A new management brief discusses the potential impact on reusable medical device cleaning validations and testing requirements resulting from the Food and Drug Administration (FDA)'s draft guidance document, "Draft Guidance for Industry and FDA Staff – Processing/Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling."
FDA guidance document is not legally enforceable, it describes the agency's 'current thinking and should be viewed as recommendations,'" says Steven Richter, PhD, president and scientific director of Microtest Laboratories — a former FDA official — and author of the brief.
In his brief titled "Reusable Medical Device Cleaning Validation and Testing Requirements (An Industry Perspective)," Richter discusses a variety of issues raised by the document which the FDA released last May for industry comment. The issues include:
- "Spore tag reduction" and Hucker's soil challenges
- Cleaning methods using protein, carbohydrates, red blood cells and lipids
- Separation of cleaning, disinfectant and sterilization validation activities
- ASTM Simulated Use Test
- Three log reduction for cleaning validations
- Empirical data in 510(k) submissions
- Reducing manufacturing materials to "safe levels"
While Richter emphasized that "the FDA document was issued for comment and is not for implementation, the medical device industry understands that changes from current best practices will be required immediately."
His brief seeks to "raise the industry discussion of issues that must be anticipated, discussed, and thoroughly evaluated for the time when implementation is required," he says.
Richter founded Microtest Laboratories in 1984 after a distinguished career at the FDA. Under his leadership, Microtest Laboratories provides the medical device, pharmaceutical, and biotechnology industries with premier testing and manufacturing support.
Download a copy of the management brief, "Reusable Medical Device Cleaning Validation and Testing Requirements (An Industry Perspective)," from http://www.microtestlabs.com/reusable-med-device-brief.