Recently I had an opportunity to talk to a few medical device engineers who had questions about how to clean a product they were developing. They wanted to know if it would need to be sterilized or disinfected, high-level or intermediate, what products, and how they would write the instructions. So first, I had to thank them for even considering me, and for considering that there will be an end-user of their product who will want to know how to clean it. Many times, not a lot of thought goes into it, and the user takes all the risk.
We once purchased some special glasses for interventional radiologists to wear for xray protection. They came from a small manufacturer. The radiology tech called me when she received the glasses. It came with a small piece of paper that said, "Cleaning Instructions: Sterilize in alcohol." Well, that's not too helpful. First, they are glasses. They were to be left in the procedure room, and available to any physician or staff doing a procedure. They are non-critical, and would not need sterilization. What kind of alcohol? Not many sterile processing departments do alcohol sterilization that I know of. Also, the glasses had a rubber strip around the nose and eyebrow ridge. This would surely dry and crack after alcohol immersion.
So we abandoned those instructions, and disinfected them with a surface wipe. We felt that was safe for shared usage. Manufacturers know they should include some kind of cleaning instructions, but that doesn't mean they are reasonable or appropriate for the product. Unfortunately, you are often tied to their instructions--for the safety of the staff, the patients, and for survey or audit compliance.
We’ve just had a little accreditation survey, and as expected, they touched on environmental disinfection. They wanted to know if staff know how to use their disinfection products properly and safely. They asked for MSDS sheets and were not satisfied that we were following all the proper safety recommendations. Unfortunately, we had on hand the MSDS for a cleaning product in it’s concentrated form, not the “as-used” diluted product. Newer MSDS or SDS sheets differentiate the two, and you may find that while eye protection is required for one, it’s not for the other.
So we took a ding on that, even though we weren’t wrong. We were wrong in not having the most up to date or correct SDS form. While we were marked for the eye protection, on our own we later saw that one of our products required long sleeved clothing during use. All of our housekeeping staff have short-sleeved uniforms, so this is an issue. Another SDS stated that eye protection is required--except for “consumer use.” This is confusing, as everyone who buys and uses the product is the consumer. Does this mean for home use, as opposed to industrial or hospital use? Again, unclear. It’s not just reading the product label anymore--make sure you are reading your SDS forms to be sure you can actually comply with the instructions.
Also this week, an employee got a splash of disinfectant in his eye. When we went to the SDS sheet, there were first aid instructions, but it also referred you back to the product label! This is awful. First, you’ve got chemicals in your eye. Hopefully, you are flushing it for 15 minutes, while simultaneously completing the incident report, calling Employee Health, and finding someone to cover your patients. But now you’ve got to go get the product to make sure you didn’t miss anything important, and read (with one eye) a 3-page, tiny print, disinfectant label full of kill claims, alternate uses, and dilution instructions to find any additional first aid measures.
Check your SDS’s and compare them against the product label. Do they say the same thing? Is it clear what protective equipment is required, by whom, and for what type of use? Is there vague wording like “eye protection, as deemed necessary?” Compare section 2 of the SDS (Hazard Exposure) to Section 4 (First Aid) and Section 8 (Protective Equipment). If it says it causes irreversible eye damage in Section 2, there should be adequate protection recommended in Section 8.
Are your SDS’s up to date? Manufacturers don’t always let you know when a new update is available. You could buy a subscription to an SDS management service that keeps updated copies, but we’ve found errors there as well. You need to do random audits on them to make sure you’re getting what you paid for.
You might be thinking that none of this is your job. It’s housekeeping’s job, or the safety officer, or the materials manager. But the ICP is a crucial piece of disinfectant selection, and we don’t work in a vacuum. You can’t select a product for its efficacy, and leave everyone else to figure out the safety piece. It has to be right for everyone. You want cleaning staff to be safe, and you want to be able to comply on a survey. After our survey, we had to abandon one product as an everyday cleaner because it became clear that it was difficult to comply with safety recommendations. When evaluating a new product, ask for and review disinfectant SDS sheets upfront, and cleaning instructions for equipment.
Next week is Environmental Services Week! Show your appreciation to the staff who are physically doing the infection control every day.
