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The still-smoldering ethylene oxide controversy is inspiring more sustainable, cost-effective, and biologically safe solutions from packaging and sterilization
June 4, 2020
By: Michael Barbella
Managing Editor
Jack Orlov wanted the truth. The real truth. Living and working in Illinois, Orlov has become well-versed in the ongoing controversy over ethylene oxide (EtO), a widely-used gas sterilant for medical equipment and supplies. First prepared in 1859 and employed mainly to manufacture polyester fibers, EtO has become the preferable medtech sterilization method, accounting for more than half of all device disinfections, according to industry estimates. EtO boasts several advantages over other cleaning processes (radiation, moist heat, dry heat, vaporized hydrogen peroxide, gas plasma), most notably its prowess in harmlessly penetrating packaging and plastic, as well as its ability to sanitize complex product configurations (e.g., connectors, interior tubing, two or more contact surfaces, etc.). EtO, however, is not without its drawbacks: It is volatile, costly, time-consuming (typically 16-18 hours/cycle), and a potential health threat. The compound is one of 187 hazardous air pollutants regulated by the U.S. Environmental Protection Agency (EPA); it was officially deemed a carcinogen in 1985 and linked to diseases such as breast cancer, leukemia, and lymphomas in 2016. Shortly thereafter, the agency identified several U.S. census tracts vulnerable to elevated cancer risks from EtO emissions. One of those tracts was Willowbrook, Ill., where air monitoring had detected possibly hazardous EtO levels outside a medical device sterilization plant operated by Sterigenics LLC, a global provider of industrial sterilization solutions for the medical device, pharmaceutical, commercial, and food industries. The Illinois Environmental Protection Agency closed the facility last February—citing excessive emissions—but Sterigenics disputed the reported amounts of EtO gas released by the plant (less than 0.1 percent, the company claimed) and noted the facility operated well within federal ethylene oxide emission standards. “…less than one-tenth of 1 percent of the EO used in the sterilization process is released into the atmosphere—exceeding regulatory requirements and representing one of the highest control levels in the country for this industry,” Sterigenics said in a statement. In its attempt to allay concerns in the Willowbrook community, though, Sterigenics inadvertently ignited an explosive national debate over EtO’s potential health hazards, both real and perceived. The ensuing brouhaha—a host of communal protests, regulatory reassessments, and (mostly) unflattering media blitzes—ensnared several other sterilization service providers, impacting operations in Colorado, Georgia, Illinois, and Michigan; and threatening the medical device (sterilization) supply chain. Eventually, the uproar became too overwhelming an obstacle for Sterigenics. In late September 2019, the company abandoned plans to reopen its Willowbrook plant and instead shifted its attention to Cobb County, Ga., where deja vu circumstances were playing out. Although it initially faced the same outcome, the company’s shuttered Cobb County facility has (temporarily) been enlisted in the fight against COVID-19. Understandibly, the global coronavirus pandemic has shoved the EtO controversy to the back burner for the time being. But the issue is not about to fade into oblivion: The EPA is rewriting EtO emissions rules, proposing a 93 percent cut in discharges, and also is updating its characterization of EtO concentrations. Public outcry, meanwhile, is still intensifying, with citizens, local lawmakers, and state environmental officials in Georgia and Michigan clamoring for tighter regulations. In February, 11 state attorneys general demanded the EPA strengthen national emission standards to better safeguard Americans’ health. Amidst such efforts to severely limit, if not outright ban, EtO emissions are conflicting discharge data, media reports, and tabloid-style social media warnings of ethylene oxide’s potential health dangers—all of which have clouded the truth about industrial use of the carcinogen. Thus, when the EPA released new EtO emissions data for the Waukegan, Ill., region earlier this year, Orlov—president of both Right Healthcare Ventures LLC and the Waukegan Chamber of Commerce—looked to “informed sources” for analysis of the data. He was seeking the truth, though the truth has been easily evasive amongst all the noise from 24-hour news channels and social media posts from “people that don’t really know what they are talking about for a problem that may not exist.” Medical Product Outsourcing has been on its own quest for the truth about EtO sterilization and its potential health impacts since the controversy erupted last winter. Over the past several weeks, the magazine spoke to more than a half-dozen companies for perspective on ethylene oxide, sterilization, alternative disinfection methods, COVID-19, packaging, and the industry’s future. Sterigenics submitted a formal statement discussing its efforts to control emissions and potentially reduce the amount of EtO used in each sterilization cycle (see sidebar, page 58). Other participants included: Jose Arevalo, global business development manager, Tyvek Healthcare; Jennifer Benolken, CPP – MDM and regulatory specialist, packaging engineer, Tyvek Healthcare; Dan Floyd, MDM and regulatory specialist, microbiologist, Tyvek Healthcare; and Nick Packet, MDM specialist, packaging engineer, Tyvek Healthcare; at specialty products giant DuPont. Jennifer R. Asleson, president of Quality, Microbiology & Sterilization Services, a firm in Colorado offering microbiology and sterilization consulting services to medical device and pharmaceutical manufacturers. Gerry DiBattista, vice president of marketing, PTFE, at Porex Corporation, a global developer of advanced porous solutions and a member company of the Filtration Group. Seán Egan, director of global marketing and Vice of Customer development at Nelipak Healthcare Packaging, a Cranston, R.I.-headquartered designer, developer, and manufacturer of custom designed thermoformed packaging for medical device and pharmaceutical firms. Brandon Hoser, sales manager at Packworld USA, a Nazareth, Pa.-based manufacturer of validatable medical heat sealing equipment and impulse heat sealing pharmaceutical packaging machines. Roy E. Morgan, vice president of engineering, at Eagle Medical Inc., a Paso Robles, Calif.-headquartered provider of FDA-compliant assembly, packaging and in-house hydrogen peroxide gas plasma specific and contract irradiation (gamma, e-beam) sterilization services for the medical device industry. Christopher A. Murphy, marketing manager at package testing, medical device and combination products testing laboratory DDL Inc. Tom Williams, general manager at Millstone Medical Outsourcing, a Fall River, Mass.-based provider of customized outsourcing solutions to the medical device industry. Michael Barbella: What are the current trends in packaging and sterilization services? Jose Arevalo, Jennifer Benolken, Dan Floyd, Nick Packet: There are currently two major trends in packaging: usability and sustainability. A third topic around the use of ethylene oxide is also quickly evolving, but the next steps and impact to packaging are unknown at this time. Usability has come more to the forefront due to EU MDR changes, signifying the importance of packaging for successful patient outcomes. Usability often connotates user experience. For the requirement in ISO 11607-1:2019, however, it is much more expansive. Being able to demonstrate a package’s ability to have its opening mechanism easily identifiable. Sustainability is widely discussed but few have actual solutions on how to address the challenge as there is a lack of re-processors that take medical waste. In addition, waste from medical packaging can be confusing to the end user as to which waste stream it can go into. Recycling can be an option for a healthcare facility, but only if they can find a re-processor. Once a re-processor is found, the sorting of the waste within the healthcare facility becomes more critical, as it is not going directly to the trash anymore. They are then faced with the challenge of who sorts the waste. They will also need to develop a means of being able to identify that which can be recycled and that which has to be thrown out—medical packaging does not always come with indicators on it, as consumer products do, to indicate which stream it can go into. The Healthcare Plastics Recycling Council is an organization that is working with the healthcare value chain (medical device industry raw material suppliers, medical device manufacturers, healthcare facilities, and re-processors) to help address these conundrums. For sterilization services, restrictions are being placed in the ethylene oxide (EtO) supply chain—companies are evaluating their sterilization cycles and the role packaging plays. The same is true for gamma sterilization as well—in some cases, people are moving away from gamma, but may possibly need to change packaging or product materials to allow for a different sterilization modality. In fact, the EPA has shut down some facilities due to emissions, with concerns over causing cancer around the facilities. These shutdowns continue even in current times and reopening is not foreseen unless safety procedures/compliance to local laws is completed. The FDA has issued a challenge to the industry to develop innovative sterilization methods that reduce the need for EtO, however nothing significant has been developed so far. The most promising development is the modification of EtO cycles to be more efficient with lower exposure concentrations, taking less time to complete the cycle (using less EtO), along with a possible shift in how validations are done (move away from overkill method to BI/bioburden method). Materials used that tend to absorb EtO could also be reduced. There are two different options being discussed, which include packaging postponement (waiting to complete final packaging until after sterilization) and the removal of IFUs from the shelf carton. Gerry DiBattista: Many of the current trends in packaging and sterilization services revolve around the reduction of waste and the development of more sustainable, reusable options. Some examples of these trends include the transition away of “Blue-Wrap” used to protect surgical equipment against potential contamination when it is being sterilized but is non-reusable and has to be disposed of after use. An alternate solution for sterilization that is more sustainable and increasing in usage are sterilization containers, or autoclave containers, which are used to sterilize instruments and surgical tools in hospitals, clinics, and dental offices. These containers are reusable, but the standard filters used in the containers are disposable. As a result, another trend that is occurring is the development of reusable filters for the sterilization containers so there is virtually no waste at all. Brandon Hoser: An increased focus for machines complying to 21 CFR Part 11 is noticeable. Organizations are striving for better traceability. Knowing which operator is signed into a machine and logging the rest of the data points during machine operation is increasingly important. Roy E. Morgan: There are three key trends that we are seeing in the marketplace for packaging and sterilization services within the last year; 1) Big concerns about the long-term viability of EtO sterilization suppliers and the risks associated with potential plant closures due to health and safety concerns and the concomitant supply chain constraints that creates, 2) Continued interest in standardized packaging configurations that can save time in development for new startups looking to reduce time-to-market, 3) Desire for improved packaging materials to combat sterility barrier failures due to distribution system challenges (moisture, vibration, impact, drop, aging). On the sterilization side, Eagle has recently noticed an uptick in interest with our vertically integrated capacity for hydrogen peroxide gas plasma sterilization, which we attribute to item 1 above. Christopher A. Murphy: The increased complexity and broader diversity of medical devices, especially in the combination product realm as pharmaceutical and medical device companies dabble more in the same space, is raising awareness of the need for packaging validation and accreditation with a greater focus on usability rather than just functionality. In addition, OEMs also have to meet updated regulatory requirements, such as the EU’s new Medical Device Regulations (MDRs), which is driving demand for testing, particular packaging validations. Tom Williams: In the immediate present, the greatest change related to the COVID-19 pandemic is the radical increase in demand for low-cost packaging of auxiliary products for testing—specifically test swabs. Before the COVID-19 emergency, the big trend in the U.S. market was the migration from non-sterile product lines to sterile packaging in preparation for the EU MDR’s original May 2020 date of application. Now that this date has been pushed out by a year, the impact on long-range planning is less clear. At Millstone, it’s our opinion that most companies will proceed with their changeovers as planned; many of them were already well underway. Barbella: What factors are currently driving these trends in packaging/sterilization services? Arevalo, Benolken, Floyd, Packet: Regulatory influences are ultimately the driving force behind these trends in packaging and sterilization. There are many reasons for the continued development of regulatory standards, but societal pressure and awareness of issues, like EtO, are a significant reason behind regulatory change. Jennifer Asleson: In sterilization, everything is focused on reducing the amount of EtO used for terminal sterilization. This is driving companies to look for creative ways to achieve the required sterility assurance levels while reducing the amount of EtO and the time of exposure. Sterilization in primary packaging to reduce the amount of corrugated present in the load is an option that is getting serious consideration by many companies. This creates challenges to legacy shipping studies but can allow for a much shorter exposure time and potentially allow for a lower EtO concentration which can help with EO residual levels as well. DiBattista: As with many trends, a key factor is decreasing cost. A reusable container as well as a reusable filter within that container is less expensive than buying many single-use items. For example, one reusable sterilization container filter can be used for thousands of cycles—sometimes the entire life of the container. Other key factors include:
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