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1
Date, 2015
Safe and Effective Use ofEthylene Oxide Sterilization
2 days of presentations (May 14th & 15th ) with advisory panel questions
Key Invited SpeakersWilliam A Rutala PhD, M.P.H University of North Carolina, School of Medicine, Chapel Hill NCAndrew Ross M.D. Virginia Mason Medical Center Seattle WAZachary A. Rubin M.D. UCLA Clinical Epidemiology & Infection Presentation Los Angeles CA
Reference presentations and Webcasthttp://www.fda.gov/AdvisoryCommittees/CommitteesMeetingMaterials/MedicalDevices/MedicalDevicesAdvisoryCommittee/Gastroenterology-UrologyDevicesPanel/ucm445590.htm
CRE Outbreak - FDA Gastroenterology and Urology Devices Advisory Panel
Date Issued: August 4, 2015“Combined with strict adherence to the duodenoscope manufacturer’s reprocessing instructions, the following supplemental measures may further help reduce the risk of infection transmission associated with the use of duodenoscopes.”
“When possible and practical, duodenoscopes should be sterilized due to the greater margin of safety provided by sterilization.”
Supplemental Measures for Facilities and Staff that Reprocess Duodenoscopes to Consider:
Microbiological Culturing
Ethylene Oxide Sterilization
Use of a Liquid Chemical Sterilant Processing System
Supplemental Measures to Enhance Duodenoscope Reprocessing: FDA Safety Communication August 4th 2015
Ethylene oxide (EtO) sterilization following cleaning and high-level disinfection…
“It is critical that devices are meticulously cleaned and disinfected prior to EtO sterilization. Gas sterilization with ethylene oxide may fail in the presence of viable microorganisms after inadequate cleaning and disinfection.”
All methods of sterilization and high level disinfection would be challenged by microorganisms embedded in clinical soil that is lodged inside an endoscope channel. Meticulous cleaning is always important.
Supplemental Measures to Enhance Duodenoscope Reprocessing: FDA Safety Communication August 4th 2015
Ethylene oxide (EtO) sterilization following cleaning and high-level disinfection…“Implementing EtO gas sterilization is costly and the process may not be readily available in or accessible to all health care facilities.”
Over 600 U.S. health care facilities have ethylene oxide sterilization capability, total number of ethylene oxide sterilizers in the U.S. is greater than 1000 sterilizers.
The two newest EO sterilizers on the U.S. market received FDA 510(k) clearance this year in January 2015.
Supplemental Measures to Enhance Duodenoscope Reprocessing: FDA Safety Communication August 4th 2015
Ethylene oxide (EtO) sterilization following cleaning and high-level disinfection…
“EtO may affect the material and mechanical properties of the duodenoscope.”
No published references to support this statement. 3M has customers that have successfully used ethylene oxide sterilization for their endoscopes for many years.
It is possible that this presumption is based on confusing ethylene oxide with hydrogen peroxide which has known (published) material compatibility limitations.
Supplemental Measures to Enhance Duodenoscope Reprocessing: FDA Safety Communication August 4th 2015
Ethylene oxide (EtO) sterilization following cleaning and high-level disinfection…
“EtO may be toxic to reprocessing personnel, and to patients if residual EtO remains on the device after sterilization.”
EO has been safely used in health care for over 50 years. If in doubt, monitor your employees and procedures directly to demonstrate safety !
EO is safe when used per medical device manufacturer's (MDM) instructions for use (IFU) and sterilizer manufacturer’s operators manual cleared by the FDA.
Medical device manufacturer's (MDM) validates the device is safe for patient use; FDA reviews MDM’s device safety testing before clearance to market in U.S.
Supplemental Measures to Enhance Duodenoscope Reprocessing: FDA Safety Communication August 4th 2015
Ethylene oxide (EtO) sterilization following cleaning and high-level disinfection…
“Users should follow duodenoscope manufacturer reprocessing instructions pertaining to EtO concentration, sterilization temperature, exposure time, and relative humidity.”
These are the four critical parameters for EO sterilization.
Association for the Advancement of Medical Instrumentation. EO sterilization in health care facilities: Safety and effectiveness. ANSI/AAMI ST41:2008(R) 2012, Arlington, VA. www.aami.org
Association of periOperative Registered Nurses (AORN) Recommended Practices section on EO processing.
Pouches on edge, if possible; transparent side facing opaque side
Reference packaging manufacturer’s instruction for use (IFU)
Use good loading practices
“Full Load definition – means the maximum number of items that does not impede proper air removal, humidification of the load, or sterilant penetration and evacuation in the sterilization unit.”
EPA Reregistration Eligibility Decision (RED) for Ethylene Oxide
RED: “…determined that the benefits of continued use outweigh the associated occupational risks, provided that risk mitigation measures specified by the Agency are adopted and reflected on product labeling.”
EPA RED hospitals, required risk mitigation, effective Feb 28, 2010
• Use of a single chamber process, i.e., sterilization and aeration occur in the same chamber
Always follow the Sterilizer Manufacturers Operator’s Manual
Inspect display screen and cycle reports for error codes and listen for audible notifications (if enabled); always take action for error codes as indicated in Operators Manual
Always review the elapsed aeration time on the sterilizer display prior to opening the sterilizer door
Always inspect cycle reports (printout or electronic) to ensure the total aeration time matches the device manufacturer’s instructions for use (IFU)
• Commercially available, FDA-cleared preassembled test pack
ST41 describes two types of PCDs
• Routine BI test pack
• Challenge BI test pack
“A PCD is a device used to assess the effective performance of a sterilization process by providing a challenge to the process that is equal or greater than the challenge posed by the most difficult item routinely processed.”
AAMI ST41:2008/(R)2012 Process Challenge Device (PCD) (10.5.4)
Reprinted from ANSI/AAMI ST41:2008 with permission of the Association for the Advancement of Medical Instrumentation, Inc. (C) 2008(R)2012 AAMI www.aami.org. All rights reserved.
Challenge BI Test PackRoutine BI Test Packs
Performance Monitoring and Routine Load Release
AAMI ST41:2008/(R)2012 Process Challenge Device (PCD) (10.5.4)
Sterilizer qualification testing after installation, relocation, or after a major redesign.
1 Routine load release Testing of each non-implant and implant load
2Routine sterilizationefficacy monitoring
Each sterilization cycle should have a routine BI test pack or a commercially available BI PCD
3Sterilizer testing after sterilization process failures
Testing of the sterilizer after any monitoring device suggests that the process was inadequate. Testing consists of monitoring one cycle with routine BI test pack or commercial equivalent.
4Sterilizer qualification testing after malfunctions, major repairs
Malfunctions identified after sterilization process failures must be corrected. Major repair: repair outside the scope of normal maintenance. Qualification consists of three consecutive cycles with routine BI test packor commercial equivalent.
5Sterilizer qualification testing after installation, relocation
Testing of the sterilizer after installation or relocation using one or more challenge BI test pack(s). Three consecutive cycles using simulated loads.
6Sterilizer qualification testing after major redesign
Three consecutive half-cycles w/ challenge BI test pack(s) in simulated load.
Three consecutive full cycles w/ challenge BI test pack(s) in an otherwise empty chamber.
7 Periodic product testingTesting of routinely processed items to ensure the effectiveness of the sterilization process.
OSHA Occupational Exposure Standard for EO Exposure Limits
Employer required to monitor employee exposure WHAT?• Monitor for 8-hour TWA• 15-minute sampling periodHOW?• Breathing zone air samplesWHO?• Representative employee on each shift
for each job classificationIf EO exposure 0.5 ppm AL, 8-hr TWA• Monitoring of those employees can be discontinued
• Association for the Advancement of Medical Instrumentation. Ethylene oxide sterilization in health care facilities: Safety and effectiveness. ANSI/AAMI ST41:2008/(R)2012
• Association for the Advancement of Medical Instrumentation. Automatic, general-purpose ethylene oxide sterilizers and ethylene oxide sterilant sources intended for use in health care facilities ANSI/AAMI ST24:1999/(R)2013
• Association of periOperative Registered Nurses (AORN). Recommended Practices for Sterilization in periOperative Practice Setting, 2015
• Centers for Disease Control and Prevention. Guideline for Disinfection and Sterilization in Healthcare Facilities, 2008
• Federal Register / Vol. 72, No. 248 / Friday, December 28, 2007 / Rules and Regulations. Environmental Protection Agency. 40 CFR Part 63: National Emission Standards for Hospital Ethylene Oxide Sterilizers.http://www.epa.gov/fedrgstr/EPA-AIR/2007/December/Day-28/a25233.pdf
• Occupational Safety and Health Administration. Occupational Exposure Standard for Ethylene Oxide (29 CFR 1910.1047)
• US Environmental Protection Agency Office of Pesticide Programs, Reregistration Eligibility Decision for Ethylene Oxide, March 31, 2008http://www.epa.gov/oppfead1/cb/csb_page/updates/2008/ethylene-oxide.htm andhttp://www.epa.gov/pesticides/reregistration/REDs/ethylene-oxide-red.pdf