Working with the most challenging decontamination guidelines to date

For many years Eastwood Park has focussed on the needs of decontamination technical validation and the management of its associated processes. 

The provision of decontamination training is a major element within our training portfolio and we believe we are unparalleled in terms of its resourcing.  Committed as we are, major investment is being made through our on-going new training centre project, which is making strides ahead and we are all looking forward to completion in the not too distant future.    

Our training is designed primarily around meeting the intent of NHS guidance and therefore addressing the needs of those involved in its compliance.  We have responded to many updates to guidance and policy over recent years and believe we have been successful in assisting and guiding our clients through their adaptation to necessary change.  This has been achieved largely through careful analysis of updates to ensure clear and co-ordinated direction through training. 

Among the most recent developments relating to the Advisory Committee on Dangerous Pathogens’ (ACDP) advice on cleaning efficacy, now encapsulated in the July 2016 release of HTMs 01-01 and 01-06, have proved to be possibly the most challenging to date.  Why do we believe this?

Guidance has moved into an unprecedented area of aspirational advice.  Recipients are being advised to employ technologies which are either still not available; lack commercially available alternatives  or are believed to lack evidence of independent validation.  As a consequence our efforts to align with those aspirations are dramatically hampered by the debates raging among stakeholder ‘subject matter experts’. 

This particular issue is arguably symptomatic of broader concerns about the future continuity of hospital estates technical guidance across the NHS.  When, in 2012, guidance for surgical instrument decontamination became the subject of a deregulation pilot project in the form of CFPP, there was considerable discontent among many stakeholders who felt that their pre-release draft comments had been dismissed.  This discontent highlighted a significant breakdown in communication between those empowered to shape guidance and those charged with its operational adherence.  Many organisations questioned updates in the belief that they could be retracted.  A visible consequence is that some have become less responsive to guidance change since its status in terms of compliance priority ‘appears’ to have been downgraded to ‘consideration’ for their risk registers.  Indeed many would argue that this is an appropriate outcome.

As a consequence the humble ‘bed pan’ washer now has no specific NHS guidance aside from an uncoordinated reference to the equipment standard yet they have the potential to close down an entire hospital.  Control of dental sterilization validation has effectively been transferred to manufacturers who naturally balance such risk with their commercial competiveness aware that the equipment and process standards are vague on ‘in service’ support.  In both cases these technical standards are now the only up to date point of reference yet they are written primarily for designers and manufacturers striving to meet CE certification.

Whilst most recognise that the ‘one size fits all’ approach of previous guidance may at times have been at odds with financial efficiency or advancing technology it did provide safe answers to a vast array of operational questions.  Managers and engineers charged with the day to day responsibility of ensuring equipment adequacy and safety are now being asked to analyse their needs in a manner which demands the highest levels of subject matter expertise.  Simultaneously, cost driven optimisation asks that such people hold the broadest of skillsets and responsibilities.  There is a growing conflict that becomes frequently apparent as they search in vain for digital answers to their questions.

Where must these individuals now look for some of these answers?  Even external consultants and training organisations need a solid point of reference if continuity of best practice is to prevail. 

In-use surgical instrument decontamination is unique to healthcare providers.  Quite rightly the NHS has been a leader in a field where there were no comparable sectors to look to for optimisation.  Was is right then that HTMs 2010 and 2030 were chosen for a deregulation pilot project?  A key outcome has arguably been more focus upon risk management to control cost.  Such focus, however, places greater pressure on subject matter expertise adequately informing assessment so it is of little surprise that we should be concerned when SME’s disagree, as we have witnessed in this arena over the past five years. 

Now more than ever practitioners in the area of decontamination need to be confident in their knowledge and currency if they are to realistically provide advice which contributes to risk assessment.  How many could confidently review their existing technology and processes to effectively evaluate the return on investment for replacement upgrade or modification?  Is it acceptable to rely upon the advice of regulated suppliers?  How essential is the input of independent third party SMEs?  How clean are your surgical instruments?

This article was written by Eastwood Park Decontamination & Pressure Systems Portfolio Manager Bruce Garbutt in September 2017.