TIR 12 will encourage them to do so.
Section 4
covers decontamination, a subject of vital
importance for reprocessors. TIR 12 is quite specific regarding the
obligations of the device manufacturer:
"To assure users that an item can be successfully
decontaminated, device manufacturers should develop decontamination
recommendations that
a) provide for thorough cleaning and defined
microbial lethality;
b) can be performed in the health care facility
using commonly available chemicals, supplies, and
equipment;
c) can be duplicated by health care personnel;
d) can be easily understood by the user;
e) are in alignment with the recommendations of
professional organizations and with OSHA regulations for minimizing
occupational exposure to bloodborne pathogens (29 CFR 1910.1030); and
f) include a method by which users can verify
effective decontamination."
These recommendations should be provided in writing to
SPD personnel. Section 4.2.1 states, "The device manufacturer should
specify, in written instructions, the specific cleaning agents and
procedures that should be used to avoid damaging the device."
What should be included in these written instructions?
First, acceptable cleaning agents must be identified. If an instrument
is not clean, it cannot properly be rendered sterile. The device
manufacturer knows what its instrument is made of and should know what
commonly used agents are most effective in cleaning that material
without damaging the instrument. Further, manufacturers must specify any
conditions, such as water quality (pH level, hardness, etc.), detergent
concentration, exposure time, water temperature, and rinse time that
should be met. This is particularly true if the conditions differ from
the labeling instructions on the cleaning agent itself. TIR 12 does not
free the reprocessor from obligation, however: "It is ultimately the
user’s responsibility to choose the correct cleaning agent on the basis
of the instructions of the device manufacturer and any recommendations
of the cleaning equipment manufacturer (Section 4.2.3.1)."
TIR 12 provides some special considerations/instructions
for cleaning agents. If a manufacturer specifies the use of an enzymatic
detergent, it must not only specify water quality (e.g., pH level),
time, temperature, and exposure (especially if it differs from labeling
instructions of the enzymatic) but keep one other factor in mind:
"(4.2.3.2 ) Enzymes are themselves protein substances and must be
thoroughly rinsed away, unless the manufacturer directs otherwise."
This reminds users that although enzymatic cleaners generally will not
damage man-made materials, they can be damaging to humans if they enter
the body.
Most SPD professionals know that rinsing is a very
important final step in the washing process. Water, enzymes, detergents
and energy (in the form of ultrasound, mechanical spray from a spinner
arm, or one’s elbow grease at the other end of a brush) break down the
contaminating soils, but they do not remove them from the water. Without
proper rinsing, these contaminates can reattach themselves to
instruments. Further, the quality of water is often more important in
this step than in the earlier ones, because water that is hard, for
instance, may not attach itself to the contaminating soils and wash them
away. If the water itself is loaded with impurities (organic and
otherwise) it may deliver a new batch of contaminates to the instrument.
TIR 12 states, "(4.2.3.5) If an analysis of the water used in the
testing (for validation purposes by the Device Manufacturer) was
performed, the results should be provided to the prospective device user,"
so that the user knows to use the same quality water.
In addition to discussing the cleaning agents, TIR 12
reviews the various methods for cleaning: Manual, ultrasonic, and
mechanical. Specifically the document addresses the problem of
contaminant aerosol created during manual cleaning, which brings the
reprocessor in very close proximity to the contaminating soils. TIR 12
states, "(4.2.4.2) For devices that cannot be immersed, it is
important that manufacturers provide instructions on how to clean and
rinse such devices without creating aerosols." Manufacturers must
keep the safety of reprocessing staff in mind—as must the reprocessor!
Special instruments often require special cleaning
implements, and the manufacturer needs to specify these: "(4.2.4.2)
For lumen-containing instruments that require brushing as part of the
cleaning process, the manufacturer should specify the correct brush
dimensions (length and diameter) that are appropriate for use with the
lumen diameter of the instrument. Device manufacturers should provide
information regarding any specialized implements or equipment that will
be needed and direct the user to sources of such implements or equipment."
Of course, TIR 12 strongly promotes the use of
mechanical cleaning devices whenever and wherever they can be used.
"(4.3.1) Device manufacturers should provide users with one validated
manual cleaning method and, if applicable, one automated cleaning method."
These recommendations are made to ensure the safety of the reprocessor;
contact between SPD staff away and instruments with gross contaminants
should be kept to a minimum. "(4.2.4.3) Device manufacturers should
evaluate at least one of the various cleaning methods that might be used
and advise users on those that are appropriate or inappropriate for
cleaning their devices. This evaluation should include validation
studies by the device manufacturer, verification by the device
manufacturer of data generated by equipment manufacturers that support
processing of a particular device, and/or collaborative efforts by both
the medical device and cleaning equipment manufacturers." This
documentation should include a description of the cleaning procedures
followed in this validated process.
Ultrasonic cleaning warrants a special warning. While a
very effective method for cleaning many instruments, in certain
situations and with some instrument ultrasonic cleaning is highly
unadvisable: "(4.2.4.3) Because ultrasonic energy can loosen the fine
screws of delicate instruments, can destroy the glues or amalgam used in
certain complex instruments, and may not penetrate very long or narrow
lumens, the device manufacturer should warn the user if an ultrasonic
cleaner will damage the device or be ineffective."
Any procedure(s) the manufacturer specifies for cleaning
must include written directions for the user. Further, manufacturers
must provide reprocessing staff with hands-on training, training videos,
or (at a minimum) illustrated directions for instruments that are
particularly difficult to clean. Instructions must tell the user not
only how to clean, but also how to verify that proper cleaning has
occurred, either through direct inspection or through use of an
analogous device:
"(4.3.5) The device manufacturer should provide
users, on request, with a summary and interpretation of test data or
other information that verifies the efficacy of the manufacturer’s
recommendations for cleaning agents and cleaning procedures.
Manufacturers should strive to develop and validate test procedures that
can be replicated easily in a health care facility and that can help
users recognize whether cleaning was effective for all device surfaces.
Such tests would be particularly important for devices with components
that cannot be readily inspected for cleanliness (e.g., spring hinges,
lumens, porous materials, crevices).
Section 5
of TIR 12 discusses disinfection. Device manufacturers must recognize
the dual importance of disinfection. First, the safety of SPD staff:
reprocessors must be able to handle instruments safely as they prepare
them and assemble them for sterilization. Second, certain instruments do
not require or do not tolerate sterilization; for these instruments
disinfection is the final stage of decontamination prior to use.
Manufacturers need to recommend to the user the appropriate method for
disinfection and the steps to take in order to properly disinfect all
surfaces of a device, in accordance with the level of disinfection
(high, medium, low) needed.
Specifically, manufacturers need to consider the level
of disinfection required and the ability of the recommended disinfecting
agent to deliver that level: "(5.1) Manufacturers selecting
disinfectant products to be used with their devices must know the
spectrum or range of antimicrobial activity of the disinfectant
formulation, the interaction of the disinfectant agent with the
materials used in device construction, and the ability of the
disinfectant to contact all device surfaces that will be contaminated
during normal use."
Further, manufacturers must consider material
compatibility: "(5.6) Device manufacturers should conduct tests to
determine the effects of the disinfectant they recommend for use with
their products. Product compatibility testing should be completed to
simulate the amount of time the device will be in contact with the
disinfecting agent during repeated processing for the specified life of
the device."
As part of their filing with the FDA, device
manufacturers must not only describe suitable methods for disinfection,
they must validate that these methods are indeed effective. As part of
the instructions for the reprocessor, they need to describe these
methods and supply the documentation that they are effective: "(5.8)
Device manufacturers should provide test data and other information
supporting the efficacy of the recommended disinfectant products and
procedures. Such information should include any test procedures that can
be easily replicated in the health care facility and that can help users
determine whether the disinfecting process was effective in rendering
the device safe for patient use. Disinfecting procedures developed by
manufacturers must, of course, be repeatable in health care facilities."
Section 6
lays out the responsibility of the manufacturer for developing,
validating, and describing at least one method of sterilization for
those devices that require it. Further, the method(s) recommended for
sterilization need to be those commonly used by healthcare facilities
(steam, EtO, gas-plasma, etc.). We, as users, also have a
responsibility; namely, to verify that we can get the device sterile
using our equipment: "(6.1)The device manufacturer is responsible for
qualifying the sterilization process for the device, and health care
personnel are responsible for showing that they can replicate this
process exactly and consistently."
Section 6 of TIR 12 specifically covers:
" (6.1)
a) sterilization processes available to
health care personnel,
b) considerations in designing devices for
sterilizability,
c) packaging considerations,
d) procedures that may be used for
sterilization process qualification,
e) considerations concerning device and
sterilization compatibility,
f) evaluation of sterilant residues and
aeration or rinsing parameters,
g) appropriate documentation of
qualification,
h) information to be supplied to health
care personnel, and
i) device requalification."
Packaging is another major consideration. The
manufacturer either should provide a packaging vessel (e.g., tray) that
has been tested and validated to allow proper sterilization of the
instruments contained, or describe a procedure using packaging methods
commonly employed in healthcare facilities that has been demonstrated to
allow for proper sterilization.
With their labeling and instructions for use, the
manufacturer should provide detailed instructions, including:
"(6.9)
a) disassembly and reassembly instructions;
b) a statement to the effect that failure to
properly clean the device could lead to inadequate
sterilization;
c) the accessories required for sterilization;
d) a description of the device packaging
recommended by the manufacturer for use in the
sterilization process;
e) the identification and concentration of the sterilant;
f) set points of the sterilization process;
g) the humidity required for the sterilization
process;
h) the pressure required for the sterilization
process;
i) the required temperature of the sterilant;
j) the minimum holding or exposure time for the
sterilant;
k) if rinsing after sterilization is required,
specific instructions to ensure that recontamination
does not occur;
and
l) a description of the process for removing toxic
chemical residues and the parameters of the process."
Early adoption of TIR 12
Some manufacturers are already implementing the TIR 12
guidelines. In May 2005, Smith & Nephew updated its Cleaning and
Sterilization Guide for Orthopedic Instruments. The following are two
excerpts from the new user guide:
"The quality of water should be carefully considered
for use in cleaning reusable devices. Water hardness is a concern
because deposits left on medical devices may result in ineffective
decontamination. The use of deionized water will reduce the mineral
deposits on the devices."
"Ultrasonic Cleaners should be monitored routinely to
ensure that they are working properly. Recommended monitoring methods
are: 1) Sonocheck monitoring vials (from Healthmark Industries Co., St.
Clair Shores, MI) which change color when the ultrasonic cleaner is
supplying sufficient energy and conditions are correct."
These excerpts are examples of the manufacturer
providing specific details to the end user. They address questions
important to the cleaning process, such as, is the equipment working
properly? Is the correct type of water being used?
Getinge is another manufacturer that has stepped up to
the TIR 12 plate. Getinge has developed a performance monitoring program
that allows users to independently verify that key parameters of the
cleaning equation are under their control.
This article has highlighted just a few sections of TIR
12. Hopefully sterile processing professionals will recognize how
important this updated TIR 12 is to their departments and will obtain
and use the document as one of their standard references. Now an SPD
staff has a manual it can refer to before making a purchase. When they
request for a new product, they can now specify that it meet the
requirements found in TIR 12.
Although TIR 12 was written to guide device
manufacturers, it also guides us as reprocessors. We do not "make" the
device, but we really are part of the manufacturing process. We are the
"aftermarket" manufacturer – taking the device apart, cleaning,
disinfecting, reassembling, sterilizing and verifying that the device is
ready for reuse. So this document is for sterile processing
professionals as well. It is our Bill of Rights, but it is also our
Declaration of Responsibility. TIR 12 is a new, valuable tool SPDs can
use in working with their device suppliers to deliver quality patient
care. HPN
Editor’s note:
Designing, testing, and labeling
reusable medical devices for reprocessing in health care facilities: A
guide for device manufacturers, 2ed (TIR12) can be purchased from
AAMI at their Web site: www.aami.org or by calling them at:
(703)525-4890.
About the authors:
Ralph Basile is vice president
marketing and Stephen Kovach is the director of education at Healthmark
Industries .
|
|
|
December
2005 |
|
 |
 |
|
|