Federal health advisory recommends review of infection control practices
NOEL BRANDON KELSCH
A headline in the news about infection control in dental offices seems to be happening much more frequently-a veterans' clinic in Colorado, a volunteer event in Virginia, a dental surgeon's office in Oklahoma, a general dentist in Pennsylvania, etc. The list continues to grow.
We need to stop and take a look at what we're doing. Are we part of the problem, a headline waiting to happen?
Many of these issues are simple things to fix. These easy remedies can make a big impact on our patients. Lapses in basic cleaning, disinfection, and sterilization of medical devices, and failure to follow manufacturers' reprocessing instructions for critical and semicritical items all have an impact on outcomes. No one wants to be the one who is known for doing harm.
Critical items (surgical instruments, for example) are objects used to enter sterile tissue or the vascular system and must be cleaned and sterilized prior to reuse.
Semicritical items are objects that contact mucous membranes or nonintact skin and require, at a minimum, cleaning and high-level disinfection prior to reuse.2
Federal Advisory
The Centers for Disease Control and Prevention (CDC) and the Food and Drug Administration (FDA) wants us all to stop what we are doing and make sure we are doing it right. An official CDC health advisory was issued on Sept. 11, 2015. If you are doing what is right, you will not have to change a thing. If you have lapses, this is a great time to take inventory of your practices and make sure you are in compliance.
All offices must make sure they are properly maintaining clean and disinfected or sterilized reusable medical devices. Recent infection control lapses due to noncompliance with recommended reprocessing procedures highlight a critical gap in patient safety. Health-care facilities that utilize reusable medical devices are urged to immediately review current reprocessing practices at their facility to ensure they are complying with all steps as directed by the device's manufacturers, and have in place appropriate policies and procedures that are consistent with current standards and guidelines.1
The recommendations that focus on dentistry include an assessment to ensure that reprocessing is done correctly, including allowing enough time for reprocessing personnel to follow all steps recommended by the device manufacturer.1
The advisory from the CDC Health Alert Network first focused on training and self-auditing. A key reminder to the training section was to make sure "copies of manufacturers' instructions for operating and reprocessing each type of reusable device should be readily available to staff and inspectors. This file should include instructions for use of chemical disinfectants.
The self-auditing section reminded health-care professionals to monitor sterilizer performance among other steps.
The third section of the CDC Health Alert Network advisory was titled, "Infection control policies and procedures." I quote directly from the advisory below, adding some tips to consider.
• Healthcare facilities should allow adequate time for reprocessing to ensure adherence to all steps recommended by the device manufacturer, including drying, proper storage, and transport of reprocessed devices.
Tip from Noel: If you do not have enough time for your instruments to fully complete a cycle, then it is probably time to buy a second sterilizer. Drying is part of the cycle.
• Considerations should be made regarding scheduling of procedures and supply of devices to ensure adequate time is allotted for reprocessing.
Tip from Noel: If you are unable to buy more equipment or tools, it is vital to coordinate with the person booking appointments. Things like implant tools and specialty devices for endodontics require time to be processed between patient.
• Health-care facilities should have protocols to ensure that health-care personnel can readily identify devices that have been properly reprocessed and are ready for patient use (tagging system, storage in a designated area).
Tip from Noel: This is especially important with things that are not going through the sterilizer, such as the curing light.
• Health-care facilities should have policies and procedures outlining facility response in the event of a recognized reprocessing error or failure. Health-care personnel should assess the cause of the error or failure and the exposure event in order to determine the potential risk of infection. The procedure should include how patients who might have been exposed to an improperly reprocessed medical device would be identified, notified, and followed.
Tip from Noel: Your state dental board or local health department can aid you in this process.
• Individuals responsible for infection prevention and reprocessing at the health-care facility should be consulted whenever new devices will be purchased or introduced to ensure that infection control considerations are included in the purchasing decision as well as subsequent implementation of appropriate reprocessing policies and procedures and to ensure that the recommended reprocessing equipment is available at the health-care facility.
Tip from Noel: In choosing devices, make sure you are in compliance with all requirements surrounding the device and that you can feasibly do the procedures required of it in a timely manner between patients.
• Health-care facilities should maintain documentation of reprocessing activities, including maintenance records for reprocessing equipment (e.g., autoclaves, ultrasonic bath, medical washers and washer-disinfectors, water treatment systems), sterilization records (physical, chemical, and biological indicator results), and records verifying high-level disinfectants were tested and replaced appropriately.
Tip from Noel: Many manufacturers have forms for this in their instructions.
• Health-care facilities should follow manufacturer recommendations for maintenance and repair of medical devices that are used to perform reprocessing functions as well as medical devices that are reprocessed. If health-care facilities contract maintenance and repair of these devices to third-party vendors, health-care facilities should verify that these vendors are approved or certified by the manufacturer to provide those services.
Tip from Noel: On your calendar, add reminders for checking gaskets, cleaning machines, etc.
Dental health-care professionals have a responsibility to do no harm. This CDC alert and our compliance can keep us off the front page of the news and our patients safe. RDH
Resources
The FDA and CDC provides relevant guidance and training, including:
• CDC's Guideline for Disinfection and Sterilization in Healthcare Facilities, 2008 available at http://www. cdc.gov/hicpac/pdf/guidelines/Disinfection_Nov_2008.pdf
• Association for the Advancement of Medical Instrumentation (AAMI), available at http://www.aami.org/standards/index.aspx
• Problems with medical device reprocessing should be reported to the FDA's MedWatch Adverse Event Reporting program online at https://www.accessdata.fda.gov/scripts/medwatch/
References
1. http://emergency.cdc.gov/han/han00382.asp
2. http://www.cdc.gov/hicpac/pdf/guidelines/Disinfection_Nov_2008.pdf
NOEL BRANDON KELSCH, RDHAP, is a syndicated columnist, writer, speaker, and cartoonist. She serves on the editorial review committee for the Organization for Safety, Asepsis and Prevention newsletter and has received many national awards. Kelsch owns her dental hygiene practice that focuses on access to care for all and helps facilitate the Simi Valley Free Dental Clinic. She has devoted much of her 35 years in dentistry to educating people about the devastating effects of methamphetamines and drug use. She is a past president of the California Dental Hygienists' Association.
