Healthcare Hygiene magazine April 2020 | Page 33

and accessories, as well as other respiratory devices, during the COVID-19 pandemic to support patients with respiratory failure or difficulty breathing. Health and Human Services secretary Alex Azar said in a statement that with the Trump administration’s removal of barriers through an executive order invoking the Defense Production Act, “Medical device makers can more easily make changes to existing products, such as changes to suppliers or materials, to help address current manufacturing limitations or supply shortages. Other manufacturers, such as auto makers, can more easily repurpose production lines to help increase supply. Hospitals and other healthcare providers can repurpose machines they have now to serve as ventilators.” Guidance issued by the FDA outlines several key steps. First, the FDA will exercise enforcement discretion for certain modifications to these FDA-cleared devices. Normally, any time a manufacturer or user makes a modification to a ventilator device, those modifications can often trigger an FDA premarket review, which can delay the time it takes to get these devices to the bedside. The guidance also helps manufacturers ramp up their manufacturing by adding production lines or alternative sites, for instance, using non-medical device manufacturers such as automobile manufacturers, to start manufacturing ventilator parts. In recognition of the current pandemic situation, and to ease regulatory burden on manufacturers, the FDA is being flexible in not enforcing the premarket review requirement for these modifications. Second, hospitals and healthcare professionals may use ventilators intended for other environments. For example, the guidance notes hospitals that could repurpose ventilators normally used for transporting patients in an ambulance into the hospital setting for long-term use. The FDA’s policy also applies to healthcare facilities that use ventilators beyond their indicated shelf life, which should increase ventilator capacity. The FDA says it has been working closely with PPE manufacturers to understand their supply capabilities during this pandemic. “The agency is also aware of challenges throughout the supply chain that are presently impacting the availability of PPE products and is taking steps to mitigate shortages that healthcare facilities are already experiencing,” Azar said in a statement. “For example, on March 2, the FDA granted an Emergency Use Authorization to allow NIOSH-approved respirators typically used in industrial settings to be used in healthcare settings.” The FDA also published a Letter to Healthcare Providers and FAQs that provide conservation strategies for gowns and masks and continues to coordinate and communicate with interagency and state partners to help ensure that they are more readily available. The FDA’s strategies include two tiers of conservation: Conventional Capacity Strategies (supply levels are adequate to provide patient care without any change in routine practice): ● ● Nonsterile disposable patient examination gloves, which are used for routine patient care in healthcare settings, are appropriate for the care of patients with suspected or confirmed COVID-19. ● ● Use FDA-cleared medical gloves according to labeling and local, state, and federal requirements. www.healthcarehygienemagazine.com • april 2020 ● ● Employ engineering and administrative controls following the CDC’s and HICPAC guidelines to reduce the need for medical gloves while minimizing risks to healthcare providers and patients. Some of the CDC’s Strategies for Optimizing the Supply of N95 Respirators may also be useful for gloves conservation. ● ● Reserve use of sterile gloves for procedures in which sterility is required. Contingency Capacity Strategies (limited supply levels may change patient care, but may not have a significant impact on patient care and health care provider safety) ● ● For training or demonstration in which broad barrier protection is not needed, use gloves that are beyond the manufacturer-designated shelf life, if available. Crisis or Alternate Strategies if Medical Gloves are Running Low or Not Available (may need to be considered if medical glove supplies are critically low and demand is high) ● ● Refer to the CDC’s Hand Hygiene in Healthcare Settings guidance ● ● Use medical gloves beyond the manufacturer-designated shelf life in a setting where there is a lower risk of transmission (for example, non-surgical, non-sterile). The user should visibly inspect the gloves prior to use and, if there are concerns (for example, discolored or visible tears, holes), discard the gloves. ● ● Extend the use of medical gloves for healthcare providers without changing the gloves between patients with the same infectious disease diagnosis or exposure and no other infections. Gloved hands can be cleaned between patients and at other times when hand hygiene would normally be performed during routine patient care. Alcohol-based hand sanitizers may degrade vinyl gloves. If a glove becomes damaged or contaminated, replace it. ● ● Consider using non-medical gloves such as those used for food service, embalming, cleaning, or other industrial-grade gloves that most closely align with the ASTM standards for medical gloves as outlined in the FDA’s Medical Glove Guidance Manual. ● ● Be aware that counterfeit medical and non-medical gloves may be on the market, especially during this time of reduced supply. The FDA’s Letter to Health Care Providers refers specifically to potential shortages relating to surgeons’ gloves and patient examination gloves, which are regulated by the FDA under 21 CFR 880.6250 and 21 CFR 878.4460 as Class I medical devices that require a 510(k) premarket notification. These devices are reviewed by the FDA to ensure performance criteria such as leak resistance, tear resistance, and biocompatibility are met. A surgeon’s glove is a device made of natural or synthetic rubber intended to be worn by operating room personnel to protect a surgical wound from contamination. A patient examination glove is a disposable device intended for medical purposes that is worn on the examiner’s hand or finger to prevent contamination between the patient and examiner. The FDA says it is collaborating with manufacturers of medical gloves to better understand the current supply chain issues related to the COVID-19 pandemic and to help mitigate any widespread shortages of these products. 33