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.
British Standards Institution (BSI)
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 (MHRA)
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.
Medicines and Healthcare products Regulatory Agency (MHRA)
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.