Transporting clean instruments in biohazard-labeled containers; Using ultraviolet disinfection in the SPD

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Q I am the nurse manager of surgical support services at a large urban medical center that includes sterile processing. We have numerous surrounding clinics and physician offices throughout our medical center campus. These facilities send their soiled reusable instruments back to the medical center for reprocessing and sterilization.

Every day the sterile processing department (SPD) returns the sterile instruments to the various locations on an exchange basis, transporting them in special rigid containers with a secured tamper-evident lid. The containers holding the reprocessed sterile instruments are delivered to each location’s clean holding room. The clinic personnel remove the sterile items from the container bins and place them in the appropriate storage locations. Then they place the empty containers in the soiled utility room where they are used to hold soiled items for return to sterile processing for decontamination and cleaning. In other words, SPD delivers containers holding clean/sterile items in exchange for containers holding soiled items that require reprocessing. We have invested a lot of money purchasing superb containers that comply with OSHA and infection control requirements.

Here’s my dilemma: Each of the container lids has a bold, biohazard label permanently printed on it. The sterile and soiled bins are always segregated and delivered and picked up separately. They are even kept in separate compartments on specially designed transport carts. We have dedicated staff dealing with these items and all has gone well. However, we recently underwent an accreditation survey and we received a citation because the surveyor said we could not put sterile items in a container with a biohazard label on it. He did not accept our process as valid.

I now have to provide an action plan to resolve this matter. The container manufacturer cannot provide lids without the biohazard printing on them. Purchasing additional containers would be extremely costly and would require additional labor for the care and handling of a duplicate volume of containers. Do you know of any other facilities that have been confronted with such a problem? How do other facilities deal with this?

A It sounds like you have dedicated a lot of thought and resources in developing a very good system for the disposition and handling of soiled and sterile instruments to your offsite locations.

There is no doubt that the accrediting bodies are closely examining how healthcare facilities are handling, reprocessing and transporting sterile and soiled instruments and other medical devices. Transport containers and carts have to be clearly labeled and/or identifiable regarding the state of their contents (e.g., clean, soiled etc.). Over the past couple of years I have assisted many hospitals in addressing such needs and ensuring they are compliant with OSHA regulations and other professional guidelines. Your question is quite timely — yet not unique!

A couple of weeks ago I worked with a healthcare system confronting the exact same issue. We considered a number of alternatives before finding the perfect solution. We found and purchased a stock label imprinted with the word “CLEAN” in a size that fully covered the biohazard label. The label stays in place but is also easy to remove and leaves no adhesive residual when peeled off. The CLEAN label is placed over the Biohazard print on the container when the contents are clean/sterile. Once the clean processed instruments are removed the clean label is removed revealing the biohazard label and the container is placed in the soiled utility room and ready to hold the soiled goods for pick up and transport to sterile processing. (See Figure 1.)