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Tag No.: A0747
Based on a tour of the facility, staff interviews, review of facility policies and procedures, the facility failed to provide a sanitary environment to prevent the risk of cross contamination, as the facility was in need of cleaning, endoscopes were not stored in a sanitary manner, kitchen equipment was in need of cleaning, food was not labeled, there were expired medications and supplies, dead insects were observed, and policies related to housekeeping and food and nutrition storage were not followed.
Findings included:
During a tour of the facility on 1/21/14 accompanied by the Director of Infection Control and the Director of Patient Safety and Quality, there were infection control infractions and risks observed.
In the OR Suite, the following was observed:
1. In the Gastrointestinal (GI) Procedure room the following observations were made:
The floor in the procedure room had a separation in the seam of approximately 9 feet in length. The floor should be seamed to allow for effective disinfection after procedures to prevent cross contamination.
There was a corrugated shipping box with a shipping label from an endoscopy company on the floor. The floor is considered dirty and this presents a risk for cross contamination. Additionally, external shipping boxes are considered contaminated and should not be in the OR Suite.
In the area for scope cleaning the following issues were identified:
· 7 drawers in the area for scope cleaning, containing various supplies, were observed to have visible water stains and damage to the front of the drawers. A black colored substance, mold-like in appearance, was observed in these 7 drawers were the water stains were visible. The presence of water damage/stains indicated the area could be contaminated with bacterial particles due to the moist environment.
· A large blue plastic container/tub labeled "Revital-Ox Resert Disinfectant" for scope cleaning was observed to the left of two sinks, labeled "dirty" and "clean". The lay out for cleaning scope from left to right was: a blue container of "Revital-Ox" disinfectant, "dirty" sink, and "clean" sink. The cabinet for storing scopes was to the right of the "clean" sink. The container labeled "Revital-Ox Resert Disinfectant" was observed to have visible water stains to the entire container. Standing water was observed at the corners of the container. The presence standing water potentially provides a medium for the growth of bacteria and/or development of mold.
· Above the sinks labeled "dirty" and "clean", a paper towel dispenser was observed. Over the top of the paper towel dispenser 2 syringes to flush scopes were observed. Water droplets were visible in in the connector tubes attached to the syringes which are used to flush the scopes and check for air. The presence of water in the tubes a risk for contamination with bacterial particles due to the moist environment.
· A stretcher mattress in the room was observed to have 2 tears to the corners of the mattress, approximately 3 inches in size, revealing a permeable yellow foam substance, which could not be properly cleaned or disinfected.
· There was a two-sided endoscope storage cabinet which contained "cleaned" endoscopes, available for patient use. Three of the endoscopes were hanging with portions of the scopes touching the side of the cabinet. The tips of the three scopes were resting on a towel in the base of the cabinet. The towel on the base of the cabinet was damp to the touch. The sides and the base of the particle board cabinet was deteriorated and the laminate was buckled and peeling away from the particle board due to water damage. There were pieces of particle board in the base of the cabinet. The cabinet hinges and the door handle were rusted. There were greater than 50 black, green, and brown drips (by count) in the interior of the cabinet. This wet area provides a media for the growth of bacteria and creates a risk of cross contamination.
· On top of the scope storage cabinet, there were 2 external shipping boxes with shipping labels adhered. Storing contaminated boxes above endoscopes presents a risk for cross contamination.
· There were dust and drips on a computer stand in the room. There was a sticky tape residue on the cabinet drawer.
· On the KT-1 Endoscopy trolley, there was rust on the shelves and dirty, sticky tape adhered to the cart. Rust cannot be disinfected and presents a risk for cross contamination.
In Operating Room # 2 the following observations were made:
· The surgical stretcher mattress had approximately 10 small tears that were 2mm or less in size. These tears could not be properly cleaned or disinfected.
· Four drawers in the supply cabinet were noted to have visible debris and dust present, indicating ineffective cleaning.
· A .5 inch circumference chip was observed in the flooring, preventing effective cleaning and disinfection.
· An arm board was observed on the floor, which is a risk for cross contamination. There was a 1 x 1 inch tear in the vinyl of the arm board, which prevents effective disinfection.
· In the anesthesia cart the following were observed opened and unlabeled:
o Rocuronium 10 mg/ml
o Glycopyrrolate 1 mg/5ml
· In the second drawer of the anesthesia cart containing 3 ml, 5 ml, and 20 ml syringes and patient airways, there was a thin layer of dust.
· In the fourth drawer of the anesthesia cart containing IV start kits and syringes, there were dust and drips.
· There were several layers of tape and dust on top of the anesthesia cart.
· There was rust on the base of the IV pole; rust cannot be disinfected.
· There was rust and dirty sticky tape residue adhered to the x-ray light box.
There were at least 7 drips in the bottom of the epidural cart in the OR Suite. There was also a rusted can opener in the epidural cart; these present a risk for cross contamination.
There were multiple drips and splashes of a golden/yellow substance on the two walls in the sterile supplies hallway in the OR Suite. There was an area of approximately 8 feet by 3 feet on one wall, and an area of approximately 3 feet x 3 feet on the other wall. The substance was above the shelving and sterile supplies storage. In an interview with the Risk Manager during the tour, she stated that the substance was left over from recent maintenance completed in the ceiling above the sterile supply storage.
In the room labeled "Decontamination Room", the laminate was peeling off of the cabinet doors due to moisture damage. There was a water stain in the wall approximately 14 x 4 inches and paint was peeling off the wall over the water stain.
In the Decontamination Room, there were leg mounts or stirrups hanging on the wall. The vinyl covering over the padding was deteriorated and could not be disinfected. When asked how the stirrups were cleaned, the OR staff stated that they were cleaned using a disinfectant only. This presents a risk of cross contamination, as the padding was exposed and could not be properly disinfected.
In the Labor and Delivery suite hallway, the following was observed:
· In the sink and cabinet area there was dirt and debris under the sink.
· There was dirt and drips in the drawer with IV labels; another drawer with patient supplies had 2 packets of mustard and sugar packets. There was a 6 x 7 inch spill and drips in the base of the third drawer containing patient supplies. The drawer containing tape, alcohol preps and the pulse oximeter was dirty and there were drips in the drawer. The drawer containing baby blankets was dirty and there were yellowish drips in the drawer. This presents a risk for cross contamination.
· Next to a Rubbermaid ice chest was an ice scoop laying uncovered on a damp towel. The bowl of the scoop was turned up, which presents a risk for contamination with dust.
· In a bin on a shelving unit labeled "Circs Gomco" was a 20 ml vial of 1% Lidocaine labeled "discard after 28 days. Exp. Date". The handwritten date was 12-3-13 as observed during the tour on 1/24/13. There was dust on the low horizontal surfaces.
In Labor Room # 1 the following observations were made:
· 2 strips of tape, approximately 3 inches wide, were observed on the inside of the bathroom door. Tape was also observed on the exterior of 2 drawers for patient storage. Tape cannot be effectively cleaned.
· Rust stains were observed around the call light apparatus in the patient bathroom. Rust stains cannot be effectively cleaned or disinfected.
In Labor Room #2 the following observations were made:
· A red stain, blood-like in appearance, was noted to the wall near the bathroom door. The stain was approximately 6 inches long.
· The door to this room had a 7 x3 inch missing portion of laminate. The damage to this door prevents effective cleaning of the surface.
In Labor Room #3 the following observations were made:
· The front of 8 drawers had tape with labels which were dirty and peeling and left a dirty sticky tape residue which was unable to be disinfected.
· The front lip of the 8 drawers were dirty and in need of cleaning.
In the Decontamination Room the following observation was made:
· The base of the lower cabinet (approximately 3 x 2 feet) was damp and the particle board and laminate had disintegrated due to moisture and dampness. The laminate had buckled and the surface was covered with a black substance which appeared to be mold/mildew. This was covered with a blue chux pad, which was also damp and mildewed. The particle board shelf in the cabinet had buckled. There was a large Sonic Styrofoam cup partially full of liquid and a red solo cup with a dark liquid which appeared to be soda inside the cabinet on the shelf. The moist environment, the mildew/mold substance, the buckled and broken cabinet, the opened cup of soda present a risk for cross contamination in an area where surgical instruments are brought to be cleaned and disinfected or sterilized.
· A drawer containing 10 unopened bottles of sodas was observed next to the cabinet with water damage noted.
In the Sterilization Room the following observation was made:
· Dust and debris were visible in the corner of a cabinet storing seal packs for sterilized instruments, indicating ineffective cleaning.
In the Kitchen the following observations were made:
· A blender was observed that according to staff member # 16 was clean and ready for use. The glass component was observed to have water droplets visible on the inside of the container with the lid in place, trapping the water present. The water droplets in the blend present a risk for bacterial growth due to the moist environment.
· A cabinet containing pie crusts was observed to have visible debris present, indicating ineffective cleaning.
· A jug of corn syrup was found with an expiration date of 12/19/12 noted in marker. An open bag of chocolate chips was observed with no date present. An open bag of croissants was observed with no date indicated when opened. Half a loaf of bread with no date indicating when opened.
· A drawer containing utensils such as scissors and strainers had an unidentified white powder present.
· 2 plastic cutting boards ready for patient use were observed stacked on top of each other. Upon inspection the two cutting boards were moist to the touch. This moisture presents a risk for bacterial contamination.
· It was observed that dishware such as bowels and cups are placed upside on cloth towels to finish drying after going through the dishwasher. In an interview, staff member # 16 confirmed this is standard practice in the kitchen area. Drying dishware on cloth towels increases the risk for moisture accumulation, providing growth medium for bacteria.
· In the kitchen refrigerator, there were two plates containing food covered in plastic wrap which were undated, a pie covered in plastic wrap which was undated, and a bag of Oreo cookies which was opened and undated.
· In the dry food storage area, there was a hole which penetrated all the way through the sheetrock approximately 3/4 inch in diameter. This provides an opening for dust and insects.
· There was a dead insect in the ceiling light in the dry food storage area.
· The drawer containing plastic food/condiment cups and lids was dirty with dust and was in need of cleaning.
· The drawer containing condiments, sugar, lemon juice packets, salt and pepper packets was dirty with dust and was in need of cleaning.
· There were drips down the front of the two drawers that contained plastic coffee cups and plastic bowls, available for patient use.
· There was dried food and a water stain in a large (approximately 12 x 24 inch) pan available for use in food preparation.
· There was dried food adhered to a 12 x 8 inch pan available for use in food preparation.
· There was a moist, oily substance and food debris in 4 pans available for use in food preparation.
· There was dried food in three deep pans available for use in food preparation.
· In an under cabinet where the above pans were stored and available for use in food preparation, there was dirt and debris and a fresh pile of wood particles and saw dust, raising concerns about insect infestation.
In the Dining Room/Snack area, the following was observed:
· In the cabinet underneath the sink were old dried French fries, dirt, debris, drips and two dead insects. In this same cabinet were three opened cardboard boxes, of which one contained plastic knives, one contained plastic forks, and one contained plastic spoons, available for use. This presents a risk for cross contamination.
· In the cabinet drawer, there was a dark spill approximately 5 x 12 inches. In this drawer were loose utensils, including 7 plastic forks and 6 plastic knives. The base of the cabinet was dirty.
During the tour of the kitchen on 1/21/14, Staff #16, a food service assistance, was asked for a test strip to determine the concentration of the disinfectant solution in the red sanitizing bucket, available for use in the kitchen. Staff #16 stated they did not have any strips. When asked, she stated that she had been employed in the kitchen for one year. When asked if she had ever been trained in the use of test strips to confirm the level of disinfectant in the solution or if there had ever been test strips in the kitchen available for use, Staff #16 stated she had not been trained and she had never seen test strips in the kitchen since she had worked in the kitchen. Pathogenic microorganisms can survive and contaminate food products if food-contact surfaces are not properly cleaned and sanitized with a sanitizing agent maintained at the proper level.
In the Emergency Department Triage room the following was observed:
· Brown stains were observed in a supply drawer which contained Betadine, indicating ineffective cleaning.
· There was a rolling lamp with a sticky tape residue adhered; the lamp was dirty and in need of cleaning.
· The laundry hamper stand constructed with PVC pipe was dirty and in need of cleaning at the base of the stand.
· There was a dark blue plastic bin with medication cups, soufflé cups and plastic cups and straws, available for patient use, which was in need of cleaning as it was dirty and dusty. There was a dirty sticky partially adhered label attached to the blue bin.
In Emergency Room # 4 a supply drawer contained a packaged 3 ml syringe with a dark red stain, blood-like in appearance, on the outer packaging.
In Emergency Room # 2 the following observations were made:
· A cabinet was observed with water damage stains to the right corner near the hinged area of the door. The rust colored water stain was approximately 6 X 4 inches in size. The presence of water damage indicated the area could be contaminated with bacterial particles due to the moist environment.
· Tape was observed on the left corner of the crash cart and tape was observed on all drawers of the cabinet covering labels indicated the contents of the drawer. Tape cannot be effectively cleaned.
· The door to this room had a missing area of laminate, approximately 7 x 2 inches in size. A piece of tape, 6 X 5 inches was observed toward the bottom of this door. The damage to this door prevents effective cleaning of the surface.
In the Pediatric Emergency Room, the ceiling vent had dust on the vent and there was dust on the ceiling tiles proximal to the vent.
In Emergency Room #3, the following was observed:
· There was dust on the lower horizontal surface of the gurney. There was a reddish-brown raised substance on the wheels which indicated a need for cleaning.
· The cabinet drawers contained dust and wood particles; there were yellow drips on two of the drawer handles.
· There were raised dust fluffs and lint in a metal bucket in the cabinet with the word "Drapes" which contained sterile field drapes.
· There was a pair of rusted vise grips (a hand tool similar to pliers) in the drawer which was rusted on all surfaces.
· There was a laryngoscope blade that was exposed in a drawer; it could not be confirmed that it had been high-level disinfected or sterilized.
In the Emergency Department hallway, there was an x-ray viewer box which had pieces of dirty tape residue. There were multiple drips and tape adhered and was in need of cleaning.
In X-ray Room 1 there was an area of black, sticky tape reside approximately 4 x 2 inches in size, indicating a need for cleaning.
In X-ray Room # 7 the following observations were made:
· 2 boxes of external boxes containing disposable gowns were observed stored on the floor. Patient supplies should not be stored on the floor or in external boxes due to the risks of contamination.
· 1 jar of peanut butter was observed on a shelf in this area, which is used for patient care. Food items should not be stored in patient care areas.
In the CT Scan room, the following was observed:
· There were drips in 3 drawers which contained supplies available for patient use, including 10 ml and 20 ml syringes, alcohol preps, and catheter extender sets.
· There was a spider web on the door and cabinet at the sink.
· There was tape on the ceiling and the ceiling vent was dusty and in need of cleaning.
· There was peeling, dirty tape and sticky tape residue at the patient sign-in desk.
In the Medication room, there were drips on the front of the medication cart and two drawers in the medication cart were in need of cleaning, as they were dirty with dust and drips. There was a 12 inch hole in the base of the cabinet underneath the sink which presents a risk for cross contamination with dust, insects and debris.
There was daylight visible from inside the building between the external double doors on the east side of the building next to the heliport. Airflow was felt between the double doors. This external opening to the building presents a risk for cross contamination for dust, debris, and insects.
In the Chapel, there was a crock with a spigot and a sign labeled "Holy Water." There was water in the crock. When asked, Staff #2 stated that she did not know who was responsible for the holy water and did not know how often it was changed or if/when the container was cleaned. This presents a risk for cross contamination.
The following expired supplies were identified during the tour on 1/21/14:
· In Emergency Room #2, one boxed tracheostomy tube (15 mm) was observed with an expiration date of 10/2013.
· In the Gastrointestinal (GI) Procedure the following expired phlebotomy supplies were observed: 6 blue top tubes with an expiration date of 7/13 and 1 blue top with an expiration date of 12/13. 6 green top tubes with an expiration date of 9/13. 4 orange tops with an expiration date of 1/13.
· In Operating Room # 2 there were 7 E-Swab Collection tubes with an expiration date of 10/13.
· In Labor Room # 1 there were 3 Gen-Probe swabs with expiration date of 12/31/13.
During a tour of the facility the morning of 1/22/14 accompanied by Staff #3, the following was observed:
· In the storage room next to the Outpatient Services Department, there was raised dirt and debris on the floor, especially in the corners. This storage room contained patient supplies, such as IV fluids and was in need of cleaning.
In the pharmacy during the tour on 1/22/14 accompanied by Staff #3, the following was observed:
· There were two cases of Baxter 0.9 NACL fluid which was stored on the floor. This presents a risk for cross contamination.
· There was a cardboard box for expired medications which was broken down and was on the floor. This presents a risk for cross contamination.
· There was a corrugated box which was visibly dirty on the top of a shelving unit containing vials of medications, available for patient use. This presents a risk for cross contamination.
· The carpeting in the pharmacy was dirty. The high use pathways were very dark/dirty and there were spills on the carpeting, indicating a need for cleaning.
The Centers for Disease Control and Prevention (CDC) article, Guidelines for Environmental Infection Control in Health-Care Facilities (2003), by Sehulster LM, Chinn RYW, Arduino MJ, Carpenter J, Donlan R, Ashford D, Besser R, Fields B, McNeil MM, Whitney C, Wong S, Juranek D, Cleveland J., the Healthcare Infection Control Practices Advisory Committee (HICPAC); and the Chicago IL American Society for Healthcare Engineering/American Hospital Association, found at:
The same article also states on page 48 that gram negative bacteria is a pathogen associated with Holy Water and the use should be minimized among immunocompromised patients.
Review of the Job Description for the Food Service Supervisor stated, in part, "Enforces proper sanitation standards for Food Service areas and workers."
Review of the "Competencies for Dietary Employees" signed on 11/11/13 by Staff #8, Dietary Manager, stated, in part, "Provides an environment conducive to protecting the health and wellness of the patients and employees through high levels of sanitation standards ...Understands basic principles of food service sanitation for equipment, personnel, food, and facility ...Maintains a practice of handling clean and sanitized equipment and utensils to protect them from contamination ...Maintains storage cleanliness and sanitation in accordance with good housekeeping practices and sanitation guidelines ...Has firm understanding of infection control precautions ...Stores cleaning cloths in sanitizing solution ...Practices sanitary and safe refrigerator/freezer storage ...Wraps, dates, and labels all food properly ...Practices sanitary and safe dry storage ...Clears area of debris, and keeps area clean ..."
Review of facility policy entitled, "Cleaning Pots, Pans, and Utensils", revision date 11/30/08, stated, in part, "All pots, pans and utensils will be cleaned according to acceptable guidelines for food service sanitation. Procedures: ...Let washed items air dry before putting away."
Review of facility policy entitled, "Operation, Sanitation and Maintenance of Equipment and Work Areas" for the Food and Nutritional Services Department, revised 12/08, stated, in part, "Sanitize with sanitizing solution (1oz. Oasis 146 Multi-Quat Sanitizer to 1 gallon water)."
Review of facility policy entitled, "Food Storage", revision date 12/08, stated, in part, "2. Canned and dry good items are stored in a well-ventilated storeroom, away from possible contamination by moisture, wastewater backflow, rodents or vermin ...Cold Storage ...3. Pre-prepared leftover items are to be wrapped or covered, dated and labeled before refrigerating or freezing ..."
Review of facility policy entitled, "Housekeeping Scheduling" last revision 05/28/09, stated, in part, "OB Department: Disinfect horizontal and vertical surfaces ...ER Rooms: Disinfect horizontal & vertical surfaces & sinks ..."
Review of facility policy entitled, "Emergency Room Cleaning" last revision 05/28/09, stated, in part, "ER will be cleaned daily and as needed following patient usage..."
Review of facility policy entitled, "Environmental Cleaning in Perioperative Areas" revised date 4/3/2014, stated, in part, "8. Environmental cleaning and disinfection is a cross-functional effort involving both perioperative and environmental services staff ..."
Review of facility policy entitled, "Pest Control" revision dated 11/30/08 stated, in part, "The FANS [Food and Nutrition Services] Department shall be kept free of pests and rodents that are vehicles of transmission ...If an infestation of insects of rodents is discovered, the exterminator is called immediately."
The above findings were confirmed in an interview with the Director of Quality and Patient Safety the afternoon of 1/22/14 in the facility conference room.
Tag No.: A0118
Based on a review of facility documentation, facility policy, and staff interview, the facility failed to inform patients and/or the patient's representative of the phone number and address for lodging a grievance with the State agency, the Texas Department of State Health Services.
Findings included:
Review of the document provided to the surveyors on 1/21/14 entitled "Patient Rights & Responsibilities", there was no documented evidence that the patient or the patient's representative was notified of right to contact the state agency, which is the Texas Department of State Health Services. Complaints should be directed to the Department of State Health Services, Manager, Health Facility Compliance Group, Post Office Box 149347, Austin, Texas 78714-9347, (888) 973- 0022.
A handout was provided to the surveyors on 1/21/14 entitled, "Scott & White Healthcare Llano" which was described as the information given to patients on admission. Review of the handout provided to the surveyors revealed no documented evidence that the patient or the patient's representative was notified of right to contact the state agency, which is the Texas Department of State Health Services. Complaints should be directed to the Department of State Health Services, Manager, Health Facility Compliance Group, Post Office Box 149347, Austin, Texas 78714-9347, (888) 973- 0022.
Review of facility policy entitled, "Patient Grievance" revision date, 7/13/10, stated, in part, "8. Upon admission, the patient will be notified of this grievance process as well as informed of the right to file a complaint with the Texas Department of Health directly at any time at 1-888-973-0022."
The above findings were confirmed in an interview the afternoon of 1/22/14 in the facility conference room with the Director of Patient Safety and Quality.
Tag No.: A0951
Based on a review of facility policies, staff interview, and facility tour, the facility failed to ensure that surgical services policies were consistent to maintain a high standard of practice and patient care.
Findings were:
During a tour of the facility on 01/21/12 , in Operating Room # 2, the following was observed:
4 clamps, hemostats and other surgical instruments were observed in the closed position and the clamps were locked and closed; therefore not all surfaces were exposed to the sterilizing agent preventing effective sterilization. It could not be determined that the sterilizing agent penetrated all surfaces to ensure completed sterilization of all surfaces of the instruments. These instruments were available for patient use.
The Centers for Disease Control and Prevention (CDC) article, GUIDELINE FOR DISINFECTION AND STERILIZATION IN HEALTHCARE FACILITIES, 2008, by William A. Rutala, Ph.D., M.P.H., David J. Weber, M.D., M.P.H., and the Healthcare Infection Control Practices Advisory Committee (HICPAC), found at: http://www.cdc.gov/ncidod/dhqp/pdf/guidelines/Disinfection_Nov_2008.pdf, states on page 74 that hinged instruments and instruments that are closed should be opened during the process of sterilization.
The above was confirmed during the tour by staff member # 1 on 01/21/14.
A facility based policy entitled, Endoscopy Cleaning and Reprocessing, stated in part,
"Who May Clean and Reprocess Endoscopes
Before an individual can reprocess endoscopes without supervision, the individual is required to successfully complete the endoscope reprocessing training. The Endoscope Reprocessing Competency Checklist (tool 3.05) is used to show whether an individual successfully completed the training."
A review of the personnel record for staff member # 14 who is responsible for the cleaning of endoscopes, revealed this employee had not completed any specialized training for endoscopy cleaning. The Endoscope Reprocessing Competency Checklist was not present in the personnel folder. The only documentation of sterilization training present in the employee's personnel folder was for "Safe Handling and Decontamination of Instruments" dated 11/08/13.
In an interview on 01/22/14, staff member # 14, stated that only recent training provided for endoscope cleaning was through visiting an associated facility's sterilization facility. Staff member # 14 acknowledged they were still learning about the sterilization process for equipment.
In an interview on 01/22/14 staff member #14 who sterilizes endoscopes was asked how frequently scope procedures are performed at the facility. Staff member #14 responded "we do scopes almost weekly".
A review of the log for procedures utilizing scopes, colonoscopies and esophagogastroduodenoscopies (EGD), revealed the following number of procedures monthly. In December, 42 procedures utilizing scopes had been performed at the facility. In January, 28 procedures utilizing scopes had been performed as of the date of the survey on 01/22/14.
During a tour of the instrument processing on 01/22/14, the sterilization technician, Staff # 14 was asked about cleaning of the sterilizer chamber, including the sediment screen, for the Castle brand sterilizer and responded, "We clean it out when we do the leak test weekly...We check the drain for build up about once a week." Staff member # 14 was asked how often the interior and exterior of the sterilizer were cleaned and responded, "monthly".
Review of the Castle M/C 3533 Vacuum Steam Sterilizer manual provided by the facility, revealed the following:
"Preventative Maintenance...
Daily
Clean Sediment Screen...
Clean Exterior Surfaces...
Weekly
Clean Safety Valve...
Clean Chamber Interior and Accessories."
The sterilizer maintenance was not conducted per manufacturer's recommendations, which presents a risk for cross contamination. This was confirmed during a tour of the facility by the sterilization technician on 01/22/14.