Management of the Outcome of Bacterial Monitoring Investigations 1.0 Introduction All UK Blood Services carry out routine bacterial screening on all platelet components. Where an initial positive is identified, all related components will be quarantined and/or recalled very rapidly (with a target for this to be initiated within 1 hour of the identification of the initial reactive result). In this way, appropriate action is taken to reduce the risk to patients. However, on occasions, a component will be transfused before a positive result has been detected. All such events will require some degree of investigation. This paper is intended to define the agreed basis on which such investigations will be carried out. The extent and complexity of follow-up investigations will depend on the level of risk, so that a full investigation will not be required on each occasion, but a minimum documented investigation/statement is required for all initial reactive results from platelet screening regardless of whether they have been transfused or not. In addition to defining the extent of the investigation to be undertaken, the paper will also define those circumstances where a report needs to be made to SABRE. 2.0 Definition of BacTALERT Results Where an initial reaction is identified, there are 4 possible outcomes, as follows 2.1 Confirmed Positive A positive result will be confirmed if bacteria are grown from the initial reactive bottle and bacteria of the same species are detected in either the index bottle or an associated blood component. 2.2 Indeterminate Positive An indeterminate result will be recorded if bacteria are grown from the initial reactive bottle, but no material is available to carry out a repeat test and/or the component(s) has been transfused Or Bacteria are detected in the initial screen but not the repeat screen Or Bacteria are detected in the initial screen or repeat test which cannot be matched at the species level 2.3 Indeterminate Negative An unconfirmed result will be recorded when nothing is grown from the bottle but there is no index or associated pack to retest 2.4 False Positive A false positive result will be recorded where no bacteria are found in the original culture bottle and there is no growth in the index or associated component packs. Page 1 of 8 Management of the Outcome of Bacterial Monitoring Investigations 3.0 Reporting to SABRE Following an initial positive result, the decision tree for reporting to SABRE is in the attached flow diagram (appendix 1). In essence, a report to SABRE will be required in the following circumstances 3.1 Failure of the QMS Any failure of the QMS will be reported. Such failures could include the following: • Failure to initiate recall/quarantine of components within a reasonable time frame Recall process 1) Ensure Recall is initiated and conducted as required. Report to SABRE if the following timeframes are exceeded (unless exceptional circumstances prevail): - From “Initial Reactive” result to confirmation that component has been successfully quarantined > 4 hours - From contact made with hospital to unit removal from supply chain > 1 hour 2) Confirm Hospital response – Unit Quarantined /Disposed of /Transfused. 3) For components reported as transfused confirm that the transfusion time was prior to the time the hospital was contacted • • • • Failure of recall process to prevent transfusion of implicated component Failure to carry out arm cleansing or donor selection activity effectively Failure to clean processing equipment to the required standard Any other serious failure in the collection, processing, testing, storage or distribution of the component If a QMS error is detected as a part of any investigation, then this will be reported to SABRE as a Serious Adverse Event. The Root Cause Analysis and Corrective Action / Preventative Action will be reported as appropriate in the confirmation report. 3.2 Administration of Confirmed or Indeterminate Positive Components to a Patient Such incidents will be investigated as detailed in Section 4 4.0 Standardised investigation pathway following an initial reactive result from platelet screening and the subsequent requirements for reporting to SABRE 4.1 Initial Actions Following an initial reactive on a BacT/ALERT test 1) Quarantine on-site components (red cells, platelets, plasma, etc.) 2) Recall off-site components / materials 3) Manage through the QMS either through the recall process or by raising an incident Page 2 of 8 Management of the Outcome of Bacterial Monitoring Investigations 4) Culture of a sample taken from the reactive BacT/Alert bottle 5) Retest initial sample or associated component if available 6) Advise hospital clinicians of event if component has been transfused The cultured sample may or may not result in growth. Initial follow up will be as follows No Growth Investigate the apparent “false positive” 1) Check the incident management system or recall system to ensure that there is not an increased trend in these events. (No reported events may be considered as confirmation that all current procedures have been followed as required). 2) Have a procedure in place that ensures the culture growth media is capable of supporting growth (for example positive control, certified materials within shelf life). 3) Have a procedure in place that ensures all equipment (incubators, safety cabinets, etc.) is performing as required and within calibration dates. 4) Ensure that procedures include a review of the growth curve from BacT`/ALERT to consider the positivity index where false positives will have an index <1. Advice may be taken from the local microbiology laboratory Growth 4.2 Proceed with culture of a second sample from the original unit (if available). Follow up of False Positive or Unconfirmed Positives No further investigation will be carried out if the initial positive result has been discounted for either of these reasons. 4.3 Follow up of Confirmed or Indeterminate Positives For all confirmed positives and indeterminate positives an investigation will be carried out. Each of these incidents will be managed as a quality incident. The types of additonal investigation have been categorised based on the current knowledge of the clinical relevance of the findings of bacterial screening; this ensures that investigations appropriate and relevant to the implicated organism are completed. 4.3.1 Organisms not likely to be blood borne If it is not likely that the organism was blood borne e.g. Propionibacterium acnes, then it is possible that there has been a failure in the collection process. The likely source may be the skin of the donor or an environmental source. Confirm with relevant Blood Donation staff that they consider the arm Page 3 of 8 Management of the Outcome of Bacterial Monitoring Investigations disinfection process is satisfactory for the venepuncturist concerned. Confirm with the managers involved that they consider the environmental monitoring was satisfactory. No other action is required unless these investigations indicate a problem. Collection 1) 2) 3) 4) 5) Miscellaneous Check the incident management system to ensure that no relevant incidents have been reported. (No reported incidents may be considered as confirmation that all current procedures have been followed as required). Venepuncturists (may be up to 4 venepuncturists to be checked for Buffy coat pooled platelets) - Check the last 12 month arm cleansing history. If any failures have been identified ensure that any remedial actions have been addressed. - Ensure all training is current Check complaints system / session notes to see if any donors have reported incorrect arm cleansing. Static site only – Check environmental monitoring results for past 3 months – confirm no apparent trends. Check that all equipment is performing as required and is within calibration dates. Any additional aspects that the Establishment wish to review e.g. donor history. 4.3.2 Organisms likely to be blood borne These organisms e.g. Staphylococcus aureus, E. coli may have the potential to cause harm in a recipient. Investigate the donor to build up an evidence base, confirm relevant environmental and arm disinfection procedures and donor selection procedures operated effectively. Collection 1) 2) 3) 4) Processing 1) 2) Check the incident management system to ensure that no relevant incidents have been reported. (No reported incidents may be considered as confirmation that all current procedures have been followed as required). Venepuncturists (may be up to 4 venepuncturists to be checked for Buffy coat pooled platelets) - Check the last 12 month Arm Cleansing history. If any failures have been identified ensure that any remedial actions have been addressed. - Ensure all training is current Check Complaints system / session notes to see if any Donors have reported incorrect arm cleansing. Check that all equipment is performing as required and is within calibration dates. Check the incident management system to ensure that no relevant incidents have been reported. (No reported incidents may be considered as confirmation that all current procedures have been followed as required). Confirm cleaning has been regularly undertaken in Page 4 of 8 Management of the Outcome of Bacterial Monitoring Investigations 3) 4) Storage 1) 2) 3) Miscellaneous appropriate areas Check environmental monitoring results and monitoring of sterile connecting devices for past 3 months – confirm no apparent trends. All equipment performing as required and within calibration dates. Check the incident management system to ensure that no relevant incidents have been reported. (No reported incidents may be considered as confirmation that all current procedures have been followed as required). Confirm cleaning has been regularly undertaken in appropriate areas Confirm - Time from collection to required storage conditions (i.e. 20°C to 24°C) to be three hours or less. Any additional aspects that the Establishment wish to review e.g. Donor history. If the organism is deemed to be clinically relevant, then further follow up of the donor will also be necessary. In these cases experts in microbiology or health protection will be able to provide advice as to their potential source. They will coordinate actions concerning the donor with any relevant public health follow-up. The investigation will be managed through a Quality Incident. It will investigate donor, donor history, environment and processes. The team involved will identify appropriate action based on the bacterial species involved and the current understanding of the potential routes of transmission. Conclusion The UK regulatory group proposes that • The level of investigation that will be undertaken is driven by risk to patients, irrespective of whether the component has been transfused. • Organisms which are likely to be blood borne will be investigated whether the components have been issued or not. A root cause of the contamination will be sought so effective preventative action can be implemented. Where the cause is a systematic failing which needs to be corrected they will be reported to SABRE. • Organisms which are unlikely to be blood borne will prompt investigation of the collection process only. This is because of the experience the UK blood services have gained since screening was first implemented in Wales in 2003. NHSBT has investigated the source of contamination of confirmed and indeterminate positives which have been transfused before a recall on the basis of bacterial screening activity could be completed. Of over 80 investigations completed so far NHSBT has not demonstrated any systematic failures within the quality management system procedures for arm disinfection, environmental cleaning, sterile connecting, environmental monitoring or recall. The majority of investigations could not determine a cause and they have mainly been presumed Page 5 of 8 Management of the Outcome of Bacterial Monitoring Investigations to be transient skin contaminants which may not be removed by Chloroprep as they are found deep within the skin. A small number of investigations identified the source of contamination as normal microflora of either the donors arm or oropharynx. None of these contaminants have been identified as a cause of a transfusion reaction in a recipient. The pattern of identified organisms in the transfused group to the non transfused group is similar. The conclusion is that this confirms that UK BTS systems to reduce the risk of bacterial contamination are effective. • A SABRE report will be submitted when a failure in the collection, processing, storage or distribution processes leading to contamination cannot be discounted (positive or indeterminate test results) The approach allows UK services to focus investigations on a group of events which have the capability to highlight systematic failings in our systems but which are unlikely to impact significantly on patients. If these investigations were to identify Quality Management System failings then either individual events or a series of them would be reported to SABRE. This approach will ensure that all bacterial reactives will be investigated appropriately. As agreed by the Blood Consultative Committee (including members of the UK Regulatory Group) April 2013 Page 6 of 8 Management of the Outcome of Bacterial Monitoring Investigations Appendix 1 Flow Chart for Following Up BactALERT Positives Initial screen positive Staff quarantine platelet and associated components and/or initiate recall If recall or quarantine fails, incident report and submit SABRE report Indeterminate (No retest sample available) Sample and/or component retested Positive result and/or QMS failure Contamination discounted Investigate further, risk assess and submit SABRE report if appropriate SABRE report not required, no further investigation Page 7 of 8 Management of the Outcome of Bacterial Monitoring Investigations Page 8 of 8
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