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“The Guru is none other than the Creator, Lord Brahma;
        He verily is Lord Vishnu, the Preserver,
                          and
        He truly is Maheshvara, the Destroyer.
         He is the supreme Brahman himself,
        To such a Guru I offer my Salutations”

                                                         3
‘ No stronger condemnation of any hospital or ward could be
pronounced from the single fact that zynotic (infectious)
disease have originated in it,or that such a disease has
attacked other patients than those brought in with them’

                      - florence nightingale
   Some of the slides an the material are borrowed
    and I acknowledge Dr. Gita Nataraj from KEM,
    Mumbai and the HISI newsletter on SUDs
    reprocessing
   The entire story is borrowed from experiences of
    others and self
   I do not claim to be an expert and am as much a
    student eager to learn
   I acknowledge the contributions of technical staff
    and nursing for implementation of the program
    and the entire Infection Control colleagues at
    Delhi Apollo, particularly Dr. Leena Mendiratta


                                                         5
   Original device: “The term ‘original device’ means a new, unused entire
    single-use device.”

   Single-use device: “The term ‘single-use device’ means a device that is
    intended for one use, or on a single patient during a single procedure.”

   Reprocessed: “The term ‘reprocessed’, with respect to a single-use
    device, means an original device that has previously been used on a
    patient and has been subjected to additional processing and
    manufacturing for the purpose of an additional single use on a patient.

   Critical reprocessed single-use device

   Semi-critical reprocessed single-use device




                                                                               6
7
8
30% of all hospitals reuse one / more SUDs




Not all SUDs can be reused / reprocessed




50% of hospitals reuse through a third party processor




                                                         9
10
2002;7(1):53-
                                               59




Conclusions:
•No significant overall difference in temperature sensing
accuracy and deflection angle of new and used ablation
catheters.
•Nevertheless, individual differences in deflection
characteristics between new and used catheters are
occasionally seen and warrant screening of reprocessed
catheters prior to their reuse
                                                               11
CONCLUSIONS: Reuse of medical devices labelled "single use only" is
common in Australian hospitals. Most devices appear to be unsuitable for
reuse. Complete cessation of this practice of reusing single-use medical
devices would stop potential cross-infection, but this would cost and
estimated $2.5 million or more per case prevented




                                                                           12
•Tradition of re-use – reports on re-use of pacemakers are
available from Europe, North America and Asia (India) with no
reported adverse effects
•During 1996, in Sweden, 5% of pacemakers were re-used
devices, with no evidence that re-use has increased patient risk.
•Re-use of pacemakers may be considered, provided that their
sterility, mechanical and electrical integrity can be ensured and
operating procedures are respected. Re-used pacemakers
should only be given to patients whose life expectancy is
estimated to be less than that of the pacemaker.
                                                                    13
A Randomized Study of the Safety and Efficacy of Reused Angioplasty
Balloon Catheters
M Zubaid, CS Thomas, H Salman, I Al-Rashdan, N Hayat, A Habashi, MT
Abraham, K Varghese, L Thalib
Department of Cardiology, Chest Diseases Hospital, Kuwait and
Department of Community Medicine, Faculty of Medicine, Kuwait
University



Conclusions: When performing coronary angioplasty, reused catheters
are as effective (similar angiographic success) and safe (similar clinical
success) as new catheters. (Indian Heart J 2001; 53: 167–171)




                                                                             14
The issue really is not whether or not to reprocess, but
what constitutes safe and appropriate reuse of disposable
items.

                                                            15
   ……. requires that 510(k)s for listed reprocessed SUDs
    include “validation data, regarding cleaning and
    sterilization, and functional performance demonstrating
    that the [SUD] will remain substantially equivalent to a
    predicate device after the maximum number of times the
    device is reprocessed as intended by the person submitting
    the premarket notification.”
   On April 30, 2003, FDA identified in the Federal Register
    those critical reprocessed SUDs whose exemption from
    510(k) would be terminated.
   On April 13, 2004, FDA identified those semi-critical
    reprocessed SUDs whose exemption would be terminated.
   On September 29, 2005, FDA updated and consolidated the
    lists of the critical and semi-critical reprocessed SUDs that
    would no longer be 510(k) exempt


                                                                    16
17
    …simply because they are not designed to be taken apart for
     adequate cleaning
    …. or to perform as specified after first use.
    In addition, many of the materials utilized in the various
     components of single use medical devices, both plastics,
     glues and metals, may not withstand the chemical
     environment of the solutions utilized
     Also, the temperatures required for autoclave sterilization
     may deform many components and subsequently
     compromise their performance and safety

     December 15, 2009


    Eucomed White Paper - The Reuse of Single Use Devices




                                                                    18
   Canadian Medical Device Technology Companies (MEDEC): the
    authors refer to a 2001 review where several reprocessed single
    use devices were retrieved from hospitals in the United States and
    in Europe.
   In total, 136 devices were obtained from hospitals on both
    continents and included clip appliers, clamps, staplers, cautery
    devices, tracers and electrophysiology (EP) catheters.
   Examination revealed that at least half of these products had
    packaging defects, were contaminated with residual blood or
    tissue, and/or experienced functional failures.




                                                                       19
   MEDEC - German report, 2001 (Andreas Beck)
    where 727 angiography catheters and guide wires
    were studied
   The results showed numerous physical variations
    in devices including nicks, kinks, roughness,
    erosion, tears and changes in material properties.
   The author concluded that the refurbishment of
    devices intended for single use by both healthcare
    facilities and third party reprocessors is
    inappropriate and a risk to patient safety



                                                         20
   SGNA believes that patients deserve the same standard of care
    regardless of practice setting.
   The reuse of SUDs is a complex issue that must be balanced
    with the assurance of patient safety and the delivery of quality
    health care. These concerns cannot be overlooked when
    evaluating the legal, ethical, financial, and technical aspects of
    reusing SUDs.

   In the absence of substantial scientific evidence to prove the
    safety and effectiveness of reprocessed critical medical
    devices in the endoscopy setting, SGNA maintains the position
    that critical medical devices originally manufactured and
    labeled for single use should not be reused.
   Adopted by the SGNA Board of Directors, February 1998;
    Revised May 2002, October 2005, August 2008.


                                                                         21
   The WHO has stated ‘the safest and most
    unambiguous method for ensuring that there
    is no risk of residual infectivity on surgical
    instruments is to discard and destroy them by
    incineration … this strategy should be
    universally applied to those devices and
    materials that are designed to be disposable.’
       WHO Infection Control Guidelines for Transmissible Spongiform
       Encephalopathies, WHO/CDS/CSR/APH/2000.3. March 23-26, 1999




                                                                       22
   The use of a reprocessed single use device
    provides no direct benefit to the individual
    patient or her physician
   …Relies on voluntarily reported adverse
    events..
   …Studies on the safety, quality and cost-
    effectiveness are needed…..




                                                   23
A                                           B




A) PTCA balloon catheter refurbished by a third
   party and soiled with contrast medium and
   blood.
B) A comparison of a PTCA balloon and a
   household match demonstrating the small
   size of the catheter and how difficult it would
   be to ensure effective cleaning of such a
   small device

                                                         24
B




A




        25
A                                              C
                        B

    A) Proteinaceous contamination on the
       inner surface of a guiding catheter.
    B) XPS Scan / Spectrum confirming that
       the reddish contamination is blood.
    C) Scanning electron micrograph (SEM)
       photograph to confirm the presence of
       a red blood cell

                                                   26
Reddish brown contamination observed over the
full length of the third party reprocessed
endoscopic stapling device

                                                27
A                             B                                  C


    A) Flaking marker on a reprocessed balloon catheter, which
       may result in release of particles into the patient’s
       bloodstream.
    B) Marker of a new balloon catheter.
    C) Aluminium contamination in the lumen of a balloon
       catheter.



                                                                     28
A                                                B




    A) The coil of new, unused biopsy forceps.
    B) The coil of reprocessed biopsy forceps




                                                     29
…..Another challenge when reusing catheters is that it is difficult to predict when a
 catheter will degrade to a degree that it will break…..
 When and if depends on the type of polymer used and how it is manufactured.
 While some plastics degrade over time and show signs of wear others seem to fail
 spontaneously




   Degradation-time curves demonstrating how different polymers degrade over time

David L. West et al. “Scientific & Regulatory Consideration for the Review and
Approval of Reprocessed Single Use Devices Pre - market Submissions

                                                                                         30
Photograph showing kinks along a reprocessed
single use catheter as a result of previous usage
or reprocessing




                                                    31
When attempting to flush the single use
devices a distribution of the contamination
rather than cleaning was achieved…..


      Demonstration of the distribution of contamination rather than
      removal as assessed using the radionuclide method of detection


….Most of the inspected devices showed residual contamination in the
hinges and under the isolation coats .This was especially true for
harmonic scalpels. These findings indicate that the cleaning agent
penetrates into the device and dilutes the blood but cannot then be
flushed out of the device. Therefore, contamination and disinfection
solution remain in the devices ……

              2001, Roth, Heeg, and Reichl



                                                                       32
   A single-use bladder pressure transducer cover
    was not changed between patients, resulting in
    cross-infection due to Pseudomonas
    aeruginosa. One patient developed septicaemia
    and died of a sub-arachnoid haemorrhage
   A lithotriptor stone retrieval basket, which was
    a single-use device, had been reprocessed and
    appeared to be satisfactory for use. During the
    procedure,the cable was tightened and
    snapped, resulting in the basket remaining in
    the patient. Further surgery was required to
    retrieve it.
    Single-use Medical Devices : Implications and Consequences of Reuse
    MHRA DB 2006(04) v2.0 December 2011




                                                                          33
30% of all hospitals reuse one / more SUDs



Not all SUDs can be reused / reprocessed



50% of hospitals reuse through a third party processor



The cost is reduced by ½ to 1/10




                                                         34
    The main complication in performing true cost-
     benefit calculations in relation to refurbishment
     and reuse of single use devices is the challenge
     created by the increased patient risk involved.
    How can a price be assigned to increased patient
     risk?
    Some studies touch directly upon the problems
     associated with creating a true financial cost-
     benefit analysis, while others ignore this
     complication entirely and therefore reach
     questionable financial conclusions
    This does not include the hidden costs related to
     the risks of using refurbished single use devices,
     such as HAI, complications, litigation, staff injuries
     etc.


    Single-use Medical Devices : Implications and Consequences of Reuse
    MHRA DB 2006(04) v2.0 December 2011
                                                                          35
Cost-effectiveness……? We are doing a study
   Personnel costs: Cost of employing technical and qualified personnel for pre-
    cleaning immediately after the point of use, assembly, dismantling and
    replacement activities, maintenance and cleaning, repairs, wear and tear,
    sterilisation, sterilisation checks (chemical and biological), packaging, etc. In
    addition, personnel and/or costs for longer procedure time, re-operation and
    infections should be considered.
   Investment costs: Costly apparatus (capital equipment), buildings (designated
    for storage/spare parts); centralised sterilisation unit and special apparatus
    (autoclaves, machines for washing the devices, ultrasonic baths, means of
    cleaning, chemical products, disinfectants, lubricants, etc).
   Administrative costs: Systems used to communicate the results and establish
    traceability, managing reserves of spare parts/stock, distribution, transport,
    insurance premiums, documentation, validation procedures, auditing third
    party refurbishers, recording accidents and injuries involving members of
    staff, etc.
   Utility costs: Cost of providing the utilities associated with the sterilisation
    process (electricity and water consumption [including drainage]).
   Miscellaneous costs: Overheads, protective clothing (gloves, masks, safety
    glasses, double-thickness packaging materials), provision of safety training in
    connection with the re-utilisation of instruments, cost of treating post-
    operative infections and handling complaints

                                                                                        36
Potential Risks              Examples
Potential for cross          Any component of Microbial world esp Blood borne
infection                    viruses

Inability to clean and       Features of a device that make cleaning difficult are:
decontaminate                acute angles, coils, long or narrow lumens, spécial
                             surface coatings etc.
Residues from chemical       Disinfectants may be absorbed by plastics and leach out
decontamination agents       during use, resulting in chemical burns or a risk of
                             sensitization of the patient or user.
Material alteration          Plastics may soften, crack or become brittle during
                             exposure to elevated temperatures or pressure during
                             the sterilization process or exposure to cleaning agents
                             and chemical sterilants
Mechanical failure           Some devices may experience stress during each cycle of
                             reuse, leading to fatigue-induced failure and fracturing
                             e.g. single-use drill, burrs, saw blades, craniotomy
                             blades catheters
Reaction to endotoxins       If the device has a heavy bacterial load after use, which
                             cannot be adequately removed by cleaning
                  MHRA DB 2006(04) v2.0 December 2011
Transmission of CJD,
Prions                                                                                   37
30% of all hospitals reuse one / more SUDs

Not all SUDs can be reused / reprocessed

50% of hospitals reuse through a third party processor
Clinical evidence does not indicate increased risk in controlled
settings
Reuse is not a harmless procedure – Document Integrity and Safety

Continued surveillance for adverse events is required

The procedure has to be regulated

The cost is reduced by ½ to 1/10




                                                                    38
   The FDA classifies single-use medical devices according to the
    level and type of control needed to ensure that the devices are
    safe and effective.
     - Class I devices need the fewest controls
     - Class II devices require "special controls."
     - Class III is the most stringent regulatory category and
    medical devices that fall under this category require a
    premarket approval
   Class I and Class II devices are the best candidates for
    reprocessing, with some notable exceptions.

       Medical Device Reprocessing Don Selvey, 2011

                                                                      39
Reprocessable Class I devices include:
   Orthopedic chisels
   Surgical curettes
   Surgical gouges
   General use surgical scissors
   Non-electric biopsy forceps
   Orthopedic knives
   Orthopedic saw blades
   Chisels
   Rasps

     Between 65 and 75% of all single-use medical devices are identified as Class II.
     Class II single-use devices include:
   Non-ported trocars for endoscopic procedures
   Sequential compression devices (compression sleeves)
   Most laparoscopic instruments, including: scissors, clamps, dissecters and
    graspers
   Recording and diagnostic EP catheters
   Drills and burrs
   Flexible snares

      Class III devices include:
   Transluminal coronary angioplasty catheters
   Percutaneous and conduction tissue ablation electrodes
                                                          Medical Device Reprocessing
   Implanted infusion pumps
                                                                Don Selvey, 2011




                                                                                        40
S.U.D Policy: Components
   S.U.D. List (approval of End-Users and Management and
    ICC members)
   Specialties using S.U.D.
   Serial Number for each S.U.D
   Number of re-uses specified for each S.U.D
   Protocols on Re-processing of S.U.D.
   Training of Personnel involved (Part of staff Appraisals)
   Functional integrity check to each S.U.D.
   Rejection Criteria of each S.U.D
   Traceability
   Monitoring of S.U.D
   Recall Policy
   Documentation
   Validation by user / third party reprocessor
   Monitoring of Policy


                                                                41
   Initial pre-cleaning on site
   Cleaning and rinsing
   Decontamination
   Marking (number of re-uses)
   Packaging
   Labeling
   Sterilization
   Documentation



                                   42
   For all devices (narrow lumen/balloon) it is necessary to test the
    functional integrity before drying.

   The devices shall be inspected for any damage and its functional
    integrity verified by the user after the process of cleaning and
    decontamination

   Assessment of the functional performance on a worst case basis,
    i.e., after the maximum number of times the device is intended to
    be reprocessed as specified.

   Simulation of device in reprocessing cycle and this step should be
    specified in the summary of the process design and validation.

   The performance tests should be summarized in the process design
    and validation documentation
                                                                         43
   Incase the number of usages equals the number of usages
    as per Policy, approved for that particular article.
   Any kinks, curves leading to loss of functional integrity
   Blood clots not getting removed
   Loss of Lumen patency
   Incase signals are not being received
   Any leaks
   Incase smooth functioning is absent
   Incase inflation is not taking place
   Incase of breakage
   Incase tip is blunted
   Incase tip is broken
   Incase sharp edge is blunted


                                                                44
   Ensure drying by either passing dry
    compressed air through it or drying in
    controlled environment (biosafety) for
    devices which are delicate or not able to
    withstand air pressure




                                                45
Marking


          Should be ensured that marking does not
          compromise on the integrity of the device




                                                      46
   Excess air must be removed from packets before
    sealing
   Appropriate packaging shall be carried out to
    ensure effective sterilisation.
   The packaging shall be compatible to the type of
    sterilization being carried out.
   The items shall be wrapped in medical grade
    packaging.




                                                       48
   Appropriate labeling of every packed item is done.
   The Label should include the following:
      - Name
      - Size
      - Manufacturer
      - Unique Device No
      - Usage no
      - Date of Last Usage
     - Date of reprocessing
    The Unique Device No includes the following essentially in the
    given sequence: Manufacturer / Serial Number of that particular
    item- as specified in the approved SUD List / Year of present
    usage/ Month of present usage/ no of times that particular type
    of item has been opened on that particular day, (eg Ox / 21 /
    2008 / 02/ 01)
   These items are then sent for further appropriate sterilization.



                                                                       49
S.U.D. Monitoring




                    50
   The device should be sterilised by an appropriate sterilisation
    method for that device e.g. ethylene oxide gas sterilisation
    method
   The process of sterilisation should be strictly controlled and as
    per the manufacturer’s instructions.
   The cycle shall be monitored with physical,
    chemical and biological indicators.
   The device shall not be released till 72 hours
    post- Ethylene oxide sterilization
   PCD to be used as simulators

                                                                        51
Labeling Gun:
   Sterilizer number,
   Load number,
   Batch number,
   Date of sterilization
   Date of expiry
Sterilization: Validation through Indicators
Keeping the track record of that article through appropriate documentation
                                                                             54
SINGLE-USE DEVICE REPROCESSING GUIDE TEMPLATE

         The following single-use devices have been approved for reprocessing by the Medical Executive Committee.

 No other single-use device may be reprocessed unless written authorization is obtained from the Medical Executive Committee.

Effective Date:

                                                                                                      Device Status
                                                                    Approved Third-Party
   Clinical Category     Device      Manufacturer     Model(s)                                           Open &
                                                                       Reprocessor               Used               Expired
                                                                                                         Unused




                                        Ambulatory Surgery Center Quality Programme




                                                                                                                                55
56
57
   Any adverse event related to the device
    should be reported in an incident- form




                                              58
“There is no conclusive evidence to substantiate
the notion that either morbidity or mortality
associated with single use or reuse is different.”
National Kidney Foundation Report on Dialyzer Reuse, AJKD 1997
Assuming a dialyzer price of $20, costs of
                                                                                               Reuse Cost Reduction Curve
       reprocessing of $5, and 15 uses, the cost savings for
       one patient are $2,050 every year with reuse

        Cost of Single Use vs. Multiple Use                                                                                   $25                                   $25
           (Cost per Patient per Year)
                                                                                                                              $20                                   $20
       $5,000




                                                                                                         Cost per treatment
                                                                                                                              $15                                   $15
       $4,000
                                                                                                                              $10                                   $10
       $3,000
Cost




                                                                       Costs for 50 Patients per Year                          $5                                   $5
                                                                         (6 Reuses vs. 15 Reuses)
       $2,000
                                                                                                                               $0                                   $0
                                                                   $70,000                                                          1   4   7   10   13   16   19
       $1,000                                                      $60,000
                                                   Cost per year




                                                                   $50,000
          $0
                  Single Use        Multiple Use                   $40,000
                                                                   $30,000
       Dialyzer Cost    Reprocessing Cost                          $20,000
                                                                   $10,000
                                                                       $0
                                                                              6 Reuses       15 Reuses

                                                                   Reprocessing Cost     Dialyzer Cost


                Automated Dialyzer Reprocessing , Minntech 1999

                                                                                                                                                                          60
Daily Checklist For Dialyzer Re-processing System                Serial no:____________
                   01.01.20
    Parameters                 02.01.2011    03.01.11    04.01.11   05.01.11      06.01.11         07.01.11
                       11
Calibration
Verification Volume
in ml
( 70[+/-]3 ml )
Pressure Log:
Static Pressure
(Ideally: 20 psi to 55
psi)
Dynamic Pressure
(Ideally: 35 psi to 40
psi)

Exterior Cleaning
with 1% Renalin

Caps:
30 minutes
disinfection with 1%
Renalin

Sanitization


VERIFICATION


                                                                                                              61
   If required, a S.U.D. maybe recalled, if decided
    so by the Infection Control Committee, incase
    of repetitive incidents if any, or if any such
    notification from the Manufacturer




                                                       62
   Appropriate Personal Protective Equipment (gown, gloves, eye-
    protection, etc) to be worn while cleaning and decontamination

   Care should be taken in the direct handling of intricate or sharp-
    edged devices to avoid injury to the handler or damage to the
    device.

   For devices with lumen special care should be taken while
    injecting the cleaning solution into the lumen so as not to cause
    damage




                                                                         63
   Cleaning, sterilization, and functional performance
    validation of reprocessed SUDs include aspects of
    both:
    (i) design validation
    (ii) and process validation.
   Design validation, in this case, should incorporate
    both the design of the product and the design of the
    processes to be used in reprocessing the device.



                                                           64
‘Rapid’ monitor that uses bioluminescence to measure
the levels of ATP on a surface. It works through
collection and quantification of ATP remaining in
organic residues post-cleaning


                                           Capable of detecting 2mg protein / m2

                                         ATP Results of less than 10 RLU are preferred




                                                                     Green Color-Satisfactory
VALIDATING SINGLE USE DEVICES

•Understanding it’s configuration and application (List of the
parts, mantling and dismantling, manufacturers
specifications)
•Point of use care (Immediate aspiration, flushing)
•Safe transport to re-processing department
• Standard operating protocols of reprocessing
department
•Number of turns, tracking, recall procedure
• Back to user
•Discard after the last use
Steps                        Validation                  Responsibility

Integrity & functionality    through Visual inspection Device User

Post use pre-cleaning        through visual inspection   Device User

Safe & covered transport Supervision                     (Assisting personnel)

Disinfection & thorough      Microbiological testing     Reprocessing Dept.
Cleaning                                                 & microbiology dept.

Inspection, Assembling,      Sterility check             CSSD
Packing, sterilization       (No toxic residues left)
                             Pyrogen free

Next turn usability          Check by user               User department

Usable life / No. of turns   Sterility Assurance &       User / reprocessing
                             Adequate working of         Microbiology
                             the device, QA              dept. headed by
                                                         I.C.Chief
68
Instrument      Single-use   Cost per        Additional    Saving per patient    Procedure where device
                device       patient when    cartridge    in multiple use (Rs)   used (Rs)
                (MRP) (Rs)   used multiple   Cost (Rs)
                             times
Harmonic        40,000-      7,000-          Nil          30,000                 Advanced and
Shear           50,000       10,000                                              routine Laproscopic
                             approx                                              surgery
Diagnostic      1000         250             Nil          750                    Interventional
guidewire                                                                        Cardiology and
                                                                                 radiology imaging
Angioplasty     10,000 –     4,000-5,000     Nil          5,000-6,000            Interventional
Balloon         12,000       approx                       approx                 Cardiology and
Catheter                                                                         radiology imaging
Open            21,000 –     4,000-5,000     4,000-       12,000-18,000          Open major
surgery         28,000       approx          6,000                               abdominal surgery
linear cutter                                approx
Endoscopic      22,000 –     5,000 approx    6,000-       11,000-18,000          Advanced
Linear cutter   36,000                       8,000                               Laproscopic
                                             approx                              Gastrointestinal
                                                                                 Surgery
Mutiload        19,700       2,000 per       Nil          8000 if an             Clipping of blood
clip                         clip applied                 average of 6           vessels, cystic duct
applicator                                                clips used
Skin stapler Natl Med J India 2012;25:151–5, Hussain et al
               734         183             Nil           500                     Skin incision
                                                                                 approximation
                                                                                                          69
   Is it moral or ethical to treat a patient with a
    refurbished medical device of unknown and
    potentially lower (i)quality, (ii)performance or
    (iii)cleanliness than when it was used on the
    previous patient?
   Informed Consent from Patient…?
   Is the treating Physician fully aware……?

                                                       70
   ……But before medical devices can be reprocessed and reused, a third-
    party or hospital reprocessor must comply with the same requirements
    that apply to original equipment manufacturers, including:
   Submitting documents for premarket notification or approval
   Registering reprocessing firms and listing all products
   Submitting adverse event reports
   Tracking devices whose failure could have serious outcomes
   Correcting or removing from the market unsafe devices
   Meeting manufacturing and labeling requirements



    DEADLINES: Manufacturers of reprocessed single-use laparoscopic
    and endoscopic electrosurgical accessories who already have 510(k)
    clearance for these devices were required to submit supplemental
    validation data for the devices by June 29, 2006, or their devices were
    no longer legally marketed.


                                                                              71
Single-Use Medical Devices: Little
Available Evidence of Harm From Reuse,
but Oversight Warranted
(Letter Report, 06/20/2000, GAO/HEHS-
 00-123)




                                         72
   ……….while   the agency reviews all adverse event reports, it places
    the highest priority on reports involving pediatric deaths, multiple
    deaths or serious injuries from a single device, fires, burns, or
    highly unusual events such as radiation exposure, over- or
    underdosing of radiation, radiation being delivered to the wrong
    site, and severe allergic reactions (anaphylaxis)
   While FDA has made changes to its data collection process
    regarding reprocessed SUD-related adverse events, the data are
    not suitable for a rigorous comparison of the safety of
    reprocessed SUDs compared to similar original SUDs
   Rigorous Safety Comparisons Not Possible through Current or
    Planned Adverse Event Reporting
   Neither existing FDA data nor studies performed by others are
    sufficient to draw definitive conclusions about the safety of
    reprocessed SUDs compared to similar original devices.
   FDA Oversight Has Increased, and Available Information Does Not
    Indicate That Use Presents an Elevated Health Risk


                                                                           73
   Potential for cost saving
    - Health care establishment
    - Patients

   Dependable supply

   Reduction of waste

   Ecofriendly - pollution reduction, less
    incineration and less use of landfills and dump
    sites


                                                      74
   Who should be allowed to reprocess?

   Who will provide the guidelines, standards and
    protocols ?

   Who will cross check the quality of the
    reprocessing and regulatory oversight?

   Who will pay for failures?

   What if we do away with reprocessing- who
    would bear the cost?

                                                     75
   If a device cannot be cleaned, it cannot be re-
    processed and re-used
   If the sterility of a post-processed device cannot be
    demonstrated, the device cannot be re-processed
    and re-used
   If the integrity and functionality of a re-processed
    SUD cannot be demonstrated and documented as
    safe for patient care and or equal to the original
    device specifications, the device cannot be re-
    processed and re-used.
   If anything sterile is opened, it needs to be
    decontaminated before re-processing
   Validation and documentation of processes and
    outcomes is mandtory


                                                        76
SUDs would be reused – need to identify those that can
and those that shouldn’t



For the developed nations – reuse is a ‘green option’



For resource crunch settings - Reuse is not only cost
saving but also life-saving


Standards need to be laid down and implemented in
healthcare units/ May be a third party reprocessing unit
needs to step in



                                                           77
The debate would go on, but the
dictum remains….




                        STERILITY

                        INTEGRITY




                                    78
79

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Single Use Devices

  • 1. The presentation is solely meant for Academic purpose
  • 2.
  • 3. “The Guru is none other than the Creator, Lord Brahma; He verily is Lord Vishnu, the Preserver, and He truly is Maheshvara, the Destroyer. He is the supreme Brahman himself, To such a Guru I offer my Salutations” 3
  • 4. ‘ No stronger condemnation of any hospital or ward could be pronounced from the single fact that zynotic (infectious) disease have originated in it,or that such a disease has attacked other patients than those brought in with them’ - florence nightingale
  • 5. Some of the slides an the material are borrowed and I acknowledge Dr. Gita Nataraj from KEM, Mumbai and the HISI newsletter on SUDs reprocessing  The entire story is borrowed from experiences of others and self  I do not claim to be an expert and am as much a student eager to learn  I acknowledge the contributions of technical staff and nursing for implementation of the program and the entire Infection Control colleagues at Delhi Apollo, particularly Dr. Leena Mendiratta 5
  • 6. Original device: “The term ‘original device’ means a new, unused entire single-use device.”  Single-use device: “The term ‘single-use device’ means a device that is intended for one use, or on a single patient during a single procedure.”  Reprocessed: “The term ‘reprocessed’, with respect to a single-use device, means an original device that has previously been used on a patient and has been subjected to additional processing and manufacturing for the purpose of an additional single use on a patient.  Critical reprocessed single-use device  Semi-critical reprocessed single-use device 6
  • 7. 7
  • 8. 8
  • 9. 30% of all hospitals reuse one / more SUDs Not all SUDs can be reused / reprocessed 50% of hospitals reuse through a third party processor 9
  • 10. 10
  • 11. 2002;7(1):53- 59 Conclusions: •No significant overall difference in temperature sensing accuracy and deflection angle of new and used ablation catheters. •Nevertheless, individual differences in deflection characteristics between new and used catheters are occasionally seen and warrant screening of reprocessed catheters prior to their reuse 11
  • 12. CONCLUSIONS: Reuse of medical devices labelled "single use only" is common in Australian hospitals. Most devices appear to be unsuitable for reuse. Complete cessation of this practice of reusing single-use medical devices would stop potential cross-infection, but this would cost and estimated $2.5 million or more per case prevented 12
  • 13. •Tradition of re-use – reports on re-use of pacemakers are available from Europe, North America and Asia (India) with no reported adverse effects •During 1996, in Sweden, 5% of pacemakers were re-used devices, with no evidence that re-use has increased patient risk. •Re-use of pacemakers may be considered, provided that their sterility, mechanical and electrical integrity can be ensured and operating procedures are respected. Re-used pacemakers should only be given to patients whose life expectancy is estimated to be less than that of the pacemaker. 13
  • 14. A Randomized Study of the Safety and Efficacy of Reused Angioplasty Balloon Catheters M Zubaid, CS Thomas, H Salman, I Al-Rashdan, N Hayat, A Habashi, MT Abraham, K Varghese, L Thalib Department of Cardiology, Chest Diseases Hospital, Kuwait and Department of Community Medicine, Faculty of Medicine, Kuwait University Conclusions: When performing coronary angioplasty, reused catheters are as effective (similar angiographic success) and safe (similar clinical success) as new catheters. (Indian Heart J 2001; 53: 167–171) 14
  • 15. The issue really is not whether or not to reprocess, but what constitutes safe and appropriate reuse of disposable items. 15
  • 16. ……. requires that 510(k)s for listed reprocessed SUDs include “validation data, regarding cleaning and sterilization, and functional performance demonstrating that the [SUD] will remain substantially equivalent to a predicate device after the maximum number of times the device is reprocessed as intended by the person submitting the premarket notification.”  On April 30, 2003, FDA identified in the Federal Register those critical reprocessed SUDs whose exemption from 510(k) would be terminated.  On April 13, 2004, FDA identified those semi-critical reprocessed SUDs whose exemption would be terminated.  On September 29, 2005, FDA updated and consolidated the lists of the critical and semi-critical reprocessed SUDs that would no longer be 510(k) exempt 16
  • 17. 17
  • 18. …simply because they are not designed to be taken apart for adequate cleaning  …. or to perform as specified after first use.  In addition, many of the materials utilized in the various components of single use medical devices, both plastics, glues and metals, may not withstand the chemical environment of the solutions utilized  Also, the temperatures required for autoclave sterilization may deform many components and subsequently compromise their performance and safety December 15, 2009 Eucomed White Paper - The Reuse of Single Use Devices 18
  • 19. Canadian Medical Device Technology Companies (MEDEC): the authors refer to a 2001 review where several reprocessed single use devices were retrieved from hospitals in the United States and in Europe.  In total, 136 devices were obtained from hospitals on both continents and included clip appliers, clamps, staplers, cautery devices, tracers and electrophysiology (EP) catheters.  Examination revealed that at least half of these products had packaging defects, were contaminated with residual blood or tissue, and/or experienced functional failures. 19
  • 20. MEDEC - German report, 2001 (Andreas Beck) where 727 angiography catheters and guide wires were studied  The results showed numerous physical variations in devices including nicks, kinks, roughness, erosion, tears and changes in material properties.  The author concluded that the refurbishment of devices intended for single use by both healthcare facilities and third party reprocessors is inappropriate and a risk to patient safety 20
  • 21. SGNA believes that patients deserve the same standard of care regardless of practice setting.  The reuse of SUDs is a complex issue that must be balanced with the assurance of patient safety and the delivery of quality health care. These concerns cannot be overlooked when evaluating the legal, ethical, financial, and technical aspects of reusing SUDs.  In the absence of substantial scientific evidence to prove the safety and effectiveness of reprocessed critical medical devices in the endoscopy setting, SGNA maintains the position that critical medical devices originally manufactured and labeled for single use should not be reused.  Adopted by the SGNA Board of Directors, February 1998; Revised May 2002, October 2005, August 2008. 21
  • 22. The WHO has stated ‘the safest and most unambiguous method for ensuring that there is no risk of residual infectivity on surgical instruments is to discard and destroy them by incineration … this strategy should be universally applied to those devices and materials that are designed to be disposable.’ WHO Infection Control Guidelines for Transmissible Spongiform Encephalopathies, WHO/CDS/CSR/APH/2000.3. March 23-26, 1999 22
  • 23. The use of a reprocessed single use device provides no direct benefit to the individual patient or her physician  …Relies on voluntarily reported adverse events..  …Studies on the safety, quality and cost- effectiveness are needed….. 23
  • 24. A B A) PTCA balloon catheter refurbished by a third party and soiled with contrast medium and blood. B) A comparison of a PTCA balloon and a household match demonstrating the small size of the catheter and how difficult it would be to ensure effective cleaning of such a small device 24
  • 25. B A 25
  • 26. A C B A) Proteinaceous contamination on the inner surface of a guiding catheter. B) XPS Scan / Spectrum confirming that the reddish contamination is blood. C) Scanning electron micrograph (SEM) photograph to confirm the presence of a red blood cell 26
  • 27. Reddish brown contamination observed over the full length of the third party reprocessed endoscopic stapling device 27
  • 28. A B C A) Flaking marker on a reprocessed balloon catheter, which may result in release of particles into the patient’s bloodstream. B) Marker of a new balloon catheter. C) Aluminium contamination in the lumen of a balloon catheter. 28
  • 29. A B A) The coil of new, unused biopsy forceps. B) The coil of reprocessed biopsy forceps 29
  • 30. …..Another challenge when reusing catheters is that it is difficult to predict when a catheter will degrade to a degree that it will break….. When and if depends on the type of polymer used and how it is manufactured. While some plastics degrade over time and show signs of wear others seem to fail spontaneously Degradation-time curves demonstrating how different polymers degrade over time David L. West et al. “Scientific & Regulatory Consideration for the Review and Approval of Reprocessed Single Use Devices Pre - market Submissions 30
  • 31. Photograph showing kinks along a reprocessed single use catheter as a result of previous usage or reprocessing 31
  • 32. When attempting to flush the single use devices a distribution of the contamination rather than cleaning was achieved….. Demonstration of the distribution of contamination rather than removal as assessed using the radionuclide method of detection ….Most of the inspected devices showed residual contamination in the hinges and under the isolation coats .This was especially true for harmonic scalpels. These findings indicate that the cleaning agent penetrates into the device and dilutes the blood but cannot then be flushed out of the device. Therefore, contamination and disinfection solution remain in the devices …… 2001, Roth, Heeg, and Reichl 32
  • 33. A single-use bladder pressure transducer cover was not changed between patients, resulting in cross-infection due to Pseudomonas aeruginosa. One patient developed septicaemia and died of a sub-arachnoid haemorrhage  A lithotriptor stone retrieval basket, which was a single-use device, had been reprocessed and appeared to be satisfactory for use. During the procedure,the cable was tightened and snapped, resulting in the basket remaining in the patient. Further surgery was required to retrieve it. Single-use Medical Devices : Implications and Consequences of Reuse MHRA DB 2006(04) v2.0 December 2011 33
  • 34. 30% of all hospitals reuse one / more SUDs Not all SUDs can be reused / reprocessed 50% of hospitals reuse through a third party processor The cost is reduced by ½ to 1/10 34
  • 35. The main complication in performing true cost- benefit calculations in relation to refurbishment and reuse of single use devices is the challenge created by the increased patient risk involved.  How can a price be assigned to increased patient risk?  Some studies touch directly upon the problems associated with creating a true financial cost- benefit analysis, while others ignore this complication entirely and therefore reach questionable financial conclusions  This does not include the hidden costs related to the risks of using refurbished single use devices, such as HAI, complications, litigation, staff injuries etc. Single-use Medical Devices : Implications and Consequences of Reuse MHRA DB 2006(04) v2.0 December 2011 35
  • 36. Cost-effectiveness……? We are doing a study  Personnel costs: Cost of employing technical and qualified personnel for pre- cleaning immediately after the point of use, assembly, dismantling and replacement activities, maintenance and cleaning, repairs, wear and tear, sterilisation, sterilisation checks (chemical and biological), packaging, etc. In addition, personnel and/or costs for longer procedure time, re-operation and infections should be considered.  Investment costs: Costly apparatus (capital equipment), buildings (designated for storage/spare parts); centralised sterilisation unit and special apparatus (autoclaves, machines for washing the devices, ultrasonic baths, means of cleaning, chemical products, disinfectants, lubricants, etc).  Administrative costs: Systems used to communicate the results and establish traceability, managing reserves of spare parts/stock, distribution, transport, insurance premiums, documentation, validation procedures, auditing third party refurbishers, recording accidents and injuries involving members of staff, etc.  Utility costs: Cost of providing the utilities associated with the sterilisation process (electricity and water consumption [including drainage]).  Miscellaneous costs: Overheads, protective clothing (gloves, masks, safety glasses, double-thickness packaging materials), provision of safety training in connection with the re-utilisation of instruments, cost of treating post- operative infections and handling complaints 36
  • 37. Potential Risks Examples Potential for cross Any component of Microbial world esp Blood borne infection viruses Inability to clean and Features of a device that make cleaning difficult are: decontaminate acute angles, coils, long or narrow lumens, spécial surface coatings etc. Residues from chemical Disinfectants may be absorbed by plastics and leach out decontamination agents during use, resulting in chemical burns or a risk of sensitization of the patient or user. Material alteration Plastics may soften, crack or become brittle during exposure to elevated temperatures or pressure during the sterilization process or exposure to cleaning agents and chemical sterilants Mechanical failure Some devices may experience stress during each cycle of reuse, leading to fatigue-induced failure and fracturing e.g. single-use drill, burrs, saw blades, craniotomy blades catheters Reaction to endotoxins If the device has a heavy bacterial load after use, which cannot be adequately removed by cleaning MHRA DB 2006(04) v2.0 December 2011 Transmission of CJD, Prions 37
  • 38. 30% of all hospitals reuse one / more SUDs Not all SUDs can be reused / reprocessed 50% of hospitals reuse through a third party processor Clinical evidence does not indicate increased risk in controlled settings Reuse is not a harmless procedure – Document Integrity and Safety Continued surveillance for adverse events is required The procedure has to be regulated The cost is reduced by ½ to 1/10 38
  • 39. The FDA classifies single-use medical devices according to the level and type of control needed to ensure that the devices are safe and effective. - Class I devices need the fewest controls - Class II devices require "special controls." - Class III is the most stringent regulatory category and medical devices that fall under this category require a premarket approval  Class I and Class II devices are the best candidates for reprocessing, with some notable exceptions. Medical Device Reprocessing Don Selvey, 2011 39
  • 40. Reprocessable Class I devices include:  Orthopedic chisels  Surgical curettes  Surgical gouges  General use surgical scissors  Non-electric biopsy forceps  Orthopedic knives  Orthopedic saw blades  Chisels  Rasps Between 65 and 75% of all single-use medical devices are identified as Class II. Class II single-use devices include:  Non-ported trocars for endoscopic procedures  Sequential compression devices (compression sleeves)  Most laparoscopic instruments, including: scissors, clamps, dissecters and graspers  Recording and diagnostic EP catheters  Drills and burrs  Flexible snares Class III devices include:  Transluminal coronary angioplasty catheters  Percutaneous and conduction tissue ablation electrodes Medical Device Reprocessing  Implanted infusion pumps Don Selvey, 2011 40
  • 41. S.U.D Policy: Components  S.U.D. List (approval of End-Users and Management and ICC members)  Specialties using S.U.D.  Serial Number for each S.U.D  Number of re-uses specified for each S.U.D  Protocols on Re-processing of S.U.D.  Training of Personnel involved (Part of staff Appraisals)  Functional integrity check to each S.U.D.  Rejection Criteria of each S.U.D  Traceability  Monitoring of S.U.D  Recall Policy  Documentation  Validation by user / third party reprocessor  Monitoring of Policy 41
  • 42. Initial pre-cleaning on site  Cleaning and rinsing  Decontamination  Marking (number of re-uses)  Packaging  Labeling  Sterilization  Documentation 42
  • 43. For all devices (narrow lumen/balloon) it is necessary to test the functional integrity before drying.  The devices shall be inspected for any damage and its functional integrity verified by the user after the process of cleaning and decontamination  Assessment of the functional performance on a worst case basis, i.e., after the maximum number of times the device is intended to be reprocessed as specified.  Simulation of device in reprocessing cycle and this step should be specified in the summary of the process design and validation.  The performance tests should be summarized in the process design and validation documentation 43
  • 44. Incase the number of usages equals the number of usages as per Policy, approved for that particular article.  Any kinks, curves leading to loss of functional integrity  Blood clots not getting removed  Loss of Lumen patency  Incase signals are not being received  Any leaks  Incase smooth functioning is absent  Incase inflation is not taking place  Incase of breakage  Incase tip is blunted  Incase tip is broken  Incase sharp edge is blunted 44
  • 45. Ensure drying by either passing dry compressed air through it or drying in controlled environment (biosafety) for devices which are delicate or not able to withstand air pressure 45
  • 46. Marking Should be ensured that marking does not compromise on the integrity of the device 46
  • 47.
  • 48. Excess air must be removed from packets before sealing  Appropriate packaging shall be carried out to ensure effective sterilisation.  The packaging shall be compatible to the type of sterilization being carried out.  The items shall be wrapped in medical grade packaging. 48
  • 49. Appropriate labeling of every packed item is done.  The Label should include the following: - Name - Size - Manufacturer - Unique Device No - Usage no - Date of Last Usage - Date of reprocessing  The Unique Device No includes the following essentially in the given sequence: Manufacturer / Serial Number of that particular item- as specified in the approved SUD List / Year of present usage/ Month of present usage/ no of times that particular type of item has been opened on that particular day, (eg Ox / 21 / 2008 / 02/ 01)  These items are then sent for further appropriate sterilization. 49
  • 51. The device should be sterilised by an appropriate sterilisation method for that device e.g. ethylene oxide gas sterilisation method  The process of sterilisation should be strictly controlled and as per the manufacturer’s instructions.  The cycle shall be monitored with physical, chemical and biological indicators.  The device shall not be released till 72 hours post- Ethylene oxide sterilization  PCD to be used as simulators 51
  • 52. Labeling Gun:  Sterilizer number,  Load number,  Batch number,  Date of sterilization  Date of expiry
  • 54. Keeping the track record of that article through appropriate documentation 54
  • 55. SINGLE-USE DEVICE REPROCESSING GUIDE TEMPLATE The following single-use devices have been approved for reprocessing by the Medical Executive Committee. No other single-use device may be reprocessed unless written authorization is obtained from the Medical Executive Committee. Effective Date: Device Status Approved Third-Party Clinical Category Device Manufacturer Model(s) Open & Reprocessor Used Expired Unused Ambulatory Surgery Center Quality Programme 55
  • 56. 56
  • 57. 57
  • 58. Any adverse event related to the device should be reported in an incident- form 58
  • 59. “There is no conclusive evidence to substantiate the notion that either morbidity or mortality associated with single use or reuse is different.” National Kidney Foundation Report on Dialyzer Reuse, AJKD 1997
  • 60. Assuming a dialyzer price of $20, costs of Reuse Cost Reduction Curve reprocessing of $5, and 15 uses, the cost savings for one patient are $2,050 every year with reuse Cost of Single Use vs. Multiple Use $25 $25 (Cost per Patient per Year) $20 $20 $5,000 Cost per treatment $15 $15 $4,000 $10 $10 $3,000 Cost Costs for 50 Patients per Year $5 $5 (6 Reuses vs. 15 Reuses) $2,000 $0 $0 $70,000 1 4 7 10 13 16 19 $1,000 $60,000 Cost per year $50,000 $0 Single Use Multiple Use $40,000 $30,000 Dialyzer Cost Reprocessing Cost $20,000 $10,000 $0 6 Reuses 15 Reuses Reprocessing Cost Dialyzer Cost Automated Dialyzer Reprocessing , Minntech 1999 60
  • 61. Daily Checklist For Dialyzer Re-processing System Serial no:____________ 01.01.20 Parameters 02.01.2011 03.01.11 04.01.11 05.01.11 06.01.11 07.01.11 11 Calibration Verification Volume in ml ( 70[+/-]3 ml ) Pressure Log: Static Pressure (Ideally: 20 psi to 55 psi) Dynamic Pressure (Ideally: 35 psi to 40 psi) Exterior Cleaning with 1% Renalin Caps: 30 minutes disinfection with 1% Renalin Sanitization VERIFICATION 61
  • 62. If required, a S.U.D. maybe recalled, if decided so by the Infection Control Committee, incase of repetitive incidents if any, or if any such notification from the Manufacturer 62
  • 63. Appropriate Personal Protective Equipment (gown, gloves, eye- protection, etc) to be worn while cleaning and decontamination  Care should be taken in the direct handling of intricate or sharp- edged devices to avoid injury to the handler or damage to the device.  For devices with lumen special care should be taken while injecting the cleaning solution into the lumen so as not to cause damage 63
  • 64. Cleaning, sterilization, and functional performance validation of reprocessed SUDs include aspects of both: (i) design validation (ii) and process validation.  Design validation, in this case, should incorporate both the design of the product and the design of the processes to be used in reprocessing the device. 64
  • 65. ‘Rapid’ monitor that uses bioluminescence to measure the levels of ATP on a surface. It works through collection and quantification of ATP remaining in organic residues post-cleaning Capable of detecting 2mg protein / m2 ATP Results of less than 10 RLU are preferred Green Color-Satisfactory
  • 66. VALIDATING SINGLE USE DEVICES •Understanding it’s configuration and application (List of the parts, mantling and dismantling, manufacturers specifications) •Point of use care (Immediate aspiration, flushing) •Safe transport to re-processing department • Standard operating protocols of reprocessing department •Number of turns, tracking, recall procedure • Back to user •Discard after the last use
  • 67. Steps Validation Responsibility Integrity & functionality through Visual inspection Device User Post use pre-cleaning through visual inspection Device User Safe & covered transport Supervision (Assisting personnel) Disinfection & thorough Microbiological testing Reprocessing Dept. Cleaning & microbiology dept. Inspection, Assembling, Sterility check CSSD Packing, sterilization (No toxic residues left) Pyrogen free Next turn usability Check by user User department Usable life / No. of turns Sterility Assurance & User / reprocessing Adequate working of Microbiology the device, QA dept. headed by I.C.Chief
  • 68. 68
  • 69. Instrument Single-use Cost per Additional Saving per patient Procedure where device device patient when cartridge in multiple use (Rs) used (Rs) (MRP) (Rs) used multiple Cost (Rs) times Harmonic 40,000- 7,000- Nil 30,000 Advanced and Shear 50,000 10,000 routine Laproscopic approx surgery Diagnostic 1000 250 Nil 750 Interventional guidewire Cardiology and radiology imaging Angioplasty 10,000 – 4,000-5,000 Nil 5,000-6,000 Interventional Balloon 12,000 approx approx Cardiology and Catheter radiology imaging Open 21,000 – 4,000-5,000 4,000- 12,000-18,000 Open major surgery 28,000 approx 6,000 abdominal surgery linear cutter approx Endoscopic 22,000 – 5,000 approx 6,000- 11,000-18,000 Advanced Linear cutter 36,000 8,000 Laproscopic approx Gastrointestinal Surgery Mutiload 19,700 2,000 per Nil 8000 if an Clipping of blood clip clip applied average of 6 vessels, cystic duct applicator clips used Skin stapler Natl Med J India 2012;25:151–5, Hussain et al 734 183 Nil 500 Skin incision approximation 69
  • 70. Is it moral or ethical to treat a patient with a refurbished medical device of unknown and potentially lower (i)quality, (ii)performance or (iii)cleanliness than when it was used on the previous patient?  Informed Consent from Patient…?  Is the treating Physician fully aware……? 70
  • 71. ……But before medical devices can be reprocessed and reused, a third- party or hospital reprocessor must comply with the same requirements that apply to original equipment manufacturers, including:  Submitting documents for premarket notification or approval  Registering reprocessing firms and listing all products  Submitting adverse event reports  Tracking devices whose failure could have serious outcomes  Correcting or removing from the market unsafe devices  Meeting manufacturing and labeling requirements DEADLINES: Manufacturers of reprocessed single-use laparoscopic and endoscopic electrosurgical accessories who already have 510(k) clearance for these devices were required to submit supplemental validation data for the devices by June 29, 2006, or their devices were no longer legally marketed. 71
  • 72. Single-Use Medical Devices: Little Available Evidence of Harm From Reuse, but Oversight Warranted (Letter Report, 06/20/2000, GAO/HEHS- 00-123) 72
  • 73. ……….while the agency reviews all adverse event reports, it places the highest priority on reports involving pediatric deaths, multiple deaths or serious injuries from a single device, fires, burns, or highly unusual events such as radiation exposure, over- or underdosing of radiation, radiation being delivered to the wrong site, and severe allergic reactions (anaphylaxis)  While FDA has made changes to its data collection process regarding reprocessed SUD-related adverse events, the data are not suitable for a rigorous comparison of the safety of reprocessed SUDs compared to similar original SUDs  Rigorous Safety Comparisons Not Possible through Current or Planned Adverse Event Reporting  Neither existing FDA data nor studies performed by others are sufficient to draw definitive conclusions about the safety of reprocessed SUDs compared to similar original devices.  FDA Oversight Has Increased, and Available Information Does Not Indicate That Use Presents an Elevated Health Risk 73
  • 74. Potential for cost saving - Health care establishment - Patients  Dependable supply  Reduction of waste  Ecofriendly - pollution reduction, less incineration and less use of landfills and dump sites 74
  • 75. Who should be allowed to reprocess?  Who will provide the guidelines, standards and protocols ?  Who will cross check the quality of the reprocessing and regulatory oversight?  Who will pay for failures?  What if we do away with reprocessing- who would bear the cost? 75
  • 76. If a device cannot be cleaned, it cannot be re- processed and re-used  If the sterility of a post-processed device cannot be demonstrated, the device cannot be re-processed and re-used  If the integrity and functionality of a re-processed SUD cannot be demonstrated and documented as safe for patient care and or equal to the original device specifications, the device cannot be re- processed and re-used.  If anything sterile is opened, it needs to be decontaminated before re-processing  Validation and documentation of processes and outcomes is mandtory 76
  • 77. SUDs would be reused – need to identify those that can and those that shouldn’t For the developed nations – reuse is a ‘green option’ For resource crunch settings - Reuse is not only cost saving but also life-saving Standards need to be laid down and implemented in healthcare units/ May be a third party reprocessing unit needs to step in 77
  • 78. The debate would go on, but the dictum remains…. STERILITY INTEGRITY 78
  • 79. 79