Documentation of Visual Inspection at Issue with Remote Refrigerators

[bbtech55]

Had a CAP inspector cite for not performing a visual inspection at "issuance" from a Blood Track Emerge remote refrigerator.  For those of you with a Blood Track Emerge or Haemobank, how are you documenting visual inspection at issuance (the removal from the refrigerator)?  She stated that even though the unit is visually inspected at the bedside prior to transfusion, this does not meet the requirement of VI at issuance as the unit can be in the remote refrigerator for several days.  

Edited January 11, 2023 by bbtech55

[jayinsat]

16 hours ago, bbtech55 said:

Had a CAP inspector cite for not performing a visual inspection at "issuance" from a Blood Track Emerge remote refrigerator.  For those of you with a Blood Track Emerge or Haemobank, how are you documenting visual inspection at issuance (the removal from the refrigerator)?  She stated that even though the unit is visually inspected at the bedside prior to transfusion, this does not meet the requirement of VI at issuance as the unit can be in the remote refrigerator for several days.  

I do not have any remote refrigerators but, is there a way to have an automated comment added to the unit history when a unit is removed from the remote refrigerator that states it was visually inspected? That would give you documentation. Of course, you would need to have clearly stated in your policy that visual inspection is performed when units are retrieved, and nursing training would have to have that documented as well. That's how I would resolve that issue.

That said, I think that the inspector may be improperly applying the checklist item to your situation. The checklist item states:

TRM.40900 Blood/Tissue Sign-Out Phase II The process for signing blood and tissue out of the laboratory provides adequate protection for the potential recipient. NOTE: A person authorized by the transfusion medicine service must perform a clerical and visual inspection of each component immediately before it is issued. Transporters of blood components and tissue must be trained in prompt delivery. Training may consist of instruction at the time the product is dispensed.

There is no blood bank staff that is "issuing" the blood so, technically, there is no "person" signing out the unit. I would argue that the inspection would have to take place when the unit is placed in the remote remote refrigerator. I would challenge the deficiency on those grounds.

[John C. Staley]

I would make the argument that the blood was inspected when it was issued to the remote storage unit.  At that point the transfusion service had completed it's obligation.  I am assuming (and we all know how that goes!) that the remoted storage unit has been exhaustively validated and monitored with documentation to confirm my assumption.  As well as any training required for those accessing the remote storage unit.  I'm always more worried about the blood going to the wrong patient in these situations than I am for the quality of the unit.

  Personally I always enjoyed challenging such citations.   

[exlimey]

Apologies in advance for my ignorance on these matters. Are the units/products in the remote storage locations assigned to specific patients, or are they available to random patients ?

If the former is true, arguably they've already been issued.

[bbtech55]

She referenced: 

TRM.42450 Blood/Blood Component Inspection Phase II All blood/blood components and tissues are inspected upon receipt from the supplier and at the time of issue, and records retained of these checks.  NOTE: Upon receipt from the supplier, each product must be inspected for proper labeling
and shipping conditions, including an inspection of the shipping container and condition of the
coolant. Temperature measurement is not required unless a problem is suspected. Products
must be checked for expiration date and abnormal appearance, such as color, hemolysis, clots,
and bag integrity, upon receipt from the supplier and at the time of issue. Comparison of bag
and segment color should be performed for red blood cell units as an aid in detecting bacterially contaminated
units.

The unit is checked prior to placing in the Blood Track Emerge but not upon removing by nursing in the trauma bay, only at the bedside.  We have had the BT Emerge for years and this is the first time we have encountered this.  

[bbtech55]

19 minutes ago, exlimey said:

Apologies in advance for my ignorance on these matters. Are the units/products in the remote storage locations assigned to specific patients, or are they available to random patients ?

If the former is true, arguably they've already been issued.

The units are not assigned, they have emergency release tags on them.  The remote refrigerator is in the trauma bay.  She stated even though the units were inspected prior to placing in the refrigerator, they could potentially have a 10-day storage in the trauma bay and no one is visually inspecting when removing.  

[Ensis01]

How often do you check / restock the fridge? As that could be your documented inspection.