Update on Premarket Notification Requirements Concerning Gowns Intended for Use in Health Care

Similar documents
[] PERSONAL PROTECTIVE EQUIPMENT Vol. 13, No. 8 August 2009

AAMI Levels and Surgical Gowns: Know if You re Protected

THE STANDARD PRECAUTIONS CONFIRMED ISSUE 6 CLINICAL ISSUE INTRODUCTION TABLE OF CONTENTS:

issue THE Standard Precautions Confirmed Introduction Table of Contents:

CDRH Standards Program

Isolation Gowns That Provide AAMI Level 1, 2 and 3 Protection

2016 Sterilization Standards Update

Karen W. Dyer MT(ASCP), DLM Director, Division of Laboratory Services Centers for Medicare & Medicaid Services CLIA

we ve got you COVERED.

Student Protocol for the Operating Room. Authored by: Vangie Dennis, RN, BSN, CNOR, CMLSO

Choosing the right mask A guide to ASTM barrier protection standards

Sterile Processing Management, Regulations and Responsibilities WEBINAR

Part I AAMI ST79 Recommended Practice

REGULATORY & ACCREDITING AGENCIES

Personal Hygiene & Protective Equipment. NEO111 M. Jorgenson, RN BSN

Sterile Processing Management, Regulations and Responsibilities WEBINAR 2018

MDUFA Performance Goals and Procedures Process Improvements Pre-Submissions Submission Acceptance Criteria Interactive Review

Sterile Processing Department Design and HVAC Considerations

TPRG is accredited by the FDA to review Medical Device Submissions on their behalf as part of the Third Party Review Program.

November 7, Division of Dockets Management (HFA-305) Food and Drug Administration 5630 Fishers Lane, Room 1061 Rockville, MD 20852

Joint Commission NPSG 7: 2011 Update and 2012 Preview

Charles Hughes. Instrument Reprocessing Update: What s New?

New Innovations in Reusable OR Textiles

10/18/2010. Disclosure. Learning Objectives. Components of an Effective Infection Control Program

Student Protocol for the Operating Room. Vangie Dennis, RN, CNOR, CMLSO

Ministry of Labour Occupational Health & Safety and Infection Prevention & Control

CRCST Self-Study Lesson Plan Lesson No. CRCST 136 (Technical Continuing Education - TCE)

CENTRAL SERVICE (CS) TECHNICIANS PERFORM MANY IMPORTANT

PLAN OF ACTION FOR IMPLEMENTATION OF 510(K) AND SCIENCE RECOMMENDATIONS

Welcome to Scott & White Memorial Hospital. Perioperative Services

4/7/15. ASC Regulatory Update and Survey Trends. Objectives. Disclosure. Describe recent changes to the CMS interpretive guidelines.

Rigid Containers for Immediate Use Steam Sterilization

World Accreditation Day Webinar

OR staffing supports the provision of safe perioperative patient care and promotes a safe perioperative environment

NJ Dept of Health Central Service Standards SUBCHAPTER 8. CENTRAL SERVICE. 8:43G-8.1 Central service policies and procedures

Visitor Guide to the OR

Erlanger Infection Control Program. Resident Resident Orientation and. and

THE BEGINNING OF THE END OF THE FLASH DANCE, WHICH

Legal Implications Recommended Practices

510(k) Clinical Data Requirements: Current Status and Considerations for Clinical Studies

Oregon Health & Science University Department of Surgery Standard Precautions Policy

THE INFECTION CONTROL STAFF

Chapter 10. medical and Surgical Asepsis. safe, effective Care environment. Practices that Promote Medical Asepsis

Infection Prevention & Exposure Control Online Orientation. Kimberly Koerner RN, BSN Associate Health Nurse

Received an RTA Deficiency List or AI Letter? Now What?

Surgical Fires: Reducing the Risk of Patient Injury

Standards and Medical Device Regulation Roundtable. Seoul South Korea. 21 October ASTM International

Interactive Review for Medical Device Submissions: 510(k)s, Original PMAs, PMA Supplements, Original BLAs, and BLA Supplements

Adverse Events: Thorough Analysis

FDA s Office of Regulatory Affairs: Violation Trends & Medical Device Update

Infection Prevention and Control in Ambulatory Care Settings: Minimum Expectations for Safe Care

EAST CAROLINA UNIVERSITY INFECTION CONTROL POLICY

3M Sterile U Network 3M Sterile U Web Meeting January 16, 2014

Welcome to Baylor Scott & White Hillcrest. A Perioperative Services Orientation

4/30/2012. Disclosure. Housekeeping. The Role of the Infection Preventionist on the Value Analysis Committee. Boyd Wilson

Perioperative Learning Center Mission Statement: The mission of the Perioperative Learning Center is to provide excellence in the education and

San Francisco General Hospital INFECTION CONTROL

The Mammography Quality Standards Act Final Regulations Quality Assurance Documentation

EAST CAROLINA UNIVERSITY INFECTION CONTROL POLICY

Guidelines for Best Practices for Humidity in the Operating Room

INFECTION CONTROL POLICY DATE: 03/01/01 REVISED: 7/15/09 STATEMENT

Of Critical Importance: Infection Prevention Strategies for Environmental Management of the CSSD. Study Points

Challenges in the US Approach to Disinfection and Sterilization

Jeanne Moldenhauer (c) Jeanne Moldenhauer

Changes to QSR. The table below provides a history of changes to FDA s Quality System Regulation (QSR)

Guidance for the Selection and Use of Personal Protective Equipment (PPE) in Healthcare Settings

REGULATORY & ACCREDITING AGENCIES

& Agalloco Associates

2010 Practice Greenhealth May 19, Reusable Surgical Textiles: A Means to Save Money and Reduce OR Waste Up to 30 Percent.

EAST CAROLINA UNIVERSITY INFECTION CONTROL POLICY

Perioperative Services

JOB DESCRIPTION. Revised:1/24/2018

Sterilisation Apparel & Accessories. CSSD Accessories and Consumables

PROCESS IMPROVEMENT AND ENHANCED QUALITY CARE ARE THE

INFECTION CONTROL PLAN- MAINTAINING COMPLIANCE WITH THE INFECTION CONTROL AND PREVENTION STANDARDS AND REGULATIONS: CMS CfC

a. Goggles b. Gowns c. Gloves d. Masks

Everyone Involved in providing healthcare should adhere to the principals of infection control.

Infection Prevention and Control Program

CDI Preventing and Managing Clostridium Difficile - A Provider's Perspective

Sterile Processing in Healthcare Facilities

Sterile Processing Management, Regulations and Responsibilities WEBINAR

BLOODBORNE PATHOGENS EXPOSURE PREVENTION POLICY AND PROCEDURE BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN

Infection Control in the Hearing Aid Clinic What is infection control & why should we care?

JOB DESCRIPTION. 1. Uphold Nursing Code of Ethics (ANA) 2. Understands the Magnet Recognition Program.

Medicare Part C Medical Coverage Policy

MEDICAL WASTE MANAGEMENT PLAN

10/11/2013. Immediate-Use Steam Sterilization in the OR. House Keeping. House Keeping. Questions. Martha Young, MS, BS,

Medical Equipment, Devices, & Supplies

CENTRAL SERVICE (CS) IS A VITAL DEPARTMENT IN ANY HOSPITAL

Inspections, Compliance, Enforcement, and Criminal Investigations

Assessing and Optimizing Operations and Patient Flow in VHA Facilities

Guidance for Industry and FDA Staff Radiation Safety Considerations for X-Ray Equipment Designed for Hand-Held Use

1 What is an AAAHC/Medicare Deemed Status survey? 2 What are the Medicare Conditions for Coverage (CfC)?

Infection Prevention and Control and Isolation Authored by: Infection Prevention and Control Department

Facility Tuberculosis (TB) Risk Assessment for Correctional Facilities

Guidance for Industry and Food and Drug Administration Staff

Recommendation II. Recommendation I. Who s on Your Team? Recommendation III

Mask and Respirator Use in the Health Care Setting Sept 30/05 Customer Answers to Problem Solving Questions

Humidity in Anesthetizing Locations Where Mechanical Systems and Compliance Collide

Last year, when Ebola made its way into

Transcription:

Update on Premarket Notification Requirements Concerning Gowns Intended for Use in Health Care Terrell Cunningham, BSN, RN Scientific Reviewer, Team Leader Personal Protective Equipment Infection Control Branch Division of Anesthesiology, General Hospital, Infection Control and Dental DevicesCenter for Devices and Radiological Health March 31, 2016 1

Key Efforts Draft Guidance Published June 2015 Final Guidance Published December 8, 2015 Webinar on the Guidance January 21, 2016 AAMI-Protective Barrier & ASTM F23.40 Joint Meeting April 19, 2016 Proposed Joint CDC/FDA Gown Workshop (Pending) Plan to Update 1993 Gown Guidance Document (Pending) 2

Background 1993 - CDRH published Guidance for Surgical Gowns & Drapes 2000 All other surgical apparel other than surgical gowns and surgical masks exempted from premarket review 2003 - AAMI PB70 liquid barrier categorization published, recognized by FDA in 2004 January 2015-NIOSH released results of study of Isolation gowns used in health care settings 3

Guidance Scope Limited to gowns making liquid barrier protection claims and intended for use in health care settings. Minimal or Low Barrier protection ANSI/AAMI PB70 Level l protection or equivalent; or ANSI/AAMI PB70 Level2 protection or equivalent. Moderate or High Barrier protection ANSI/AAMI PB70 Level 3 protection or equivalent; or ANSI/AAMI PB70 Level 4 protection or equivalent 4

Class II Gown Subject to Premarket Notification Submission [510(k)] Surgical Gowns Surgical Isolation Gowns Isolation Gowns are Class I devices but become Class II devices if additional claims are made, such as moderate or high barrier function claims Isolation Gowns with such barrier function claims are defined as surgical isolation gowns 5

FDA Premarket Review of Gowns 1993 guidance document for surgical gowns 2015 guidance document for surgical gowns Performance Testing Resist blood and liquid penetration - ANSI/AAMI PB70 Safety Testing Biocompatibility Sterilization method and validation (surgical only) ( Other properties: physical strength, comfort, heat dissipation, vapor transmission, linting, flammability, dyes 6

FDA Expectations for Manufacturers Manufacturers proposing to market or those currently marketing Class II gowns as described in this guidance should: Submit a 510(k) for the gown to the Agency within 60 days of publication of the final guidance Have a 510(k) submission for the gown accepted by the Agency for review within 75 days of publication of the final guidance Obtain 510(k) clearance for the gown within 180 days of publication of the final guidance. 7

Objectives To understand how the clinical use of surgical and isolation gowns has changed with the development of new technologies and terminology. What are the clinically relevant performance parameters? What exposure are gowns subjected to? Are manufactures and/or health care industry moving to a one-size-fits-all product line? If so do variable exposure conditions matter? 8

Objectives To determine the current performance standards are adequate. If not, what are the appropriate, clinically relevant metrics for the current use paradigm? Are the current performance tests appropriate for the intended use of the gowns? AATCC 42 and 127 ASTM 1670 and 1671 Surgical vs. non-surgical/isolation gowns Should there be a review of all testing labs 9

Objectives Objective: To determine if the current sampling, validation, and monitoring ensures that existing performance standards are met or should measure be taken to improve compliance, if so, what can be done to improve that compliance? Are the current sampling strategies prescribed in the standard(s) adequate? Testing is typically performed in the design or production validation stage. Is there value in continuous or periodic testing post production phase? Are the current AQL of 4% and RQL of 20% adequate 10

Standards for Performance Testing of Surgical Gowns Barrier Performance ANSI/AAMI PB70:2003-4 Levels of Performance at an AQL of 4% Level 1 AATCC 42:2000 </= 4.5gm Level 2 AATCC 42:2000 AATCC 127:1998 </= 1.0gm >/= 20cm Level 3 AATCC 42:2000 AATCC 127:1998 Level 4 ASTM F 1671:2012 </= 1.0gm >/=50cm PASS 11

Objectives Determine if there is a need to revise the definition of an isolation gown? Should open back gowns be included in the definition? 12

Discussion/Questions 13