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