Hazard and Recall Management for Medical Devices and Systems
A key responsibility for many biomedical engineering programs is the management of
hazards and recalls for medical devices and systems. Typically, the biomedical engineering
program, whether it is an in-house department or an independent service organization
(ISO), manages this information for only the devices it is responsible for servicing.
Hazards and recalls for other devices or systems are often managed by other departments
like materials management, radiology, or the clinical laboratory. A less typical approach
is for one department or individual to have centralized responsibility for hazards and
recalls for all medical devices and systems in the institution.
Regardless of the approach used for managing hazards and recalls, the challenge for any
institution is to make sure that the process is handled consistently throughout the
institution. Key safety or device-failure information must get to the right personnel in
the institution, without creating a drain on the institutions resources. To meet
this goal, each institution needs to establish clear responsibilities, use consistent
naming conventions for devices and systems, establish approved and comprehensive sources
for information, disseminate information in a reliable manner, and set up a process for
accountability and follow-through. This article provides some examples of how this can be
done and is in part based on ECRIs 30-plus years of experience with disseminating
medical devicerelated hazards, recall notices, and other safety information. This
information can be used by institutions starting a hazard-and-recall management program or
as benchmark for improving an existing program.
Lessons Learned
Johns Hopkins University is known for having one of the best medical centers in
the world. It is not uncommon for Johns Hopkins to make national news about developing a
new medical breakthrough or about its highly ranked medical specialties. However, Johns
Hopkins also had the misfortune to be the subject of a national news story about a problem
with a medical-device recall. Bronchoscopes were recalled by the manufacturer because of
their potential for causing infections. Instead of being sent to the Johns Hopkins
department that used the bronchoscopes, the manufacturers recall was sent to a
loading dock at another department across the street. The recall was never forwarded to
the department that uses the bronchoscopes. In fact, the hospital did not learn about the
recall until it began investigating unexpected infection rates in some of its pulmonary
patients. In the end, several hundred patients were exposed to the potentially
contaminated bronchoscopes. As a result, infections related to contaminated bronchoscopes
may have contributed to the deaths of two patients. Also, Johns Hopkins had to contact
more than 400 patients for evaluation and offer everyone testing for possible
infections.1, 2 The lesson from the Johns Hopkins experience is that even the best
institutions can have gaps in a critical responsibility like hazard-and-recall management
and should be able to find strategies for improvement from the following information.
Roles and Responsibilities
Every hospital should have a centralized list of who is to receive, disseminate,
and resolve hazards, recalls, and other safety information about medical devices. The list
should be specific, so that all classes of medical devices are clearly covered by the
list. The list should cover all medical devices used or supported by the institution, for
example, home-care services or satellite facilities. Clear responsibilities should be
delineated for hybrid devices that might be supported or managed by two departments, like
drug/device combinations or computer-based medical devices. Responsibilities also need to
be defined for rental equipment, equipment on loan, and physician- or patient-owned
equipment.
Some staff may be assigned the responsibility of combing through approved sources for
hazards and recalls. Relevant reports can be forwarded to staff responsible for resolving
information in the hazard or recall notices. Resolution may be as simple as verifying that
the hospital does not have the affected products, or it may involve informing appropriate
staff about the reported problem and recommended solutions.
Naming Conventions
In order to put together a comprehensive list of who is responsible for management of
hazards and recalls for every class of medical device, an institution needs to have a
comprehensive inventory of the devices used in its system. Ideally the inventory should be
accessible from a central location and cover the full range of devices used in the
institution. This includes capital equipment, disposable products, reagents for devices
like clinical laboratory analyzers, hybrid devices like drug-eluting stents, and
computer-based or network-connected medical devices.
We have reviewed hundreds of hospital medical device inventories as part of a
compliance service during the Y2K days and for various other services. Many of the
inventories that we have seen over the years have serious problems with nomenclature. It
is not uncommon for one hospitals inventory to have six different names for one type
of medical device in its database and even more names for the same medical device vendor.
This problem is even worse for hospital systems, especially when each hospital in the
system manages its own inventory.
Check your inventory to see if your hospital has used consistent and up-to-date
terminology. Try a test by checking all of your entries for electrosurgical units and
blood-pressure monitors. For electrosurgical units, we have seen a broad range of
device-type names, including Bovie, ESU, cautery units, electrocautery units, and
diathermy units. Do you see a mix of these names and maybe others in your inventory? For
blood-pressure monitors, we have also seen a range of device-type names, including
Dynamap, BP monitor, monitor, and pressure monitor. ECRI has also seen many creative
abbreviations used for the names listed above. Try the same test for a few
manufacturers names. If you find inconsistencies in your database, they need to be
corrected. If not corrected, a search in your database for a match to a hazard or recall
notice about an electrosurgical unit, for example, will not find the devices recorded
incorrectly as electrocautery units or Bovies. Ideally your database should be corrected
with commonly used or standard names and spellings for device types and manufacturers.
Information Sources
The Joint Commission for the Accreditation of Healthcare Organizations (JCAHO)
Environment of Care Standard EC.6.10 requires that health care organizations manage
medical-equipment risks by identifying and implementing processes for monitoring and
acting on equipment hazard notices and recalls. Note that hazard notices" is
underscored to emphasize that we are not just talking about recalls. Some of the most
serious device problems that we have reported on were abstracted from the clinical
literature or identified by our independent hazard investigation research. In most cases
the problems were never classified as recalls by FDA or medical-device manufacturers.
Unfortunately this distinction between hazards and recalls is not appreciated by many
health care organizations. They attempt to comply with JCAHOs standard by monitoring
only for recalls. This puts their accreditation and, more important, their patients at
risk by overlooking critical safety information.
Every hospital should have an approved list of sources for medical devicerelated
hazards, recall notices, and other safety information. Sources should include
manufacturers, regulatory agencies like FDA, hazard-and-recall notification services, and
clinical literature. Facilities should have a system in place for checking the device
identifier information in their source data against the device identifier information in
their inventories. They will save a tremendous amount of time and avoid the risk of having
critical safety information slip through the cracks if the naming convention in their
source data is consistent with the naming conventions in the inventory.
Also, keep in mind that some source information can be wrong or incomplete. Heres
another test for your system. Ask your source providers how they verify the information
you receive. Is their nomenclature consistent with the one used in your inventory
databases? If additional recommendations are included in the data provided, what are the
qualifications of the individuals creating those recommendations? Also, does your source
data include more than recalls?
Disseminating Information
In January 2002, a problem was widely reported regarding misconnection of a
nitrous oxide regulator in a cardiac catheterization laboratory in Connecticut. Two
patients died because they were accidentally given nitrous oxide instead of oxygen.3 The
information about how this problem could occur and, more important, how to prevent it from
happening again is critical for several specialty areas in your institution. These include
at least anesthesia, cardiac catheterization, clinical or biomedical engineering, nursing,
respiratory therapy, plant operations, and risk management.
Look back at your hazard-and-recall distribution records for early 2002. Do you have a
report on the nitrous oxide misconnection problem? If so, does it have recommendations for
how to prevent the problem? Can you verify that this information was disseminated to
responsible individuals in the departments listed above? Can you think of other
departments in your institution that should have been informed of this problem? If so, do
you have a record that this was done? If you cannot answer yes to each of these questions,
you may need to look at the how hazard-and-recall information is distributed within your
institution. If you are not aware of the misconnection incident and the recommendations on
how to prevent the problem, then you need to consider using additional or better sources
for medical-device hazards and recalls. If the specialty areas listed above did not
receive the report or if you dont have records that they did, then you may need to
reconsider how you disseminate medical-device hazard-and-recall information within your
institution.
Accountability and Follow-Through
A hospital may have a very reliable method for disseminating hazards and recalls.
If it does not have a good feedback mechanism for what is being done with the information,
however, then it has no assurance that the problems are being addressed. Regarding the
nitrous oxide misconnection problem, does your hospital have a record showing that the
recommended user training was done? Your hospital may have made a conscious decision that
training the staff related to this problem was unnecessary. If so, do your records related
to this problem include justification for why the training was not needed at your
facility?
As you review your program for medical-device hazard-and-recall management, make sure
that it includes an effective feedback loop. Everyone who receives hazard-and-recall
notifications should have an easy method for communicating back to hazard-and-recall
coordinators what is being done about the problems. As noted above, each class of medical
devices should have an individual responsible for receiving and resolving hazards and
recalls in that category. Those responsibilities should be clearly communicated to the
appropriate staff. And, hazard-and-recall coordinators should have mechanism for routinely
checking the status of their reports. If nothing is being done, coordinators should have
the clout either to push the responsible staff to action or to find other staff to help
resolve the problem.
Conclusions
Management of medical-device hazards and recalls is a critical task for every
health care institution. With the rapid growth of medical technology, very serious
problems can slip through the cracks and result in unnecessary patient deaths or injury. A
well-organized program for managing hazards and recalls with a reliable feedback loop will
not prevent problems from happening at your institution. However, it will significantly
increase your odds addressing problems quickly.
James P. Keller, Jr is director, health devices group, ECRI.
References
1. Defective Bronchoscopes Identified as Probable Cause of Infections Are Part of
Manufacturers National RecallHopkins Launches Effort to Contact, Evaluate All
Potentially Exposed Patients [press release]. Baltimore: Johns Hopkins Medical
Institutions, Office of Communications and Public Affairs; March 4, 2002.
2. Altman, LK, Grady, D. Hospital says faulty recall may have exposed 400 to infection,
New York Times. March 5, 2002: A1.
3. Misconnected flowmeter leads to two deaths. Health Devices Alerts Action Items. Special
Report. January 25, 2002: 26 (A4): 1.