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User Facility Bulletin Logo

A quarterly bulletin to assist hospitals, nursing homes, and other device user facilities
Issue No. 36  Fall 2001

 
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In This Issue:


MEDICAL PRODUCT SURVEILLANCE NETWORK (MEDSUN)
READY TO LAUNCH FIRST SEGMENT OF THE PHASE II PILOT

By Marilyn Flack

Background

At the Food and Drug Administration (FDA), the Center for Devices and Radiological Health (CDRH) sees first hand the technological advances in healthcare as new medical devices are reviewed and cleared for marketing. The increasing complexity of medical technology, perhaps coupled with economic pressures and organizational change within health care institutions, increases the potential for unanticipated and unintended consequences.1 These changes demand that surveillance of marketed devices moves from a defensive to a proactive stance. This proactive strategy includes an understanding of how organizations encounter devices, how problems are perceived and reported, and what characteristics of the system contribute to any event.

To the extent possible to identify device failures before patients are injured, FDA can join with manufacturers and healthcare professionals in creating a safer healthcare environment. Along these lines, the Center has instituted as part of its planning process the concept of the Total Product Life Cycle (TPLC). TPLC follows the life of a medical device from its inception through its development and use, and finally its replacement by newer products.

Although there are mandatory reporting requirements for user facilities (under the Safe Medical Devices Act of 1990), there is evidence of significant under-reporting by the clinical community of adverse events associated with medical devices. FDA must have quality information about postmarket problems with devices, especially how they are used in the clinical setting, if it is to be successful in promoting patient safety.

The Food and Drug Modernization Act of 1997 mandated that FDA move away from the universal reporting requirement for user facilities to a smaller "sentinel-type" system. The current universal reporting system remains in place during the pilot stages of the new program and until FDA implements the new national system. This legislation provides FDA with the opportunity to design and implement a national surveillance network, composed of well-trained clinical facilities, to provide high quality data on medical devices in clinical use. This new system is called the Medical Product Surveillance Network (MedSun).

Before writing a regulation to implement the large-scale national MedSun reporting system, FDA plans to conduct a pilot project to ensure all aspects of the new system address the needs of both the reporting facilities and FDA. This pilot project will begin with a small sample (25) and increase to a larger sample (200) over a period of about three years. A regulation will then be promulgated reflecting the outcomes learned from the pilot project.

Goals for MedSun

Launching Phase II

Currently, the system is undergoing testing by 10 hospitals (Phase I). Following this testing, 25 hospitals will launch Phase II of MedSun in November 2001. An additional 25 hospitals and 20 nursing homes will quickly join these 25 facilities. The participating facilities will increase to about 200 during the Phase II pilot.

Recruitment for the first 25 facilities is occurring now. Any hospital that would like to participate in this exciting project, or would like to learn more about it, should call Tina Powell at CODA (the contractor administering the program): 301-588- 0177 or 1-800-859-9821. Reporting to MedSun fulfills a facility's SMDA reporting requirements.

How the program will work

During the pilot phase, up to 200 user facilities will send reports of deaths, serious injuries, and "close-call" events associated with medical devices to a secure webserver at the FDA via an Internet-based form. Two to three persons from each facility will be identified as the official MedSun participants and will have passwords to access the system. An important functionality of the software is that it is dynamic in nature. Certain questions appear only if particular responses were made to earlier questions, thus making it quick and efficient to complete. Further, it is constructed with the flexibility to permit FDA to design features that will permit specific questions to appear when certain medical devices are the topic of the report. For example, if the user facility is making a report about a catheter, the web site will automatically display several questions related to that device.

Feedback to the participating facilities is considered a key element in this new system. Information from the project about medical devices and related problems/health issues will be part of active outreach to the facilities. This may include newsletters, safety information, study data posted on the web site, etc. Types of feedback will be expanded as FDA learns from the participating facilities what type of information would be most useful to them.
__________
1 Cook, Richard I., Woods, David D., Miller, Charlotte. A Tale of Two Stories: Contrasting Views of Patient Safety. Report from a Workshop; Assembling the Scientific Basis for Progress on Patient Safety, National Health Care Safety Council of the National Patient Safety Foundation at the American Medical Association, 1998.


Marilyn Flack is a Senior Public Health Analyst in the Center for Devices and Radiological Health's Office of Surveillance and Biometrics.


FDA SENDS ANOTHER LETTER TO HOSPITALS
ABOUT REUSE OF SINGLE-USE DEVICES

Recently, FDA sent a letter to hospitals explaining the change in its enforcement approach for hospital SUD (single-use device) reprocessors. At the discretion of Department of Health and Human Services Secretary Tommy Thompson, hospital SUD reprocessors were granted another year before FDA actively enforces the non-premarket requirements with the exception of registration and listing. Premarket requirements are still being actively enforced. The complete text of the September 25th letter is on page 2.


ELECTRONIC NOTIFICATION FOR THE
USER FACILITY REPORTING BULLETIN IS NOW AVAILABLE

If you would like to be notified electronically (via e-mail) when a new issue of the User Facility Reporting Bulletin is released, you can sign-up for our List Service at:
http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCDRHNew/listman.cfm
Please share this information with your colleagues. They'll thank you for it!



CHANGES IN ENFORCEMENT OF FDA'S REQUIREMENTS ON
REPROCESSING OF SINGLE-USE DEVICES

Letter to Hospitals Re: Changes in Enforcement of FDA's Requirements on Reprocessing of Single-Use Devices (Issued September 25, 2001):



ALARMING MONITOR ERROR*
By Beverly Gallauresi, R.N., M.P.H., B.S.

A 67-year-old man with a history of schwannoma tumors, hypertension, heart failure, hypertensive cardiomyopathy, and hyperlipidemia was admitted in serious condition to the intensive care unit. He developed a cardiac arrhythmia -- ventricular tachycardia that progressed to ventricular fibrillation -- but his bedside monitor never produced a "lethal-arrhythmia" alarm or printout. Several minutes elapsed before his condition was discovered and someone called for assistance. The patient died.

What went wrong?

The alarm never sounded because it was not turned on. According to the hospital's biomedical department, the alarm suspension log revealed that all alarms for this patient were turned off before he developed the arrhythmia. The manufacturer investigated and concluded that the device was performing to specifications and had not failed mechanically.

What precautions can you take?

Alarm modes vary according to the type of monitoring system, so become familiar with the ones you use.

Although you need to support the adverse-event reporting policy of your healthcare facility, you may voluntarily report a problem with a medical device that does not perform as intended by calling MedWatch at 1-800-FDA-1088 (fax: 1-800-FDA-0178).

For more information about telemetry and bedside monitors reported to the Food and Drug Administration, please contact the author at BXG@CDRH.FDA.GOV.

Beverly Gallauresi, R.N., B.S., M.P.H., is a Nurse-Consultant in the Center for Devices and Radiological Health's Office of Surveillance and Biometrics.

*Adapted from the September issue of Nursing2001, Volume 31 Number 9.


CHECK THESE OUT! BROCHURES AVAILABLE ON THE INTERNET

Reprocessing of Single-Use Medical Devices by Hospitals

A Guide to Bed Safety - Bed Rails in Hospitals, Nursing Homes and Home Health Care: The Facts


SUBJECT MATTER INDEX TO UFR BULLETIN, ISSUES 1-36

SUBJECT
ISSUE
 
Computer Database
CDRH's MAUDE System 2
MAUDE Update 10
MAUDE Update 11
MAUDE Update 5
MAUDE Update: Errors in Reporting 3
MAUDE Update: Semi-Annual Reports 4
User Facility Reporting Bulletin and MDR Information Are Now on Internet 14
 
Electromagnetic Interference (EMI)
FDA and AAMI to Present a Forum on Electromagnetic Compatibility for Medical Devices 10
FDA Concerned About Interference With Medical Devices (EMI) 18
FDA Warns About EMI Risks with Telemetry 31
Implanted Pacemakers: Avoiding Electromagnetic Interference 24
Interference Between Digital TV Transmissions & Telemetry Systems 23
Review of MDR Reports Reinforces Concern About EMI 20
 
Flowcharts
FDA Device Tracking Regulations: Device and Information Flowchart 6
Flowcharts Promote Internal Reporting Procedures 6
Sample Flowchart: How to Report Incidents Involving Medical Devices, Drugs, Utilities, and Security 6
 
Forms and Instructions
Abbreviated Instructions for FDA Form 3500A Specific to Medical Device Reporting 15
FDA Form 3419 15
Mandatory MedWatch FDA Form 3500A 15
Where to Get MDR Materials 15
 
Hospital Beds and Vulnerable Patients
Hospital Side Rails: Preventing Entrapment 21
Hospital Bed Safety Work Group: Highlights of March Meeting 35
Working Group Formed to Address the Problem of Patient Entrapment in Hospital Beds 29
Workshop Held on Hospital Beds and Vulnerable Patients 30
 
Human Factors
AAMI/FDA Conference Will Address Human Factors in Medical Device Design, Regulations, and Safety 11
Human Factors and Medical Devices 12
Human Factors and Medical Devices: Lack of Device Feedback 14
Importance of Information About Use Error and Human Factors in Adverse Event Reporting 23
We Urge You to Report Medical Devices Design Problems 16
 
Index
Subject Matter Index to UFR Bulletin Issues 1-16 17
Subject Matter Index to UFR Bulletin Issues 1-26 26
Subject Matter Index to UFR Bulletin Issues 1-36 36
 
Latex
Adverse Reactions to Natural Rubber Latex 19
Cornstarch As A Glove Donning Powder 21
FDA Answers Latex Glove Questions 21
FDA Clarifies Latex Terminology 19
FDA Issues Final Rule on Natural Rubber Device Labeling 21
FDA Scientists Study Quality Assurance Tests for Latex Gloves 19
Glove Quality and Selection Criteria 19
How FDA Regulates Gloves 19
Natural Rubber Latex Allergy: A MedWatch Success Story 19
Natural Rubber /Latex Allergy: Recognition, Treatment, Prevention 22
New Labeling for Natural Rubber Latex 25
 
MDR Studies
Contracts Awarded for User Facility Reporting Study 2
Evaluation of Device User Facility Reporting 2
Medical Device Surveillance Network (MeDSuN) 26
Medical Product Surveillance Network (MeDSuN) Ready to Launch First Segment of the Phase II Pilot 36
MEDSUN - Using Facility Reporting for the New Millennium 30
Update on User Facility Reporting Study 4
 
Medical Device Problems
Adverse Reactions to Natural Rubber Latex 19
Alarming Monitor Error 36
Avoiding Sticks from Sharp Containers 25
Biliblanket Phototherapy Light Safety Tips 25
Central Venous Catheters and Cardiac Tamponade 33
Complications Related to the Use of Vascular Hemostasis Devices 28
Complications with the Use of Small-bore Catheters in Continuous Spinal Anesthesia 2
Cornstarch As A Glove Donning Powder 21
Cross Contamination of Hemodialysis Machines: An Unexpected Risk 29
Disposable Devices: Time for a Change 21
Explosions & Fires in Aluminum Oxygen Regulators 25
FDA Cautions Users of Vacuum Assisted Delivery Devices 24
FDA Concerned About Interference With Medical Devices (EMI) 18
FDA Publishes Results of Infusion Pump Investigation 6
FDA Sends Safety Alerts and Public Health Advisories to Warn of Medical Device Risks 8
FDA Warns About EMI Risks with Telemetry 31
FDA Warns About Radioactivity in Radiation Protection Devices 20
FDA Will Co-sponsor Conference on Unprotected Patient Cable and Electrode Lead Wires 8
Full Field Digital Mammography Approved for Use in MQSA-Certified Facilities 30
Glass Capillary Tubes Pose Risks 25
Healthcare Community Alerted to Device Problems During 1994 10
Heating Devices: How to Avoid Burns 21
Hospital Side Rails: Preventing Entrapment 21
Hospital Bed Safety Work Group: Highlights of March Meeting 35
How to Avoid Injuries from Liquid Chemical Disinfectant 27
Implanted Pacemakers: Avoiding Electromagnetic Interference 24
Incorrect Restraint Use: Deadly Protection 21
Infections from Inadequately Reprocessed Endoscopes: FDA & CDC Issue Public Health Advisory 28
Infusion Pump Mishap: Outside The Channel 21
Interference Between Digital TV Transmissions and Telemetry Systems 23
Labor and Delivery Beds: Keeping Newborns Safe from Falls 27
Medical Device Year 2000 Update 25
Medication Errors Associated with Medical Gas Mix-Ups 35
Pacing Your Patients 30
Peritoneal Dialysate Overfill and Human Factor Implications 27
Potential Hypersensitivity Reactions to Chlorhexidine-Impregnated Devices 23
Potential Injury from Circumcision Clamps 32
Problems with Biological Indicators 10
Problems with Circumcision Clamps 28
Protecting Your Patient's Eyes 31
Public Health Advisory on Electric Heating Pads Prompted by MDR Reports 16
Public Health Advisory: Potential for Injury from Medical Gas Misconnections of Cryogenic Vessels 35
Public Health Message: Electrode Lead Wires and Patient Cables 24
Risk with Collagen Hemostasis Devices 26
Safeguarding Cardiac Guide Wires: Follow These Tips to Avoid Breakage 24
Safeguarding Contrast Media Injections 33
Safe Infusions 31
Safety Alert Issued for Hospital Bed Side Rails 13
Sending the Wrong Signals 33
Serious Complications Associated with Pulmonary Artery Catheters 30
Serious Injuries from Microwave Thermotherapy Used for Benign Prostatic Hyperplasia 32
Some Antimicrobial Susceptibility Tests Fail to Detect Resistance 9
Steam Resterilization Roughens Surface of Zirconia Ceramic Femoral Heads 20
Working Group Formed to Address the Problem of Patient Entrapment in Hospital Beds 29
Workshop Held on Hospital Beds and Vulnerable Patients 30
 
Medical Device Reporting (MDR)
A Review of Mandatory MedWatch Form 3500A and Semiannual Report Form 3419 16
Applying the Safe Medical Devices Act to Nursing Homes 17
Comments Received on Proposed Medical Device Reporting Regulation 2
FDA Begins Inspection of User Facilities 13
FDA Begins Train the Trainer Courses 17
FDA Extends Effective Date for MDR to 7/31/96 15
FDA Holds Train the Trainer Courses 18
FDA Regions Offer MDR Training 18
FDA Sends Public Health Notice About Important Y2K Planning Information 27
FDA Will Present Live Satellite Teleconference 14
Final Civil Penalties Rule Published 13
Handling Adverse Events Reports 33
How to Handle Failed Devices 27
Live Satellite Teleconference on MDR Final Rule 15
MDR Final Regulation to Be Published Soon 10
MDR Program Starter Kit (Table) 14
MDR Teleconference Reaches Large Audience 16
MDR: A Public Health Partnership 14
Medical Device Amendments of 1992 2
Medical Device Tracking: A Case Study 31
Preserving the Evidence! The First Step in An Accident Investigation 23
President's Council on Year 2000 Conversion 27
Public Availability of User Reports 4
Reporting Problems with Medical Devices: Overview 35
Reporting Y2K Adverse Events 28
Review of MDR Reports Reinforces Concern About EMI 20
Those Codes 18
Training Medical Personnel to Comply with SMDA 3
User Facility ID Number 4
What to Expect During an FDA User Facility Inspection 24
When to File an MDR Report 12
 
MedWatch
FDA Announces New MedWatch Program 5
MedWatch Software Available On Internet 18
MedWatch 6
Natural Rubber Latex Allergy: A MedWatch Success Story 19
Obtaining MedWatch Forms and Instructions 5
 
Miscellaneous
A Note from James L. Morrison, Acting Director 8
Applying the Safe Medical Devices Act to Nursing Homes 17
HCFA to Hold Conferences on Year 2000 (Y2K) Readiness Strategies 26
How to Request MDR Records Under the Freedom of Information Act 11
Lyme Disease: Difficult to Diagnose 26
MDR from an Insurance Company Perspective 11
New Mammogram Requirements Effective April 28 26
 
Public Health Advisories and Alerts
FDA Sends Safety Alerts and Public Health Advisories to Warn of Medical Device Risks 8
Infections from Inadequately Reprocessed Endoscopes: FDA & CDC Issue Public Health Advisory 28
Public Health Advisory on Electric Heating Pads Prompted by MDR Reports 16
Public Health Advisory: Potential for Injury from Medical Gas Misconnections of Cryogenic Vessels 35
Public Health Message: Electrode Lead Wires and Patient Cables 24
Safety Alert Issued for Hospital Bed Side Rails 13
 
Questions
Frequently Asked MDR Questions 16
Frequently Asked Questions 1
Frequently Asked Questions 3
How to Avoid Problems with MDR Reports 11
Questions and Answers 5
Questions and Answers 9
Quiz: Are These Medical Incident Reports Required? 2
 
Reader Survey
Analysis of Bulletin Questionnaires 10
Preliminary Results of the Reader Survey 9
Questionnaire 8
 
Report to Congress
Highlights of the Report to Congress on User Facility Reporting 7
 
Reporting Requirements
First Semiannual Report Due by July 31 1
Food and Drug Administration Modernization Act of 1977 22
 
Reuse/Single-Use/Disposable
AAMI/FDA to Hold Conference on Reuse of Single-Use Devices 25
August 14, 2001: Important Enforcement Date for Hospital Reprocessors of Single-Use Devices 34
Applying the Quality System Regulation to Hospitals that Reprocess SUDs 34
Changes in Enforcement of FDA's Requirements on Reprocessing of Single-Use Devices: Letter from Dr. Feigal (September 25, 2001) 36
Disposable Devices: Time for a Change 21
Establishment Registration & Medical Device Listing 34
Extensions Granted to Enforcement Priorities of Reprocessed Single-Use Devices 35
FDA Alerts Users of Reusable Medical Devices 19
FDA Releases Final Guidance on the Reprocessing and Reuse of Single-Use Devices 31
FDA Sends Another Letter to Hospitals About Reuse of Single-Use Devices 36
Labeling and Tracking Requirements 34
Medical Device Reporting 34
PMA Submissions Now Due for Reprocessed Class III Single-Use Devices 33
Premarket Approval 34
Premarket Notification 34
Reports of Corrections and Removals 34
Reprocessing of Single-Use Devices: Letter from Dr. Feigal (September 28, 2000) 32
Reuse Events 30-36
Reuse of Single-Use Devices 29
Reuse of Single-Use Devices Workshops 34
Reuse Teleconference, December 13, 2000 32
 
Tracking
Device Tracking 2
Devices to Be Tracked (Table) 3
Devices to Be Tracked as of 8/29/93 (table) 5,6
Implementing a Medical Device Tracking System at Thomas Jefferson University Hospital 6
Tracking for 26 Devices Is Required 8/29/93 5
 
User Facility Reporting Bulletin
Cost of Printing Bulletin May Lead To Availability Only On Internet 18
Future of Bulletin Uncertain 24
Last Printing of User Facility Reporting Bulletin 20
List Serve Announcements 34-36
Two Ways to Get the Bulletin In the Future 20
 
User Reports
A Look at the First 50 User Facility Reports 1
Accessing User Facility Reporting Information on the World Wide Web 20
Confidentiality of User Facility Reports Is Governed by Freedom of Information Act 9
FDA Introduces Study for User Facility Reporting 22
Public Availability of User Reports 4
Summary of User Facility Reporting: 1992-1996 18
The First Year of User Facility Reporting: Part I. A User Facility Perspective 4
Part II. The FDA Perspective 4
What Does FDA Do With Adverse Event Reports? 2
Highlights of the User Facility Medical Device Reporting (MDR) Requirements (Table) 2
It's the Law: User Facility Reporting Under SMDA 1
Safe Medical Devices Act of 1990 1
Semiannual Reports Were Due by July 31 5

 

UPCOMING REUSE EVENTS

November 4-7, 2001
RAPS 2001 Conference, Baltimore, Maryland,
FDA Speaker: Lily Ng
For more information: http://www.raps.org/educ/uprogs.cfm

November 14, 2001
Association for Professionals in Infection Control of Greater Detroit, Detroit, Michigan,
FDA Speaker: Eric Joneson
For more information go to their website: www.APICGD.org; or contact Lisa Sturm by electronic mail: lsturm@umich.edu.

For additional information about reuse, visit the Reuse Website at:
http://www.fda.gov/cdrh/reuse/index.shtml


USER FACILITY REPORTING BULLETIN

FDA produces the User Facility Reporting Bulletin quarterly to assist hospitals, nursing homes, and other medical device user facilities in complying with their statutory reporting requirements under the Safe Medical Devices Act of 1990, the Medical Device Amendments of 1992, and the Food and Drug Administration Modernization Act of 1997. The Bulletin's contents may be freely reproduced. Comments should be sent to the Editor.

Editor: Nancy Lowe
Assistant Editor: Mary Ann Wollerton
Associate Editor: Edie Seligson

Department of Health and Human Services
Public Health Service Food and Drug Administration
Center for Devices and Radiological Health, HFZ-230

 

Updated November 9, 2001

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