Source · HSSIB Patient Safety Investigation
Decontamination of surgical instruments
Published 26 May 2022
Launched 24 August 2021
Published
HSIB Legacy
Hospital care
Surgical
Detailed examination of how the risk of contamination is currently managed within NHS trusts. Our investigation identifies regulatory and assurance gaps, plus four safety recommendations to address them.
Summary
3 recommendations
5 observations
3 of 3 responded
Safety Recommendations
R/2022/192
CQC
HSIB recommends that the Care Quality Commission reviews and ensures that the approach used by healthcare providers to assure themselves that in-house or externally contracted sterile services for decontamination are safe and can identify and respond to patient safety concerns.
The CQC is exploring how to incorporate this recommendation into its new regulatory model and Single Assessment Framework. It has considered including sterile services assurance in trust assessments and is collaborating with DHSC/NHSE on a single framework.
Response received 1 August 2022
We welcome this report, which highlights the importance of effective sterile service departments in providing safe care and treatment to patients. We welcome the opportunity to consider what role we can play in providing oversight of the assurance that healthcare providers have of the safety of their sterile services – be those supplied in house or externally. We are currently developing a new regulatory model, underpinned by a new Single Assessment Framework, in order to adapt to changes in health and care. We’re committed to exploring how this recommendation could be incorporated to support improvements in safety for patients. There are clear links with the recommendations made to the Department of Health and Social Care and NHS England, which should lead to a more consistent approach and an agreement as to the most appropriate framework and standards that providers need to meet. We are pleased to have started to map out how we can work with our colleagues across the three organisations to progress this. Actions planned to deliver the safety recommendation: To consider, in developing the evidence requirements for NHS Trusts, whether evidence about assurance of sterile services can be included in the trust level well led assessment. This action is complete. Work with colleagues in DHSC and NHSE to determine what progress can be made on developing a single framework and / or standards against which a healthcare provider can assure themselves of the quality and safety of their sterile services, by March 2023. Resources in place: Agreement to attend working groups in Autumn 2022. Ongoing involvement in a reviewer capacity through to March 2023. Ensure that any outputs from this work are included in supporting guidance in the new Single Assessment Framework, by post March 2023. Resources in place: Existing policy team resources. Response received on 1 August 2022.
R/2022/193
NHS England
HSIB recommends that NHS England and NHS Improvement amends Health Technical Memorandum 01-01 to define ‘top management’ and its commitment to quality, and that external independent audits are reported directly to the responsible executive director in a trust who is accountable for the service, not just the certified department.
NHS England is proposing to issue Technical Bulletins by March 2023 as intermediate amendments to HTM 01-01, addressing the recommendations. This is pending senior management approval, as a full HTM update is not near-term.
Response received 1 November 2022
Health Technical Memorandum (HTM) 01-01 “Decontamination of surgical instruments” currently provides guidance to the NHS on this area. NHS England has a rolling programme to update Health Technical Memoranda (HTM’s) and Healthcare Building Notes (HBN’s). A formal process has been established to review all guidance in relation to its priority for updating based on relevant factors including the related risks, emergence of new technology, date of last review, available resources and changes by the NHS to clinical procedures. Actions identified in safety recommendations by the HSIB are included in these reviews. HTM 01-01 has been reviewed and the outcome is that it is not currently in our near term (next 4 year) prioritization, though it will be included in future reviews, so its status is subject to change. However, having reviewed your recommendations, NHS England: Have joined the Department of Health and Social Care’s oversight group for decontamination – whilst we appreciate recommendation R/2022/193 was for the Department of Health and Social Care, NHS England wanted to take a pro-active approach to best inform the next iteration of the HTM. Are proposing to undertake two discrete pieces of work to address your recommendations R/2022/194 and R/2022/195. Guidance resulting from this work is expected to be issued to the NHS as Technical Bulletins which will act as intermediate amendments to the HTM before its formal review. Our proposal is that we will start this work in financial year 2022-23 and we will update you once each item has been completed. Action planned to deliver the safety recommendation: NHS organisations will be provided with guidance on the safety recommendation setting out the changes required, by 31 March 2023. Resources in place: A proposal to deliver Technical Bulletins is being developed to issue actions such as these recommendations. Other dependencies identified: The proposed Technical Bulletins system will need approval from NHSE senior management. Response received on 1 November 2022.
R/2022/195
NHS England
HSIB recommends that NHS England and NHS Improvement develops a competency framework, stating skills, qualifications and professional registration as required, for all sterile services staff and includes it in Health Technical Memorandum 01-01.
NHS England has released a technical bulletin outlining a competency framework for sterile services and decontamination staff, detailing the required knowledge, skills, abilities, and behaviours.
Response received 1 November 2022
Actions planned to deliver safety recommendation: Competency frameworks for major elements of NHS Estates work, and decontamination of surgical instruments is included in the list of areas to be included, by 31 March 2023. Resources in place: resources have not yet been identified for this work, but will be included in the budget requests for 2023-24. Response received on 1 November 2022. NHS England has released a technical bulletin on the competency framework for staff working in sterile services and decontamination departments . The bulletin outlines the knowledge, skills, abilities and behaviours required by staff working in decontamination units to ensure the highest standards of decontamination are achieved. Updated on 13 March 2024.
Safety Observations
Observation 1
Observation
It may be beneficial for sterile services departments and operating theatres to report all incidents of incorrectly decontaminated surgical instruments nationally so that the healthcare system can understand the resulting patient safety risks and issues.
Observation 2
Observation
It may be beneficial to consider the adoption of standardised risk management systems across NHS trusts.
Observation 3
Observation
It may be beneficial to define clear lines of accountability for sterile services departments, to include services provided by NHS trusts and contracted services.
Observation 4
Observation
It may be beneficial to review the process that assures that decontamination of surgical instruments is appropriately considered during the design of surgical instruments.
Observation 5
Observation
It may be beneficial to include a process for cleaning internal surfaces of tubes (lumen) by use of an ultrasonic bath and confirmation clear by high pressure air (where this is not specifically excluded by the device manufacturer) in addition to the requirements set in the manufacturer’s instructions for use.