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Everything posted by tcoyle

  1. Hi, can you cite the standard/regulation that requires biannual validation?
  2. CAP All Common 30400 was recently revised; Transfusion service laboratories may use rare reagents (ie, rare antisera and selected panel red cells to determine the specificity of red cell antigens and antibodies) beyond their expiration date if appropriate positive and negative controls are run each day of use and react as expected. The laboratory must have in-date reagents for routine antigen typing and antibody panel testing. I suppose the validation could document how long those cells could be used past expiration...a week; two weeks, etc.
  3. Blood products that were taken into isolation are never returned to us. If they are not used, they are discarded in the room.
  4. Hi, you could start with the medication deferral list that is provided to blood donors to review to determine their eligibility. Meds that may affect blood products are most likely listed here. http://www.aabb.org/tm/questionnaires/Documents/dhq/v2/DHQ Medication Deferral List v2.0.pdf
  5. I hope you are stating the AP are FFP and your O inventory are RBCs?
  6. Dear Misty, so much happening! Does this person have training records? Competency? Does your facility have an institutional patient safety reporting? However, I think this goes well beyond that. It is a patient safety issue and would recommend you take your documentation to his manager. This seems like reckless behavior, which in the event management world should become an HR issue.
  7. We have a process for a new piece of hardware such as this. The lab will print a label from the printer. Attach this to the form that we use or another piece of paper. They also take a screen print from the application that label was printed. They then compare the printed label to the information in the application. It's all documented on a worksheet and kept in the work unit for the required record retention.
  8. As far as I know, FDA currently has a draft guidance for pathogen reduced platelets. FDA recently came out with the final regarding bacterial risk and platelets. You can search for FDA guidance's any time. Copy this link https://www.fda.gov/regulatory-information/search-fda-guidance-documents
  9. What does the manufacturer of the WB bag state in their package insert?
  10. tcoyle

    Unit Labels

    We have a label adherence validation that we do with the label and bag set; so we validate that the label will adhere in all conditions that it may incur. That could be anything from the blast freezer to a microwave for thawing and of course refrigerator/RT/Freezer conditions. We do this with any new label stock that we would receive prior to putting it into use. We basically test the label as it goes thru the manufacturing, storage and processing life cycle.
  11. tcoyle

    Unit Labels

    While not endorsing anyone, we use digitrax labels. We also have a robust pre-qualification/label adherence protocol to ensure that they will stay put in all situations. We also ensure that these labels meet the FDA regs for adhesive.
  12. Hey Cliff, What standard/checklist item were you cited against?
  13. 31st edition of the AABB Standards 5.1.1 Change Control: The BB/TS shall have a process to develop new processes or procedures or to change existing ones. This process shall include identification of specifications and verification that the specification have been met. Before implementation, the new or changed processes or procedures shall be validated. Stand 2.12 applies. To show that your laboratory isn't changing things on the fly, it is important to have a controlled process in making changes. AABB has a section on their website under the Accreditation Member Tools a Commendable Practices link. You may be able to glean some information on how to set up a change control process for your laboratory.
  14. According to the CMS guidelines you do not need to develop one, as long as you are performing the required QC. This is a snippet from that additional information link: I HAVE ALWAYS FOLLOWED MANUFACTURER’S INSTRUCTIONS FOR QC IN MY LABORATORY WHICH IS LESS THAN THE CLIA REQUIREMENT OF 2 LEVELS OF QC EACH DAY OF TESTING. WHY DO I NEED TO CONSIDER DOING AN IQCP? Effective as of January 1, 2016, if you wish to continue your current QC practice you will need to perform an IQCP. During test system development, manufacturers challenge their tests in many ways to identify possible failures and build in features to reduce the risk of those failures. However, manufacturers’ instructions for QC may not address all the risks, potential errors and variables that are specific to your laboratory’s situation. Developing an IQCP will address the risks that are specific to your laboratory and help you determine the appropriate QC for your patient testing.
  15. From AABB Weekly, May 5, 2017 AABB Accreditation to Accept IQCP Beginning Oct. 1, facilities that use AABB as their provider under the Clinical Laboratory Improvement Amendments of 1988 (CLIA) will be able to use an individualized quality control plan (IQCP) for limited testing of bacteriology. This is a change in AABB’s accreditation practice regarding the requirements under CLIA, for which AABB has been granted deemed status. Beginning in October, facilities that are accredited by AABB under CLIA that use either the BacT/Alert or Verax system for bacterial contamination testing may use an IQCP or continue to follow the quality control requirements set forth in the Code of Federal Regulations. An IQCP will only be accepted for this limited testing in the specialty of bacteriology. An IQCP will not be accepted for any other specialty for which AABB has been granted deemed status. Additional information about IQCP is available from the Centers for Medicare and Medicaid Services. And there was this additional information in the AABB News June 2017 Anne Chenoweth, MBA, MT(ASCP)CM, CQA(ASQ), senior director of accreditation and quality at AABB, told “AABB News” that this change will be beneficial for those facilities that are affected. “Once the Centers for Medicare and Medicaid Services [CMS] removed the CLSI guidance from their interpretative guidelines, AABB realized that the burden for quality control of culture bottles would fall to the facility,” Chenoweth said. “We worked with CMS to ensure that we could recognize IQCP for limited use in bacteriology. IQCP is not required, but this will give facilities that use AABB as their CLIA provider a choice for bacteriology quality control.”
  16. There was a good pod cast recently from Joe Chaffin (blood bank guy) and Anne Chenoweth discussing AABB related items. Anne discussed competency as well. It was good information and may be helpful (and you can get a free CE as well). Check it out!
  17. Hello, are you looking to actually create physical products or just in a computer? In the past we have made physical units with card stock...yellow for yellow products, red for red cells, and then labeled with labels we have created in our validation environment.
  18. Mabel, do you write your own reports? If so, have you seen Tableau? I'm not an expert on anything SQL, but tableau is a good software for creating your own reports. Please note: this is my opinion and not necessarily that of my employer.
  19. I don't know of any regs or accreditation standards, however your software vendor may have a stipulation about how many versions users can be behind before they stop supporting the software. You might check with them.
  20. Hello, are you wanting to validate the actual printer (hardware) or all the labels coming out of Hematrax?
  21. Hello, The people have spoken and thanks for the comments! I agree that the verification of a blood sample per CAP does not state how to do this. However, AABB is quite clear that determinations of ABO group be performed with the Anti-A and Anti-B reagents and with A1 and B reagent red cells. A question to consider: isn't it safer for the patient to do the full ABO group test when actual testing is required rather than performing only the front type? With the front and back type of testing you have a built in monitor to help discover discrepancies.
  22. Agreed! From the 31st Edition of the BBTS Standards: Standard 5.14.5 Pretransfusion Testing requires two ABO group determinations and cites Standard 5.14.1 as the precursor. 5.14.1 states the ABO group shall be determined by testing the red cells with Anti-A and Anti-B reagents and by testing the serum or plasma for expected antibodies with A1 and B reagent red cells.... TRM.40550 Forward/Reverse Typing Phase II For each patient, red blood cells are tested with anti-A, anti-B, anti-D, and serum/plasma is tested using A1 and B reagent red cells. NOTE: The ABO/Rh type of the patient's red blood cells must be determined by an appropriate test procedure. Tests on each sample must include forward and reverse grouping. CAP and AABB are in agreement.
  23. And then a comprehensive validation to show that it would work in all situations. Best to stick with what the manufacturer requires in their directions.
  24. That is exactly what we have at the end of our documents. If there are validations or change controls associated with the document updates, we also include those in that revision history. When the history field becomes extra-long (and it can especially if you have an SOP that has been used for many years) we will archive that revision history for except the last 3 years or so and note that in the synopsis of change.
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