Lab accreditation for water testing?

[Michael Wishart]

Hi all

Have a question. Like many of us, we have been microbiologically testing rinse waters from endoscopes and automated endoscope reprocesors (AERs) as per the GENCA/GESA guidelines for many years, via our human pathology testing lab. The lab has always maintained that it does these tests for us as a ‘favour’ (although we do pay… 🙂 ), as they are not NATA accredited to perform environmental testing, and that is what these tests actually are.

Now that the final advisory for AS/NZS4187:2014 has been released from the ASCQHC, and there is a definite requirement to perform water testing for these AERs by December 2021, we also have to consider endotoxin testing (which our human pathology lab does not do), and possibly some chemical purity tests (dependent upon AER manufacturer advice). Now we should probably consider whether all of the final rinse water testing should be done by a lab accredited by NATA for this purpose (eg an environmental testing lab), despite some of the components of testing are already being done by our human pathology lab.

AS/NZS4187: 2014 amendment 2:2019 has the following tests required for final rinse water in AERs:

Total viable count 10 cfu/100 mL
Pseudomonas aeruginosa Not detected/100 mL
(Atypical) Mycobacterium sp Not detected/ 100 mL
Chemical purity (as per manufacturer)
Endotoxin 30 EU/mL

Of those, we already routinely perform the first three with our human pathology testing accredited lab. Not sure what methods they currently use (the standard is very specific), so would need to check that as well.

So, the question becomes: should we send ALL of our final rinse water specimens to an environmental testing accredited lab? Does anyone know if the NSQHS Standards accreditors will care which lab does what test, or they will look at the specific of the accreditation of the lab doing the testing, to measure compliance to this requirement of AS/NZS4187:2014?

This is not an issue in CSSD as our human pathology lab has always declined to process those water samples, so we already have an environmental lab processing those specimens.

Any thoughts or discussion would be valued. Am I being too pedantic about this, and no-one will care provided we get water tested?

Thanks
Michael

Michael Wishart | Infection Control Coordinator, CICP-E

St Vincent’s Private Hospital Northside | 627 Rode Road CHERMSIDE QLD 4032
T +61 7 3326 3068 | F +61 7 3607 2226
E michael.wishart@svha.org.au |
W https://www.svphn.org.au

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[Thomson, Rachel EA (THS)]

Hi Michael,

In response to your questions;

The question becomes: should we send ALL of our final rinse water specimens to an environmental testing accredited lab?

* We have changed our processes and hare now sending all of our specimens to a NATA approved laboratory

Does anyone know if the NSQHS Standards accreditors will care which lab does what test, or they will look at the specific of the accreditation of the lab doing the testing, to measure compliance to this requirement of AS/NZS4187:2014

* Uncertain of this, but our laboratory has recommended that we undertake all testing through a NATA certified laboratory.

Kind regards
Rachel

……………………………………………………………………………..
Rachel Thomson
Nurse Unit Manager

Infection Prevention & Control Unit
Royal Hobart Hospital
Tasmanian Health Organisation-South

*: 03 6166 7882/ 6166 8658

Level 4, H Block
48 Liverpool Street
Hobart, 7000

Hi all

Have a question. Like many of us, we have been microbiologically testing rinse waters from endoscopes and automated endoscope reprocesors (AERs) as per the GENCA/GESA guidelines for many years, via our human pathology testing lab. The lab has always maintained that it does these tests for us as a ‘favour’ (although we do pay… 🙂 ), as they are not NATA accredited to perform environmental testing, and that is what these tests actually are.

Now that the final advisory for AS/NZS4187:2014 has been released from the ASCQHC, and there is a definite requirement to perform water testing for these AERs by December 2021, we also have to consider endotoxin testing (which our human pathology lab does not do), and possibly some chemical purity tests (dependent upon AER manufacturer advice). Now we should probably consider whether all of the final rinse water testing should be done by a lab accredited by NATA for this purpose (eg an environmental testing lab), despite some of the components of testing are already being done by our human pathology lab.

AS/NZS4187: 2014 amendment 2:2019 has the following tests required for final rinse water in AERs:

Total viable count 10 cfu/100 mL
Pseudomonas aeruginosa Not detected/100 mL
(Atypical) Mycobacterium sp Not detected/ 100 mL
Chemical purity (as per manufacturer)
Endotoxin 30 EU/mL

Of those, we already routinely perform the first three with our human pathology testing accredited lab. Not sure what methods they currently use (the standard is very specific), so would need to check that as well.

So, the question becomes: should we send ALL of our final rinse water specimens to an environmental testing accredited lab? Does anyone know if the NSQHS Standards accreditors will care which lab does what test, or they will look at the specific of the accreditation of the lab doing the testing, to measure compliance to this requirement of AS/NZS4187:2014?

This is not an issue in CSSD as our human pathology lab has always declined to process those water samples, so we already have an environmental lab processing those specimens.

Any thoughts or discussion would be valued. Am I being too pedantic about this, and no-one will care provided we get water tested?

Thanks
Michael

Michael Wishart | Infection Control Coordinator, CICP-E

St Vincent’s Private Hospital Northside | 627 Rode Road CHERMSIDE QLD 4032
T +61 7 3326 3068 | F +61 7 3607 2226
E michael.wishart@svha.org.au |
W https://www.svphn.org.au

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[Anonymous]

Michael,

I agree, I don’t think you are being pedantic at all. Normally everything is fine until there is a problem, i.e., you get an unexpected result. Then starts the usual cascade of events where you try to figure out why you have the result that you do. Is it a collection error, a testing error or and is it real?

If you are not dealing with an accredited lab, this is going to make it challenging to progress. Another issue that I have recently come across, is that it is not only an accredited lab that matters, but also that the test performed is NATA accredited as well AND to the standard specified.

My recent experience is with the requirement for Atypical mycobacteria testing or NTM. There are not many labs that actually perform this test as per the recommended methodology set out in ISO 15883-4 (see Annex E for detail). The water samples were sent to an accredited Environmental Laboratory, however as I was reviewing the results, I happened to read the fine print of the report and discovered that this was not a NATA accredited test. Then when we got a positive result, it became “challenging” to know what action to take, as there is always pressure to continue to use the equipment.

As a side point, because the decision usually on which lab to use is often a financial one, I recently received some great advice. If you are going to use a lab that is not accredited, then ensure that it is documented in your organisations risk register. I would also include actions to take when you do have a positive result.

Have a great day and good-luck.

Mandy Davidson
RN; GCert Inf Pre & Cont; MPHTM; Cert III Sterilisation; Cert IV TAE; Immunisation cred; CICP-A
Clinical Nurse Consultant – 4187 Implementation project
Infection Prevention & Control

[cid:image001.png@01D3A192.E1513890]
T
07 4433 1873 | 0402 987 432
E
Mandy.Davidson@health.qld.gov.au
W
http://www.health.qld.gov.au/townsville

Townsville Hospital and Health Service
100 Angus Smith Drive, Douglas, QLD 4814
[Facebook-Icon] [Twitter-Icon] [Linkedin-Icon]
Townsville Hospital and Health Service acknowledges the Traditional Owners of the land, and pays respect to Elders past, present and future.

Hi all

Have a question. Like many of us, we have been microbiologically testing rinse waters from endoscopes and automated endoscope reprocesors (AERs) as per the GENCA/GESA guidelines for many years, via our human pathology testing lab. The lab has always maintained that it does these tests for us as a ‘favour’ (although we do pay… 🙂 ), as they are not NATA accredited to perform environmental testing, and that is what these tests actually are.

Now that the final advisory for AS/NZS4187:2014 has been released from the ASCQHC, and there is a definite requirement to perform water testing for these AERs by December 2021, we also have to consider endotoxin testing (which our human pathology lab does not do), and possibly some chemical purity tests (dependent upon AER manufacturer advice). Now we should probably consider whether all of the final rinse water testing should be done by a lab accredited by NATA for this purpose (eg an environmental testing lab), despite some of the components of testing are already being done by our human pathology lab.

AS/NZS4187: 2014 amendment 2:2019 has the following tests required for final rinse water in AERs:

Total viable count 10 cfu/100 mL
Pseudomonas aeruginosa Not detected/100 mL
(Atypical) Mycobacterium sp Not detected/ 100 mL
Chemical purity (as per manufacturer)
Endotoxin 30 EU/mL

Of those, we already routinely perform the first three with our human pathology testing accredited lab. Not sure what methods they currently use (the standard is very specific), so would need to check that as well.

So, the question becomes: should we send ALL of our final rinse water specimens to an environmental testing accredited lab? Does anyone know if the NSQHS Standards accreditors will care which lab does what test, or they will look at the specific of the accreditation of the lab doing the testing, to measure compliance to this requirement of AS/NZS4187:2014?

This is not an issue in CSSD as our human pathology lab has always declined to process those water samples, so we already have an environmental lab processing those specimens.

Any thoughts or discussion would be valued. Am I being too pedantic about this, and no-one will care provided we get water tested?

Thanks
Michael

Michael Wishart | Infection Control Coordinator, CICP-E

St Vincent’s Private Hospital Northside | 627 Rode Road CHERMSIDE QLD 4032
T +61 7 3326 3068 | F +61 7 3607 2226
E michael.wishart@svha.org.au |
W https://www.svphn.org.au

[cid:image001.jpg@01D46C86.4CDB6090]
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[Donna Cameron]

[Michael Wishart]

[Posted on behalf of Dr Robson, with thanks – Moderator]

Hi Michael et al
Thought I would pass on that there is limited NATA accreditation available for Human Pathology labs in the environmental testing arena (see page 10 of 15 in the SoA).
For example our lab has NATA accreditation for environmental testing as below. It does not however fulfil all the requirements of AS/NZS4187:2014 (endotoxin testing).

[cid:image001.png@01D5C475.8F43A350]

Additionally the ACQSHC and MTAC recommendations for Heater Cooler Unit mycobacterial testing (but not hetertrophic bacterial counts) can only be performed in Human Pathology Clinical Lab. The culture requirements for non-rapidly growing mycobacteria (e.g chimera) cannot usually be performed in environmental testing laboratories.

Currently there is an RCPAQAP module available for Human pathology laboratory laboratories to perform endoscope testing and moves afoot to also possibly introduce a QAP for Mycobacterial testing to satisfy heater cooler unit requirements. To have NATA accreditation for a particular test the laboratory is required to be enrolled in a formal QAP programme or if not available a laboratory exchange programme.

Kind regards
Dr Jenny Robson
Sullivan Nicolaides Pathology

Michael,

I agree, I don’t think you are being pedantic at all. Normally everything is fine until there is a problem, i.e., you get an unexpected result. Then starts the usual cascade of events where you try to figure out why you have the result that you do. Is it a collection error, a testing error or and is it real?

If you are not dealing with an accredited lab, this is going to make it challenging to progress. Another issue that I have recently come across, is that it is not only an accredited lab that matters, but also that the test performed is NATA accredited as well AND to the standard specified.

My recent experience is with the requirement for Atypical mycobacteria testing or NTM. There are not many labs that actually perform this test as per the recommended methodology set out in ISO 15883-4 (see Annex E for detail). The water samples were sent to an accredited Environmental Laboratory, however as I was reviewing the results, I happened to read the fine print of the report and discovered that this was not a NATA accredited test. Then when we got a positive result, it became “challenging” to know what action to take, as there is always pressure to continue to use the equipment.

As a side point, because the decision usually on which lab to use is often a financial one, I recently received some great advice. If you are going to use a lab that is not accredited, then ensure that it is documented in your organisations risk register. I would also include actions to take when you do have a positive result.

Have a great day and good-luck.

Mandy Davidson
RN; GCert Inf Pre & Cont; MPHTM; Cert III Sterilisation; Cert IV TAE; Immunisation cred; CICP-A
Clinical Nurse Consultant – 4187 Implementation project
Infection Prevention & Control

[cid:image001.png@01D3A192.E1513890]
T
07 4433 1873 | 0402 987 432
E
Mandy.Davidson@health.qld.gov.au
W
http://www.health.qld.gov.au/townsville

Townsville Hospital and Health Service
100 Angus Smith Drive, Douglas, QLD 4814
[Facebook-Icon] [Twitter-Icon] [Linkedin-Icon]
Townsville Hospital and Health Service acknowledges the Traditional Owners of the land, and pays respect to Elders past, present and future.

Hi all

Have a question. Like many of us, we have been microbiologically testing rinse waters from endoscopes and automated endoscope reprocesors (AERs) as per the GENCA/GESA guidelines for many years, via our human pathology testing lab. The lab has always maintained that it does these tests for us as a ‘favour’ (although we do pay… 🙂 ), as they are not NATA accredited to perform environmental testing, and that is what these tests actually are.

Now that the final advisory for AS/NZS4187:2014 has been released from the ASCQHC, and there is a definite requirement to perform water testing for these AERs by December 2021, we also have to consider endotoxin testing (which our human pathology lab does not do), and possibly some chemical purity tests (dependent upon AER manufacturer advice). Now we should probably consider whether all of the final rinse water testing should be done by a lab accredited by NATA for this purpose (eg an environmental testing lab), despite some of the components of testing are already being done by our human pathology lab.

AS/NZS4187: 2014 amendment 2:2019 has the following tests required for final rinse water in AERs:

Total viable count 10 cfu/100 mL
Pseudomonas aeruginosa Not detected/100 mL
(Atypical) Mycobacterium sp Not detected/ 100 mL
Chemical purity (as per manufacturer)
Endotoxin 30 EU/mL

Of those, we already routinely perform the first three with our human pathology testing accredited lab. Not sure what methods they currently use (the standard is very specific), so would need to check that as well.

So, the question becomes: should we send ALL of our final rinse water specimens to an environmental testing accredited lab? Does anyone know if the NSQHS Standards accreditors will care which lab does what test, or they will look at the specific of the accreditation of the lab doing the testing, to measure compliance to this requirement of AS/NZS4187:2014?

This is not an issue in CSSD as our human pathology lab has always declined to process those water samples, so we already have an environmental lab processing those specimens.

Any thoughts or discussion would be valued. Am I being too pedantic about this, and no-one will care provided we get water tested?

Thanks
Michael

Michael Wishart | Infection Control Coordinator, CICP-E

St Vincent’s Private Hospital Northside | 627 Rode Road CHERMSIDE QLD 4032
T +61 7 3326 3068 | F +61 7 3607 2226
E michael.wishart@svha.org.au |
W https://www.svphn.org.au

[cid:image001.jpg@01D46C86.4CDB6090]
[2019 conference email signature]

______________________________________________________________________

______________________________________________________________________
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MESSAGES POSTED TO THIS LIST ARE SOLELY THE OPINION OF THE AUTHOR, AND DO NOT REPRESENT THE OPINION OF ACIPC.

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[Mona Schousboe]

I agree with Jenny Robson that the issue of environmental testing is not
black or white. For testing of endoscopes, there are good and regularly
updated guidelines. What was the history behind the requirements for
endotoxin testing, and what was the research into the general availability
of the test? While mycobacterial testing already is concentrated in
specialist TB laboratories, atypical mycobacteria like *M marinum *is
isolated on the general microbiology benches. Research into new pathogens
like was required for Heater-Cooler Units water analyses was performed in
TB laboratories, not in environmental laboratories. We have not even
touched on the problems of organisms resistant to metals such as copper. We
found the M chimaera was isolated from a Heater-Cooler Unit sample with a
very high concentration of copper. We started environment testing for
legionella pneumophila in hospital hot water systems in the 1980es- and
published results many times. The requirements for environmental testing
accreditation, with the associated high cost, was not because we could not
culture for environmental * Legionella, *but because of IANZ (the NZ
equivalent of NATA) require different programmes for water testing than the
direct human specimen. They have no plan for swabs from showerheads. I
wonder if the accreditation authorities should be more conscious of the
cost of accreditation and become more versatile in the programmes they
offer to Microbiology Laboratories.
Kind regards
Mona Schousboe
FRCPA, MPH
Christchurch

On Mon, Jan 6, 2020 at 12:55 PM Michael Wishart
wrote:

> [Posted on behalf of Dr Robson, with thanks Moderator]
>
>
>
> Hi Michael et al
>
> Thought I would pass on that there is limited NATA accreditation available
> for Human Pathology labs in the environmental testing arena (see page 10 of
> 15 in the SoA).
>
> For example our lab has NATA accreditation for environmental testing as
> below. It does not however fulfil all the requirements of AS/NZS4187:2014
> (endotoxin testing).
>
>
>
>
>
> Additionally the ACQSHC and MTAC recommendations for Heater Cooler Unit
> mycobacterial testing (but not hetertrophic bacterial counts) can only be
> performed in Human Pathology Clinical Lab. The culture requirements for
> non-rapidly growing mycobacteria (e.g chimera) cannot usually be performed
> in environmental testing laboratories.
>
>
>
> Currently there is an RCPAQAP module available for Human pathology
> laboratory laboratories to perform endoscope testing and moves afoot to
> also possibly introduce a QAP for Mycobacterial testing to satisfy heater
> cooler unit requirements. To have NATA accreditation for a particular test
> the laboratory is required to be enrolled in a formal QAP programme or if
> not available a laboratory exchange programme.
>
>
>
> Kind regards
>
> Dr Jenny Robson
>
> Sullivan Nicolaides Pathology
>
> *From:* ACIPC Infexion Connexion [mailto:ACIPCLIST@ACIPC.ORG.AU
> ] *On Behalf Of *Mandy Davidson
> *Sent:* Monday, 6 January 2020 8:14 AM
> *To:* ACIPCLIST@ACIPC.ORG.AU
> *Subject:* [External] Re: [ACIPC_Infexion_Connexion] Lab accreditation
> for water testing?
>
>
>
> Michael,
>
>
>
> I agree, I dont think you are being pedantic at all. Normally everything
> is fine until there is a problem, i.e., you get an unexpected result. Then
> starts the usual cascade of events where you try to figure out why you have
> the result that you do. Is it a collection error, a testing error or and
> is it real?
>
>
>
> If you are not dealing with an accredited lab, this is going to make it
> challenging to progress. Another issue that I have recently come across, is
> that it is not only an accredited lab that matters, but also that the test
> performed is NATA accredited as well AND to the standard specified.
>
>
>
> My recent experience is with the requirement for Atypical mycobacteria
> testing or NTM. There are not many labs that actually perform this test as
> per the recommended methodology set out in ISO 15883-4 (see Annex E for
> detail). The water samples were sent to an accredited Environmental
> Laboratory, however as I was reviewing the results, I happened to read the
> fine print of the report and discovered that this was not a NATA accredited
> test. Then when we got a positive result, it became challenging to know
> what action to take, as there is always pressure to continue to use the
> equipment.
>
>
>
> As a side point, because the decision usually on which lab to use is often
> a financial one, I recently received some great advice. If you are going to
> use a lab that is not accredited, then ensure that it is documented in your
> organisations risk register. I would also include actions to take when you
> do have a positive result.
>
>
>
> Have a great day and good-luck.
>
>
>
> *Mandy Davidson*
>
> *RN; GCert Inf Pre & Cont; MPHTM; Cert III Sterilisation; Cert IV TAE;
> Immunisation cred; CICP-A*
>
> Clinical Nurse Consultant 4187 Implementation project
>
> Infection Prevention & Control
>
>
>
> [image: cid:image001.png@01D3A192.E1513890]
>
> *T*
>
> *07 4433 1873* | *0402 987 432*
>
> *E*
>
> Mandy.Davidson@health.qld.gov.au
>
> *W*
>
> http://www.health.qld.gov.au/townsville
>
>
>
>
>
> *Townsville Hospital and Health Service*
>
> 100 Angus Smith Drive, Douglas, QLD 4814
>
> *[image: Facebook-Icon]*
>
> *[image: Twitter-Icon]*
>
> *[image: Linkedin-Icon]*
>
>
> *Townsville Hospital and Health Service acknowledges the Traditional
> Owners of the land, and pays respect to Elders past, present and future.*
>
>
>
>
>
> *From:* ACIPC Infexion Connexion *On Behalf Of *Michael
> Wishart
> *Sent:* Thursday, 19 December 2019 11:51 AM
> *To:* ACIPCLIST@ACIPC.ORG.AU
> *Subject:* [ACIPC_Infexion_Connexion] Lab accreditation for water testing?
>
>
>
> Hi all
>
>
>
> Have a question. Like many of us, we have been microbiologically testing
> rinse waters from endoscopes and automated endoscope reprocesors (AERs) as
> per the GENCA/GESA guidelines for many years, via our human pathology
> testing lab. The lab has always maintained that it does these tests for us
> as a favour (although we do pay J ), as they are not NATA accredited
> to perform environmental testing, and that is what these tests actually are.
>
>
>
> Now that the final advisory for AS/NZS4187:2014 has been released from the
> ASCQHC, and there is a definite requirement to perform water testing for
> these AERs by December 2021, we also have to consider endotoxin testing
> (which our human pathology lab does not do), and possibly some chemical
> purity tests (dependent upon AER manufacturer advice). Now we should
> probably consider whether all of the final rinse water testing should be
> done by a lab accredited by NATA for this purpose (eg an environmental
> testing lab), despite some of the components of testing are already being
> done by our human pathology lab.
>
>
>
> AS/NZS4187: 2014 amendment 2:2019 has the following tests required for
> final rinse water in AERs:
>
>
>
> Total viable count 10 cfu/100 mL
>
> Pseudomonas aeruginosa Not detected/100 mL
>
> (Atypical) Mycobacterium sp Not detected/ 100 mL
>
> Chemical purity (as per manufacturer)
>
> Endotoxin 30 EU/mL
>
>
>
> Of those, we already routinely perform the first three with our human
> pathology testing accredited lab. Not sure what methods they currently use
> (the standard is very specific), so would need to check that as well.
>
>
>
> So, the question becomes: should we send ALL of our final rinse water
> specimens to an environmental testing accredited lab? Does anyone know if
> the NSQHS Standards accreditors will care which lab does what test, or they
> will look at the specific of the accreditation of the lab doing the
> testing, to measure compliance to this requirement of AS/NZS4187:2014?
>
>
>
> This is not an issue in CSSD as our human pathology lab has always
> declined to process those water samples, so we already have an
> environmental lab processing those specimens.
>
>
>
> Any thoughts or discussion would be valued. Am I being too pedantic about
> this, and no-one will care provided we get water tested?
>
>
>
> Thanks
>
> Michael
>
>
>
>
>
> *Michael Wishart *| Infection Control Coordinator, CICP-E
>
>
> St Vincents Private Hospital Northside | 627 Rode Road CHERMSIDE QLD
> 4032
>
> *T *+61 7 3326 3068 |* F* +61 7 3607 2226
>
> *E* michael.wishart@svha.org.au |
>
> *W *https://www.svphn.org.au
>
>
>
>
> [image: cid:image001.jpg@01D46C86.4CDB6090]
>
> [image: 2019 conference email signature]
>
>
>
>
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[Michael Wishart]

Thanks to Jenny Robson and Mona Schousboe for the lab perspective in this. And thanks to all others who have agreed this could be an issue we need to be aware of.

We have two separate types of microbiological testing here, required by two different agencies.

1. Endoscope testing (as a QA activity to ensure cleaning is appropriate) is required by GESA/GENCA Infection Control in Endoscopy 2010 (havent yet seen the draft revision, has anybody?), and includes testing for CRE post use on known CRE patients (as per 2017 consensus guidelines). Endoscope microbiological testing is not mentioned in AS/NZS 4187 per se (only as general part of a review of storage of RMDs I would suggest).

2. Testing of the rinse water for AERs is recommended by both, but GESA/GENCA only refer to microbiological monitoring of rinse water to ensure sterility, whereas AS/NZS 4187 looks at rinse water with regard to its suitability to contact RMDs, not just microbial content (hence the extra testing required), similar to that required in CSSD. I am sure Standards Australia have some good references for the need for endotoxin testing in these environments.

To me, it looks like, as long as your path lab follows appropriate processes for testing (as per the required standards) and is accredited for the type of testing required, it should be fine. It would be prudent to check what tests they are using, and ensure these are as the relevant standard or guideline requires.

Both Jenny and Mona mentioned testing for M. chimaera in cardiac heater-coolers, and this is another example of the difficulties in getting testing done appropriately, as I believe most environmental labs have difficulty isolating M. chimaera specifically.

It would be nice to have some consistency of guidelines for testing in endoscopy, so hopefully the revision of the GESA/GENCA Infection Control in Endoscopy document will help with this, not create even more confusion!

Cheers
Michael

Michael Wishart | Infection Control Coordinator, CICP-E

St Vincents Private Hospital Northside | 627 Rode Road CHERMSIDE QLD 4032
T +61 7 3326 3068 | F +61 7 3607 2226
E michael.wishart@svha.org.au |
W https://www.svphn.org.au

[cid:image001.jpg@01D46C86.4CDB6090]

From: ACIPC Infexion Connexion On Behalf Of Mona Schousboe
Sent: Monday, 6 January 2020 11:52 AM
To: ACIPCLIST@ACIPC.ORG.AU
Subject: Re: [ACIPC_Infexion_Connexion] Lab accreditation for water testing?

I agree with Jenny Robson that the issue of environmental testing is not black or white. For testing of endoscopes, there are good and regularly updated guidelines. What was the history behind the requirements for endotoxin testing, and what was the research into the general availability of the test? While mycobacterial testing already is concentrated in specialist TB laboratories, atypical mycobacteria like M marinum is isolated on the general microbiology benches. Research into new pathogens like was required for Heater-Cooler Units water analyses was performed in TB laboratories, not in environmental laboratories. We have not even touched on the problems of organisms resistant to metals such as copper. We found the M chimaera was isolated from a Heater-Cooler Unit sample with a very high concentration of copper. We started environment testing for legionella pneumophila in hospital hot water systems in the 1980es- and published results many times. The requirements for environmental testing accreditation, with the associated high cost, was not because we could not culture for environmental Legionella, but because of IANZ (the NZ equivalent of NATA) require different programmes for water testing than the direct human specimen. They have no plan for swabs from showerheads. I wonder if the accreditation authorities should be more conscious of the cost of accreditation and become more versatile in the programmes they offer to Microbiology Laboratories.
Kind regards
Mona Schousboe
FRCPA, MPH
Christchurch

On Mon, Jan 6, 2020 at 12:55 PM Michael Wishart <Michael.Wishart@svha.org.au> wrote:
[Posted on behalf of Dr Robson, with thanks Moderator]

Hi Michael et al
Thought I would pass on that there is limited NATA accreditation available for Human Pathology labs in the environmental testing arena (see page 10 of 15 in the SoA).
For example our lab has NATA accreditation for environmental testing as below. It does not however fulfil all the requirements of AS/NZS4187:2014 (endotoxin testing).

Additionally the ACQSHC and MTAC recommendations for Heater Cooler Unit mycobacterial testing (but not hetertrophic bacterial counts) can only be performed in Human Pathology Clinical Lab. The culture requirements for non-rapidly growing mycobacteria (e.g chimera) cannot usually be performed in environmental testing laboratories.

Currently there is an RCPAQAP module available for Human pathology laboratory laboratories to perform endoscope testing and moves afoot to also possibly introduce a QAP for Mycobacterial testing to satisfy heater cooler unit requirements. To have NATA accreditation for a particular test the laboratory is required to be enrolled in a formal QAP programme or if not available a laboratory exchange programme.

Kind regards
Dr Jenny Robson
Sullivan Nicolaides Pathology
From: ACIPC Infexion Connexion [mailto:ACIPCLIST@ACIPC.ORG.AU] On Behalf Of Mandy Davidson
Sent: Monday, 6 January 2020 8:14 AM
To: ACIPCLIST@ACIPC.ORG.AU
Subject: [External] Re: [ACIPC_Infexion_Connexion] Lab accreditation for water testing?

Michael,

I agree, I dont think you are being pedantic at all. Normally everything is fine until there is a problem, i.e., you get an unexpected result. Then starts the usual cascade of events where you try to figure out why you have the result that you do. Is it a collection error, a testing error or and is it real?

If you are not dealing with an accredited lab, this is going to make it challenging to progress. Another issue that I have recently come across, is that it is not only an accredited lab that matters, but also that the test performed is NATA accredited as well AND to the standard specified.

My recent experience is with the requirement for Atypical mycobacteria testing or NTM. There are not many labs that actually perform this test as per the recommended methodology set out in ISO 15883-4 (see Annex E for detail). The water samples were sent to an accredited Environmental Laboratory, however as I was reviewing the results, I happened to read the fine print of the report and discovered that this was not a NATA accredited test. Then when we got a positive result, it became challenging to know what action to take, as there is always pressure to continue to use the equipment.

As a side point, because the decision usually on which lab to use is often a financial one, I recently received some great advice. If you are going to use a lab that is not accredited, then ensure that it is documented in your organisations risk register. I would also include actions to take when you do have a positive result.

Have a great day and good-luck.

Mandy Davidson
RN; GCert Inf Pre & Cont; MPHTM; Cert III Sterilisation; Cert IV TAE; Immunisation cred; CICP-A
Clinical Nurse Consultant 4187 Implementation project
Infection Prevention & Control

T
07 4433 1873 | 0402 987 432
E
Mandy.Davidson@health.qld.gov.au
W
http://www.health.qld.gov.au/townsville

Townsville Hospital and Health Service
100 Angus Smith Drive, Douglas, QLD 4814

Townsville Hospital and Health Service acknowledges the Traditional Owners of the land, and pays respect to Elders past, present and future.

From: ACIPC Infexion Connexion On Behalf Of Michael Wishart
Sent: Thursday, 19 December 2019 11:51 AM
To: ACIPCLIST@ACIPC.ORG.AU
Subject: [ACIPC_Infexion_Connexion] Lab accreditation for water testing?

Hi all

Have a question. Like many of us, we have been microbiologically testing rinse waters from endoscopes and automated endoscope reprocesors (AERs) as per the GENCA/GESA guidelines for many years, via our human pathology testing lab. The lab has always maintained that it does these tests for us as a favour (although we do pay ), as they are not NATA accredited to perform environmental testing, and that is what these tests actually are.

Now that the final advisory for AS/NZS4187:2014 has been released from the ASCQHC, and there is a definite requirement to perform water testing for these AERs by December 2021, we also have to consider endotoxin testing (which our human pathology lab does not do), and possibly some chemical purity tests (dependent upon AER manufacturer advice). Now we should probably consider whether all of the final rinse water testing should be done by a lab accredited by NATA for this purpose (eg an environmental testing lab), despite some of the components of testing are already being done by our human pathology lab.

AS/NZS4187: 2014 amendment 2:2019 has the following tests required for final rinse water in AERs:

Total viable count 10 cfu/100 mL
Pseudomonas aeruginosa Not detected/100 mL
(Atypical) Mycobacterium sp Not detected/ 100 mL
Chemical purity (as per manufacturer)
Endotoxin 30 EU/mL

Of those, we already routinely perform the first three with our human pathology testing accredited lab. Not sure what methods they currently use (the standard is very specific), so would need to check that as well.

So, the question becomes: should we send ALL of our final rinse water specimens to an environmental testing accredited lab? Does anyone know if the NSQHS Standards accreditors will care which lab does what test, or they will look at the specific of the accreditation of the lab doing the testing, to measure compliance to this requirement of AS/NZS4187:2014?

This is not an issue in CSSD as our human pathology lab has always declined to process those water samples, so we already have an environmental lab processing those specimens.

Any thoughts or discussion would be valued. Am I being too pedantic about this, and no-one will care provided we get water tested?

Thanks
Michael

Michael Wishart | Infection Control Coordinator, CICP-E

St Vincents Private Hospital Northside | 627 Rode Road CHERMSIDE QLD 4032
T +61 7 3326 3068 | F +61 7 3607 2226
E michael.wishart@svha.org.au |
W https://www.svphn.org.au

______________________________________________________________________

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[Morris, Sylvia (Health)]

[Karen Vickery]

HI Michael,
Re repeated sterilisation of orthopaedic screws. Could you please forward on that soil accumulation and biofilm formation is also a risk. Please see the sem in attached paper. Figure 4

Regards
Karen Vickery BVSc, MVSc, PhD
Macquarie University
Karen.vickery@mq.edu.au

Hi all

Have a question. Like many of us, we have been microbiologically testing rinse waters from endoscopes and automated endoscope reprocesors (AERs) as per the GENCA/GESA guidelines for many years, via our human pathology testing lab. The lab has always maintained that it does these tests for us as a ‘favour’ (although we do pay… 🙂 ), as they are not NATA accredited to perform environmental testing, and that is what these tests actually are.

Now that the final advisory for AS/NZS4187:2014 has been released from the ASCQHC, and there is a definite requirement to perform water testing for these AERs by December 2021, we also have to consider endotoxin testing (which our human pathology lab does not do), and possibly some chemical purity tests (dependent upon AER manufacturer advice). Now we should probably consider whether all of the final rinse water testing should be done by a lab accredited by NATA for this purpose (eg an environmental testing lab), despite some of the components of testing are already being done by our human pathology lab.

AS/NZS4187: 2014 amendment 2:2019 has the following tests required for final rinse water in AERs:

Total viable count 10 cfu/100 mL
Pseudomonas aeruginosa Not detected/100 mL
(Atypical) Mycobacterium sp Not detected/ 100 mL
Chemical purity (as per manufacturer)
Endotoxin 30 EU/mL

Of those, we already routinely perform the first three with our human pathology testing accredited lab. Not sure what methods they currently use (the standard is very specific), so would need to check that as well.

So, the question becomes: should we send ALL of our final rinse water specimens to an environmental testing accredited lab? Does anyone know if the NSQHS Standards accreditors will care which lab does what test, or they will look at the specific of the accreditation of the lab doing the testing, to measure compliance to this requirement of AS/NZS4187:2014?

This is not an issue in CSSD as our human pathology lab has always declined to process those water samples, so we already have an environmental lab processing those specimens.

Any thoughts or discussion would be valued. Am I being too pedantic about this, and no-one will care provided we get water tested?

Thanks
Michael

Michael Wishart | Infection Control Coordinator, CICP-E

St Vincent’s Private Hospital Northside | 627 Rode Road CHERMSIDE QLD 4032
T +61 7 3326 3068 | F +61 7 3607 2226
E michael.wishart@svha.org.au |
W https://www.svphn.org.au

[cid:image001.jpg@01D46C86.4CDB6090]
[2019 conference email signature]

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