1 17 November 2016. All Rights Reserved.© 3M
3M Business Name
Risk Analysis Workshop
October 26, 2016
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Disclosure Statement
Steve Zeplin, RN, MSN, CSPDT
Monitoring Technical Consultant
Midwest and North Central Region
CE Program Sponsored by 3M
3 17 November 2016. All Rights Reserved.© 3M
Learning Objectives
Discuss the purpose of performing a risk analysis
Discuss the organizations that recommend or require a risk analysis
Identify risks for sterilization process failures
Develop a risk analysis
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Quality Process Improvement
ANSI/AAMI ST79:2010 &
A1:2010 & A2:2011 & A3:2012 &
A4:2013 (Consolidated Text)
Section 11
Quality process improvement
11.2.2 Risk analysis
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The Joint Commission (TJC)
The Joint Commission: 2015 Hospital Accreditation Standards (HAS)
“The hospital’s written infection prevention
and control goals include the following:
Limiting the transmission of infections
associated with the use of medical
equipment, devices and supplies.”
“Based on the identified risks, the hospital
sets goals to minimize the possibility of
transmitting infections.”
Standard IC.01.04.01
Element of Performance 4
Require hospitals to conduct a risk assessment
6 17 November 2016. All Rights Reserved.© 3M
The Joint Commission National Patient Safety Goals
The Joint Commission: 2015 Hospital Accreditation Standards (HAS)
“The hospital reviews and identifies its
risks at least annually and
whenever significant changes occur
with input from, at a minimum, infection
control personnel, medical staff, nursing,
and leadership.”“The hospital identifies risks for acquiring
and transmitting infections.”
Standard IC.01.03.01
Element of Performance 4
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The Joint Commission (TJC)
The Joint Commission: 2015 Hospital Accreditation Standards (HAS)
“At least every 18 months, the hospital
selects one high-risk process and conducts
a proactive risk assessment.”
“The hospital has an organization-wide,
integrated patient safety program within its
performance improvement activities.”
Standard LD.04.04.05 Element of Performance 10
Example high-risk: releasing an implant before BI results are available
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The Joint Commission National Patient Safety Goals
The Joint Commission: 2015 Hospital Accreditation Standards (HAS)
“As part of the effort to reduce surgical site
infections:
― Conduct periodic risk assessments for
surgical site infections in a time frame
determined by the hospital.”
“Implement evidence-based practices for
preventing surgical site infections.”
NPSG.07.05.01
Element of Performance 4Example: conduct risk assessment 6 months after
implementing an action plan
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Centers for Disease and Control and Prevention (CDC) Guideline
http://www.cdc.gov/hicpac/pdf/guidelines/SSI_1999.pdf, p. 261
“Inadequate sterilization of surgical instruments has resulted
in SSI outbreaks…. The importance of routinely monitoring the
quality of sterilization procedures has been established. Microbial
monitoring of steam autoclave performance is necessary and can
be accomplished by use of a biological indicator.”
Guideline for the Prevention of Surgical Site Infections, 1999Example: John Harrison, 63 y/o
2009- Repair right rotator cuff
Routine procedure
Dirty Arthroscopic shavers
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Sterilization Process Failure Risk Analysis
Be proactive
• Do a risk analysis each year and
whenever major changes are made
• Do not wait for a sterilization process
failure to do this analysis
• Stay up to date on manufacturers’
Instructions for Use
• Stay up to date on evidence-based and
professional organization guidelines
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Quality Improvement
Objective is to identify the
risks to reduce the likelihood
of a sterilization process
failure and HAIs
ANSI/AAMI ST79:2010 & A1:2010 & A2:2011 & A3:2012 & A4:2013 Section 11.2.2
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Risk Analysis
Risk analysis is part of a quality
process because sterilization is a
process that you cannot determine
its effectiveness by inspection and
testing of each product
ANSI/AAMI ST79:2010 & A1:2010 & A2:2011 & A3:2012 & A4:2013 Section 11.2.2
The following are used to
determine the effectiveness
of the sterilization process:
• Validated processes (validated
by equipment and medical
device manufacturers)
• Routine monitoring with physical
monitors, BI and CIs
• Equipment maintenance
Control the variables you can to
verify the effectiveness of
sterilization
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Risk Analysis
Risk assessment (1st step)
Since sterility assurance is a probability function,
it must be assumed that at some time a failure
will occur
• Identify source of sterilization failure
• Estimate likelihood that such a failure will occur
• Assess the consequences if that failure does occur
• Assess how to prepare the facility to manage
the failure
ANSI/AAMI ST79:2010 & A1:2010 & A2:2011 & A3:2012 & A4:2013 Section 11.2.2
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Figure 12 – Decision tree for conducting investigations of steam sterilization process failures
Reprinted from ANSI/AAMI ST79:2010 with permission of Association for the Advancement of Medical Instrumentation, Inc.
© 2010 AAMI www.aami.org. All rights reserved. Further reproduction or distribution prohibited.
CI Failures BI Failures Physical Monitoring Failures
Review scope/extent of failure
If cause of failure is immediatedly identified (usually operator error) and confined to one load or one item within the load (internal CI), correct the cause and reprocess the load. If cause of the failure
is not immediately identified, quarantine the load and recall all loads back to the last negative BI.
Determine cause of failure
Minor repair
Determine cause ofsterilizer/utilities malfunction
Failure can be attributed to cause other than sterilizer/utilities malfunction
Failure cannot be attributed to cause other than sterilizer/utilities malfunction
Repair sterilizer/utilities
Test results fail
Minor repair
Run 3 consecutive BI PCD tests (all sterilizers). For dynamic air removal sterilizers, also run
3 consecutive Bowie-DIck tests.
Test results pass
Return sterilizer to service
Major repair
Correct error
Quarantine load, remove sterilizer from service, and investigate cause of failure
Sterilizer/utilities malfunction (10.6.4. 10.8)
Positive BI(10.6.4)
CI failure(10.5.2.2)
Operator error Unknown
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Table 8 – Checklist for identifying reasons for steam sterilization process failures
Operator errors (85%)
Sterilizer (10%) or Utility Malfunctions (5%)
ANSI/AAMI ST79:2010 & A1:2010 & A2:2011 & A3:2012 & A4:2013 Section 10.7.5, Table 8
Personal Communication, Charles Hancock, President, Charles O. Hancock Associates, Inc.
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Risk Analysis
Risk management (2nd step)
• Determine which of the sterilization process
failures identified require management
because they are the biggest risk
• Select and implement the plans or actions
needed to ensure those failures are controlled
• AAMI ST79 describes the accepted means of
managing these risks throughout the
document
ANSI/AAMI ST79:2010 & A1:2010 & A2:2011 & A3:2012 & A3:2014 Section 11.2.2
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Risk Analysis
Risk communication (Final step)
• SPD/CSSD informs OR and ICP
of the risk analysis and the plan
of action
• Interactive Dialogue
ANSI/AAMI ST79:2010 & A1:2010 & A2:2011 & A3:2012 & A4:2013 Section 11.2.2
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Risk Analysis of the Sterilization Process
Team consists of SPD/CSSD personnel
who are working in the department and
should be able to:
• Identify risks
• Outline reasons for the risks
• Determine which risk is the biggest threat
• Suggest ways to reduce the risks
• Be knowledgeable of recommended
“Best Practices”
Risky business: Risk analysis in CSSD. HPN Aug 2010
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Risk Analysis of the Sterilization Process
Team capability will depend on:
• Whether the department policies
and procedures meet evidence-
based and professional
organization guidelines
• Whether the manufacturer’s
IFUs are up to date
• Training and competencies
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Risk Analysis of the Sterilization Process (Team Breakouts)
Team will:
• Identify risks (based on your experience) that
could lead to potential sterilization process
failures
• Categorize them (i.e., cleaning /
decontamination, sterilization,
quality monitors, packaging)
Risky business: Risk analysis in CSSD. HPN August 2010
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Risk Analysis of the Sterilization Process
List risks and determine the highest risks to resolve:
• Undetected debris in lumens (C/D)
• Receiving loaners the day of surgery (QM/CQI)
• Not enough eye sets for the day’s surgery (S)
• Instrument sets over 25 pounds (P)
• IFUs not always available (C/D or S)
• Early release of implants (S)
• Delay in processing flexible endoscopes (C/D)
• L&D sets sent to SPD/CSSD with dried-on debris (C/D)
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Risk Analysis – Sterilization Process Failures
RiskProbability of
Occurrence
Potential Severity or
Risk of Failure
Likelihood of
Undetected
Failure
Risk Score
Undetected debris in
lumens
Holes in wrappers
Delay in processing
flexible endoscopes
Late loaners
5
2
2
2
5
4
5
4
5
2
5
4
15
8
12
10
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Risk Management
Identify Failures
• After identifying potential
sterilization process failures,
investigate solutions by
consulting standards and
recommended practices for
guidance, including:
― AAMI
― AORN
― CDC
― EPA
― OSHA
― The Joint Commission
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Risk Management of the Sterilization Process
Team develops ideas or suggestions to
eliminate the risks (risk management)
• Select the highest scored risk
• Brainstorm solutions
• Final task is to correct the
problem and report the action
(risk communication)
Risky business: Risk analysis in CSSD. HPN August 2010
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Risk Management
Suggested Solutions Ballot Action to be taken
Have all brush sizes available 30 • Review IFUs to determine correct brush size
• Purchase brushes
• Organize brushes for quick and easy identification
Install spray gun with lumen adaptors 30 • Research available types and ask for input
from facilities to assure it will be workable
Implement a method to check lumens
for debris
30 • Research types of lumen checks available
• Train staff in use
• Include lumen check in policy
Include lumen cleaning in training
program
28 • Revise training program to include in-depth
lumen training
Process Improvement Highest Rated Risk Identified: Undetected Debris in Lumens
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Risk Communication
The findings of the risk analysis are
then communicated to everyone that
has an interest in the risk. Typically,
these include:
• Infection Prevention
• OR
• SP/CSSD staff
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Summary
A risk analysis should occur annually or whenever major changes occur or more frequently if determined necessary
A risk analysis consists of a risk assessment, risk management, and risk communication
Decision making and corrective action should be based on the standards and recommended practices from AAMI, AORN, and CDC
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Summary
The SP/CSSD staff is involved in a risk analysis, since they are close to the issues and are able to identify potential sterilization process failures and corrective action
Communication is critical, so that all stakeholders are aware of the issues and changes
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Eliminating Risks of a Sterilization Process Failure
Improving Patient Safety
Questions?
Thank you
Sample Worksheets
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Risk Analysis Sterilization Process Failures
Cleaning /
DecontaminationSterilization Quality Monitoring/CQI Packaging
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Risk Analysis Sterilization Process Failures
RiskProbability of
Occurrence
Potential Severity
or Risk of Failure
Likelihood of
Undetected FailureRisk Score
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Risk Management Process Improvement Highest Rated Risk Identified:
Suggested Resolution Ballot Action to be taken
ReferencesReferences
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ANSI/AAMI ST79
Association for the Advancement of
Medical Instrumentation (AAMI)
• Comprehensive guide to steam
sterilization and sterility assurance in
health care facilities, ANSI/AAMI
ST79:2010 & A1:2010 & A2:2011 &
A3:2012 & A4:2013 (Consolidated Text)
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AORN Guidelines for Perioperative Practice (2015)
• Instruments and Powered Equipment –
Cleaning and Care of
• Disinfection – High-Level
• Environmental Cleaning
• Flexible Endoscopes – Cleaning and
Processing
• Packaging Systems – Selection and Use
• Sterilization
• Sterile Technique
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Evidence-Based Guidelines
Centers for Disease Control and Prevention
(CDC) Guideline for Disinfection and
Sterilization in Healthcare Facilities, 2008
• Available at:
http://www.cdc.gov/hicpac/pdf/guidelines/
Disinfection_Nov_2008.pdf
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Risk Analysis of the Sterilization Process Resources
In-service articles
•Risky business: Risk analysis in CSSD
by Sue Klacik(IAHCSMM representative to AAMI and
co-chair of the PCD working group)
Published in Healthcare Purchasing News
August 2010
http://www.hpnonline.com/ce/pdfs/
1008cetest.pdf
•Worth the Risk: Performing a Risk
Analysis in CSSD by Sue Klacik Published in HealthVIE.com May 2011
http://solutions.3m.com/wps/portal/
3M/en_US/Sterilization/3MSterileU/
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Other References
Microbiology
• http://en.wikipedia.org/wiki/
Microbiology
Sterilizer testing
•Association for the Advancement of
Medical Instrumentation. Hospital
steam sterilizers. ANSI/AAMI
ST8:2013. Arlington, VA. 2008.
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Device Reprocessing References
• U.S. Food and Drug Administration.
Reprocessing Medical Devices in
Health Care Settings: Validation
Methods and Labeling: Guidance for
Industry and FDA Staff. Rockville
(MD): FDA, March, 2015.
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Device Reprocessing References
• Association for the Advancement of
Medical Instrumentation. Designing,
testing, and labeling reusable
medical devices for reprocessing in
health care facilities: A guide for
medical device manufacturers.
AAMI TIR 12:2010. Arlington, VA.
2010.
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Disinfection Testing References
• U.S. Food and Drug Administration, Center for
Devices and Radiological Health. FDA Reviewer
Guidance. Content and Format of Premarket
Notification [510(k)] Submissions for Liquid
Chemical Sterilants/High Level Disinfectants.
FDA, Washington, DC, January 2000.
• U.S. Environmental Protection Agency.
Disinfectants for Use on Hard Surfaces. Efficacy
Data Requirements. DIS/TSS-1 January, 1982.
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Sterilization Monitoring Reference
Sterilization monitoring
• Schneider PM, Routine Monitoring of the
Steam Sterilization Process in Healthcare
Facilities, In: Rutala WA, editor,
Disinfection, Sterilization and Antisepsis:
Principles, Practices, Current Issues,
New Research and New Technologies,
Association for Professionals in Infection
Control and Epidemiology, APIC,
Washington, DC, 2010:168-202.
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References
• The Joint Commission, Hospital Accreditation Standards 2015
• Joint Commission Perspectives®, July 2009, Vol. 29, Issue 7.
Copyright 2009 Joint Commission on Accreditation of
Healthcare Organizations
http://www.ingentaconnect.com/content/jcaho/jcp/2009/0000002
9/00000007;jsessionid=1jbtxsooxtvio.alice
• Personal communications with hospitals that have had surveys
Thank You!
Questions/Comments?