NHS England
HSIB recommends that NHS England reviews system requirements for barcode scanning technology, in order to support local organisations to reduce the risk of incorrect selection and insertion of prostheses/implants.
NHS England provide advice, support and guidance to NHS organisations interested in adopting or improving approaches to ensure the traceability of medical devices and other products used in health and care services safely. This is NHS England’s programme for supporting Scan4Safety through national advice and guidance.
Specifically, an official Scan4Safety website has been published to help organisations find the resources they need to promote Scan4Safety locally. The website is supported by GS1 and received input from other key stakeholders. Furthermore, NHS England are launching an interactive NHS Futures page with more hands-on tools for providers to use locally.
To further our support to the system, NHS England work closely with other national organisations (MHRA, NHS Supply Chain and GS1), people who use services and NHS trusts in line with system wide requirements to increase the uptake of safe and effective scanning technologies. In addition, from March 2024 all trusts are mandated to commence recording of medical devices used in all procedures through specialty Outcome Registries.
These approaches accord with the DHSC Medical Technologies Strategy 2023 highlights the importance of utilising appropriate scanning technologies to improve the traceability of device use in health and care services.
Response received on 22 January 2024.
British Standards Institution
HSIB recommends that the British Standards Institution updates the applicable standard/s, and raises with the International Organization for Standardization, to state that medical device labelling and packaging should detail the specific use of an item. This should be developed with user input to drive consistency in the terminology used on medical device labelling/packaging.
BSI, as the UK’s National Standards Body (NSB), supports the Safety Recommendation 2023/227 made by the HSIB in report NI-003683, addressing the need for the information provided on device labelling to also include details of the medical device’s intended use.
We recognize that while the issue highlighted in the report is specific to a manufacturer and device, the concerns related to device identification, intended use, and patient safety apply to all manufacturers and medical devices. Labelling is a fundamental component of device design and used as one form of risk mitigation; however, the users of the labelling are very often not the users of the device itself, and additional information may be necessary to properly identify what device(s) may be needed.
BSI are committed to promoting best labelling practices within the UK as well as internationally and will influence consideration of this recommendation by the relevant ISO technical committees.
Detailed actions and timescales for completing this work are outlined below. We will keep the HSIB informed of the progress and results of these actions.
Actions planned to deliver safety recommendation:
- The BSI standardisation committees team will identify what international standardisation committee(s) are responsible for labelling requirements and suggest a comment be put forward to the ISO technical committee for discussion and inclusion of intended use information on device labelling. If the UK experts on the BSI standardisation committee do not agree with the HSIB recommendation, an alternative solution will be provided for consideration, by Quarter 4 2023. Other dependencies identified: Standards review timelines – BS and ISO standards. Additional comments: This will be reviewed initially at the national level before consideration at the international level.
- BSI will convene other national standards bodies to discuss patient safety investigations and feeding the recommendations back into the standards, thereby closing the feedback and continuous improvement loops, by Quarter 2 2024. Other dependencies identified: Availability of other NSBs, their relationship to national safety boards, and their access to patient safety investigations and recommendations
Response received on 17 October 2023.
Medicines and Healthcare products Regulatory Agency
HSIB recommends that the Medicines and Healthcare products Regulatory Agency ensures the assurance processes for designated approved bodies (to check medical device manufacturers conform to packaging standards) are amended to consider context of use and usability guidelines, to reduce the risk of selecting and inserting the incorrect device.
The MHRA agrees that the risk of selecting and inserting an incorrect device i.e., arteriovenous grafts can be mitigated by ensuring that medical device manufacturers consider the impact of Human factors, i.e., context of use and usability guidelines when designing packaging. Before a device is granted a UK Conformity Assessed (UKCA) mark and supplied on the GB market, an ‘Approved Body’ will have completed an assessment to ensure it conforms with the current regulations. The MHRA regularly audits Approved Bodies once they are designated. Technical files are sampled as part of surveillance audits to help ensure that correct evidence has been provided by the manufacturer and assessed appropriately.
Following your report, we will engage with the designated and applicant Approved Bodies to ensure that they are aware of this recommendation and modify our processes to ensure that when auditing Approved Bodies, their consideration of the context of use and usability guidelines when assessing adherence to packaging standards in conformity assessments is reviewed. This will be followed up at regular surveillance audits conducted by the MHRA to ensure that Approved Bodies are correctly monitoring manufacturers.
Actions planned to deliver safety recommendation:
- Provide a copy of the HSSIB report to designated and applicant Approved Bodies ahead of the next UK Approved Body (UKAB) operational meeting along with a covering letter from MHRA. To add onto the agenda to provide a ‘verbal update’ during the meeting itself. By: To be confirmed – next meeting date has not been set, expected December 2023/January 2024. Resources in place: UKAB Operational meetings are standing meetings that occur approximately once per quarter. Additional comments: Meeting has both designated and applicant Approved Bodies (AB).
- Surveillance strategy for each designated AB to be updated to note that where relevant, client files reviewed must show that the consideration to the usability of devices has been reviewed, by end of November 2023. Additional comments: Documentation to be amended to include this as a standing item the audit team should cover. This is reviewed by the lead auditor ahead of each surveillance audit. Client files reviewed on a sampling basis and these audits are conducted annually.
- Update the AB team’s Standard Operating Procedure (SOP) to reflect the processes implemented based of this recommendation, by end of Quarter 4 2023. Resources in place: Will need to consider timing of change to SOP to align with review of existing SOPs. Additional comments: AB team would have to review the changes before the document is finalised.
Response received on 13 November 2023.
Medicines and Healthcare products Regulatory Agency
HSIB recommends that the Medicines and Healthcare products Regulatory Agency publishes guidance on the labelling and packaging of medical devices, to promote best practice and reduce selection of the incorrect item.
We have considered HSIB’s investigation report relating to the selection and insertion of vascular grafts in haemodialysis patients and noted the specific recommendations made to us. We agree that publishing MHRA guidance on the labelling and packaging of medical devices will promote best practice.
We are currently on track to introduce new regulations that will allow reform of the current requirements for labelling and instructions for use as part of the new UK Medical Devices Regulation by July 2025. The regulatory changes will be accompanied by guidance to support the MedTech sector in the interpretation of the new requirements. The new regulatory framework will ensure increased scrutiny on the packaging and labelling of implantable medical devices prior to UK marketing. Furthermore, post-marketing monitoring of the safety of implantable devices will be further improved through implementation of the upcoming Statutory Instrument on Post-Market Surveillance of Medical Devices in autumn 2024.
Action planned to deliver safety recommendation:
- Publish MHRA guidance on the labelling and packaging of medical devices by July 2025.
Response received on 13 November 2023.