EtO Sterilization: Principles of Process Design
By following a structured method, process engineers can design and
validate safe and efficacious EtO steilization cycles.
Paul J. Sordellini, Susan Edel Satter, and Vincent A. Caputo
Among the sterilization technologies currently available to the medical
device industry, 100% ethylene oxide (EtO) gas remains one of the most popular.
Validated EtO processes can be run in sterilizers ranging from BIER vessels of a
few cubic feet to industrial-sized vessels exceeding 4500 cu ft. Typically, the
EtO process can be broken down into four basic phases, each of which needs
careful planning to ensure a safe and efficacious process. The four phases are:
(1) air removal, (2) steam injection and conditioning dwell, (3) EtO injection
and gas dwell, and (4) gas purge and air in bleed.
 |
Mid-infrared
gas spectrometer measures EtO and water vapor during sterilization. Photo
courtesy Spectros Instruments, Inc. (Whitinsville, MA). |
This article is intended to guide the reader through the components of each
phase of two hypothetical 100% EtO with nitrogen processes. The following
assumptions were made for the purpose of explaining the rationale behind the
design of the cycles and the options available:
- Water vapor and process nitrogen are the only inert gases considered in
the flammability calculations performed during the air-elimination and
gas-purge phases.
- There is no stratification of process gases.
- All process gases are presumed to behave as ideal gases.
- Preconditioning and aeration are performed externally to the sterilizer.
- Atmospheric and barometric pressure are constant, with atmospheric
pressure at 14.7 psia.
An effective EtO process can be properly designed for almost every type of
medical device and permeable packaging configuration, provided that all
variables are assessed through thorough process design and development. It is
here, in fact, that one notices how EtO processes possess a greater number of
variables in comparison with other sterilization technologies. However, by
following a structured method that systematically examines and considers each of
these variables, the process engineer can design, validate, and routinely
sterilize with a safe and efficacious process.
The critical parameters of an EtO sterilization cycle are typically given as
temperature, pressure, humidity, EtO concentration, and gas dwell time. However,
the process engineer must also identify and evaluate relationships that may
exist between any given process parameter(s), the product being sterilized, and
the equipment used.
The sterilization process must consistently deliver all critical process
parameters to each and every component contained within the load, to a degree
that will ensure a 10-6 sterility assurance level (SAL) without
causing any deleterious effect to the product or its sterile barrier packaging.
In addition, this process must occur under controlled conditions that will
protect the sterilization personnel monitoring the operation, the equipment
employed, and ultimately the end-user.
Each product component contained in the load must be examined for the
following characteristics: natural bioburden, physical configuration,
raw-material composition, sensitivity to both negative and positive pressure
changes, maximum heat tolerance, and chemical reaction to water vapor and
ethylene oxide. For example, surgical sutures may present an extreme sensitivity
to what are often considered even moderate temperature levels. Other materials,
especially those containing salts, may react strongly with EtO to form ethylene
chlorohydrin (ECH), a residual chemical produced during the EtO process. Some
materials may bind, through a positive reaction, large quantities of EtO
molecules, presenting the problem of excessively high postprocess levels of EtO
and ethylene glycol (EG), another process residual.1 Those components
presenting the greatest challenge to the process—due either to physical
configuration (obstruction of gas permeation) or high bioburden (natural fibers,
for example)—should be selected for the microbiological challenge. Other
product sensitivities should also be noted, as they will determine maximum ramp
rates and set points employed in the cycle. For the validation of the process, a
reference load must be selected that will represent the most difficult
combination to heat, humidify, sterilize, and aerate.
Each level of packaging, from master cartons to the unit package (the primary
sterile barrier), must be examined and evaluated for its ability to allow heat,
moisture, and sterilant to permeate. Gas delivery to and permeation within the
product, in addition to aeration of the gas from the product, are all important
considerations. Data obtained from fractional studies can provide the basis for
the calculation of the dwell times for the conditioning and gas exposure. The
process engineer must be cautious of excessively long gas-exposure dwells or
high gas concentrations, as they can result in the need for long multiple
evacuations and/or aeration times that will delay product release. The objective
is to decide whether to adopt a cycle using a long gas-exposure time with low
EtO concentration or one with brief gas exposure and a high EtO concentration.
Naturally, if gas is easily aerated from the product, production times are
improved by a short exposure to a high concentration of sterilant.
Before a preliminary cycle plan can be drafted, the process engineer must
have a thorough knowledge of the process equipment, including the minimum and
maximum operating ranges of the preconditioning facility, the sterilizer and
ancillary equipment, and the aeration facility. The sterilizer control system
must be able to perform all evacuations and gas injections (nitrogen, steam,
EtO, and air) at steady, preprogrammed rates. Accurately calibrated proportional
valves facilitate the delivery of these rates. The objective is to perform each
process ramp at gradual (linear) rates.
Both in the first part of the sterilization cycle (air removal) and in the
final stage (sterilant removal), the safety of the facility and personnel are
paramount issues. During the air-removal phase, the sterilizer is evacuated and
then backfilled with nitrogen. After each vacuum/nitrogen sequence, a calculated
amount of air is displaced. Depending on the depth of each vacuum and the final
pressure achieved by the nitrogen addition, the process engineer must determine
the minimum number of sequences necessary to bring the air content of the
sterilizer atmosphere to a composition at which there is insufficient oxygen
left to pilot a combustible reaction. EtO is flammable and can ignite in the
presence of static electricity.2 It is, therefore, essential to know,
prior to EtO injection, the volume percentage of air (%volair) left
in the chamber before deciding upon the maximum amount of sterilant to be used.
Later, when the volume percentages of air, of the inert gases (%volsteam
and %volnitrogen), and of EtO (%volEtO) are known, they
can be plotted on a flammability chart to confirm the nonflammability of the
cycle.3
Following gas contact, the EtO must be displaced from the load and removed
from the chamber. In planning this segment of the cycle, the same
routine—post vacuums followed by nitrogen flushes—is followed. A volumetric
calculation of the percentage of EtO left in the sterilizer after each
vacuum/nitrogen sequence will determine when the level of EtO has been brought
down to an acceptable level. Usually, after the final evacuation is performed,
the sterilizer is backfilled with ambient air instead of nitrogen. In the final
stage of the cycle, the sterilizer rear exhaust is activated while fresh air is
allowed into the sterilizer either through a dedicated vent or by partially
opening the door. Sufficient time must be allotted to flushing the sterilizer
headspace so that the EtO concentration is brought to a safe level before the
sterilizer is unloaded. Some workers wear industrial respirators with catalytic
filter canisters rated for atmospheres containing not more than 50 ppm of EtO.
Flammability is not the only factor that determines the number of
evacuations. In most cases, increasing the number of evacuations will also lower
the EtO residuals left on the product, thus decreasing the amount of time the
load must be quarantined for aeration. Although in this case "more is
better," limitations are imposed by product and packaging tolerances as
well as by equipment demands. A greater number of evacuations will subject the
load to increased physical stress, which, when combined with EtO, heat, and
humidity, could have a negative effect on product and packaging constructions
such as, for example, glues or seals. Time spent for additional postvacuums also
reduces the overall productivity of the sterilizer, which can affect facility
profitability.
AIR REMOVAL
Before 100% EtO can be introduced into the sterilizer, the original air
content (%volair = 100% of the initial sterilizer atmosphere) must be
displaced and substituted with an inert gas such as nitrogen (N2).
The physical parameters for the air-removal phase are determined by the
tolerances of the most sensitive products or packaging (e.g., nonpermeable foil
pouches or sealed cavities). If data are not available from the respective
component or product manufacturers, they can be generated by conducting
preliminary studies during which samples are exposed to different ramp rates
(i.e., change in pressure per unit time) and vacuum set points. Each set of
samples is then tested (both product and packaging) for conformity to original
manufacturing specifications until the fastest permissible ramp rate and deepest
acceptable evacuation set point are determined and recorded in the sterilization
process design history record.
The initial pressure inside the sterilizer at the moment the door is closed
is equivalent to atmospheric pressure (14.7 psia at sea level). The first
evacuation will remove a quantifiable amount of air. For example, an initial
evacuation from Pinitial = 14.7 psia to a depth of Pfinal
= 7.35 psia will eliminate 50% of the original air content in the sterilizer.
While the volume percentage of air is still 100%, the partial pressure of air is
reduced in direct proportion to the pressure change:
The sterilizer is programmed to backfill with nitrogen to a set point of 14.7
psia. The resulting sterilizer atmosphere is now 50% air and 50% nitrogen. After
this first vacuum/nitrogen sequence, the volume percentages of air and nitrogen
are represented as:
After the second vacuum/nitrogen sequence, the amount of air in the
sterilizer reduces again by half (%volair = 25%), while the nitrogen
increases by half (%volnitrogen = 75%). This sequence is repeated as
many times as necessary, until the %volair is reduced to a safe
level.
Ethylene oxide requires oxygen to ignite. The term safe level is
intended to mean that the air originally contained in the sterilizer at the
beginning of the process has been reduced to the point that there remains
insufficient oxygen to allow a reaction to occur should a source of ignition be
available.4 Here it should be easy for the reader to see the
relationship between the final set point of each vacuum/nitrogen sequence and
the total number of sequences that will be required to render the cycle safe.
In selecting the ramp rates and set points for the vacuum/nitrogen sequences
of an EtO process, there are various options. In general, a deep vacuum set
point is preferred because it allows the air-removal process to be completed
more efficiently. As stated earlier, determination of a maximum vacuum set point
is a function of product/packaging tolerance as well as equipment limitations.
Once the maximum ramp rate tolerances are determined for the vacuum and nitrogen
sequences, the process engineer must decide what rate is best for the given
product configuration. While the air-removal phase ensures that the sterilizer
atmosphere is almost void of air, a consequence of these purges is loss of
product moisture. The goal of process design is to displace air as efficiently
as possible while minimizing load desiccation.
AIR REMOVAL
Deeper vacuums can complete air removal with fewer sequences. When dealing
with a vacuum-resistant product, one vacuum from atmospheric (14.7 psia) to 2.0
psia, followed by a nitrogen backfill to 14.7 psia, will quickly reduce the %volair
to 13.6% (Table I). Products that can withstand this rate and depth of vacuum
will usually tolerate an equally rapid nitrogen injection. Fast ramp rates for
nitrogen backfilling also minimize product-level moisture loss.
Process
Phase |
Cycle
Segment |
Set Point
(in. HgA) |
Set Point
(psia) |
Ramp Rate
(psi/min) |
Segment
Time
(min) |
Cumulative Cycle
Time
(min) |
| Cycle start |
|
29.9 |
14.7 |
N/A |
N/A |
0.0 |
| Air removal |
Evacuation 1 |
4.1 |
2.0 |
1.00 |
12.7 |
12.7 |
| |
Nitrogen purge 1 |
29.9 |
14.7 |
1.00 |
12.7 |
25.4 |
| |
Evacuation 2 |
4.1 |
2.0 |
1.00 |
12.7 |
38.1 |
| Humidification |
Steam injection |
6.3 |
3.1 |
0.02 |
55.0 |
93.1 |
| EtO inject |
EtO injection |
17.9 |
8.8 |
0.20 |
28.5 |
121.6 |
| |
Nitrogen overlay |
29.5 |
14.5 |
0.20 |
28.5 |
150.1 |
| |
Gas contact |
29.5 |
14.5 |
0.00 |
480.0 |
630.1 |
| EtO removal |
Postevacuation #1 |
4.1 |
2.0 |
1.00 |
12.5 |
642.6 |
| |
Nitrogen flush #1 |
29.9 |
14.7 |
1.00 |
12.7 |
655.3 |
| |
Postevacuation #2 |
4.1 |
2.0 |
1.00 |
12.7 |
668.0 |
| |
Nitrogen flush #2 |
29.9 |
14.7 |
1.00 |
12.7 |
680.7 |
| |
Postevacuation #3 |
4.1 |
2.0 |
1.00 |
12.7 |
693.4 |
| |
Final air inbleed |
29.9 |
14.7 |
1.00 |
12.7 |
706.1 |
| |
Total cycle time (min) |
|
|
|
706.1 |
706.1 |
Process
Phase |
Cycle
Segment |
Partial
Pressure
Air (psi) |
Partial
Pressure
Inerts (psi)
(nitrogen
and steam) |
Partial
Pressure
EtO (psi) |
Total
Partial
Pressures
(psia) |
| Cycle start |
|
14.70 |
0.00 |
0.00 |
14.70 |
| Air removal |
Evacuation 1 |
2.00 |
0.00 |
0.00 |
2.00 |
| |
Nitrogen purge 1 |
2.00 |
12.70 |
0.00 |
14.70 |
| |
Evacuation 2 |
0.27 |
1.73 |
0.00 |
2.00 |
| Humidification |
Steam injection |
0.27 |
2.83 |
0.00 |
3.10 |
| EtO inject |
EtO injection |
0.27 |
2.83 |
5.70 |
8.80 |
| |
Nitrogen overlay |
0.27 |
8.53 |
5.70 |
14.50 |
| |
Gas contact |
0.27 |
8.53 |
5.70 |
14.50 |
| EtO removal |
Postevacuation #1 |
0.04 |
1.18 |
0.79 |
2.00 |
| |
Nitrogen flush #1 |
0.04 |
13.88 |
0.79 |
14.70 |
| |
Postevacuation #2 |
0.01 |
1.89 |
0.11 |
2.00 |
| |
Nitrogen flush #2 |
0.01 |
14.59 |
0.11 |
14.70 |
| |
Postevacuation #3 |
0.00 |
1.98 |
0.01 |
2.00 |
| |
Final air inbleed |
12.70 |
1.98 |
0.01 |
14.70 |
| |
Total cycle time (min) |
|
|
|
|
Process
Phase |
Cycle
Segment |
%Volume
Air |
%Volume
Inerts
(nitrogen
and steam) |
%Volume
EtO |
%Volume
Total |
| Cycle start |
|
100.00 |
0.00 |
0.00 |
100.00 |
| Air removal |
Evacuation 1 |
100.00 |
0.00 |
0.00 |
100.00 |
| |
Nitrogen purge 1 |
13.61 |
86.39 |
0.00 |
100.00 |
| |
Evacuation 2 |
13.61 |
86.39 |
0.00 |
100.00 |
| Humidification |
Steam injection |
8.78 |
91.22 |
0.00 |
100.00 |
| EtO inject |
EtO injection |
3.09 |
32.14 |
64.77 |
100.00 |
| |
Nitrogen overlay |
1.88 |
58.81 |
39.31 |
100.00 |
| |
Gas contact |
1.88 |
58.81 |
39.31 |
100.00 |
| EtO removal |
Postevacuation #1 |
1.88 |
58.81 |
39.31 |
100.00 |
| |
Nitrogen flush #1 |
0.26 |
94.40 |
5.35 |
100.00 |
| |
Postevacuation #2 |
0.26 |
94.40 |
5.35 |
100.00 |
| |
Nitrogen flush #2 |
0.03 |
99.24 |
0.73 |
100.00 |
| |
Postevacuation #3 |
0.03 |
99.24 |
0.73 |
100.00 |
| |
Final air inbleed |
86.40 |
13.50 |
0.10 |
100.00 |
| |
Total cycle time (min) |
|
|
|
|
Table I. Process calculations for cycle 1—deep-vacuum type.
In the case of a vacuum-sensitive product, such as a kit containing multiple
devices, the air-removal phase could require multiple slow vacuums—down to 7.0
psia, for example. The first vacuum/nitrogen sequence will only bring the %volair
from 100% down to 47.62% (Table II). In this case, the process engineer must
consider that the desiccating effect inherent in this process is further
amplified. Multiple vacuum/nitrogen injections coupled with slow ramp rates mean
that there is more time for moisture to be driven out of the load by the induced
pressure gradient. Water becomes more volatile as temperature is increased and
pressure is decreased. In these circumstances, one must begin the
steam-injection phase as soon as possible in order to replace some of the
moisture lost during the multiple slow-vacuum phases.
Process
Phase |
Cycle
Segment |
Set Point
(in.HgA) |
Set Point
(psia) |
Ramp Rate
(psi/min) |
Segment
Time
(min) |
Cumulative Cycle
Time
(min) |
| Cycle start |
|
29.9 |
14.7 |
N/A |
N/A |
0.0 |
| Air removal |
Evacuation 1 |
14.3 |
7.0 |
0.25 |
30.8 |
30.8 |
| |
Nitrogen purge 1 |
29.9 |
14.7 |
0.25 |
30.8 |
61.6 |
| |
Evacuation 2 |
14.3 |
7.0 |
0.25 |
30.8 |
92.4 |
| |
Nitrogen purge 2 |
29.9 |
14.7 |
0.25 |
30.8 |
123.2 |
| |
Evacuation 3 |
14.3 |
7.0 |
0.25 |
30.8 |
154.0 |
| |
Nitrogen purge 3 |
29.9 |
14.7 |
0.25 |
30.8 |
184.8 |
| |
Evacuation 4 |
14.3 |
7.0 |
0.25 |
30.8 |
215.6 |
| |
Nitrogen purge 4 |
29.9 |
14.7 |
0.25 |
30.8 |
246.4 |
| |
Evacuation 5 |
14.3 |
7.0 |
0.25 |
30.8 |
277.2 |
| Humidification |
Steam injection |
16.5 |
8.1 |
0.02 |
55.0 |
332.2 |
| EtO inject |
EtO injection |
28.1 |
13.8 |
0.20 |
28.5 |
360.7 |
| |
Nitrogen overlay |
29.5 |
14.5 |
0.20 |
3.5 |
364.2 |
| |
Gas contact |
29.5 |
14.5 |
0.00 |
480.0 |
844.2 |
| EtO removal |
Postevacuation #1 |
14.3 |
7.0 |
0.25 |
30.0 |
874.2 |
| |
Nitrogen flush #1 |
29.9 |
14.7 |
0.25 |
30.8 |
905.0 |
| |
Postevacuation #2 |
14.3 |
7.0 |
0.25 |
30.8 |
935.8 |
| |
Nitrogen flush #2 |
29.9 |
14.7 |
0.25 |
30.8 |
966.6 |
| |
Postevacuation #3 |
14.3 |
7.0 |
0.25 |
30.8 |
997.4 |
| |
Nitrogen flush #3 |
29.9 |
14.7 |
0.25 |
30.8 |
1028.2 |
| |
Postevacuation #4 |
14.3 |
7.0 |
0.25 |
30.8 |
1059.0 |
| |
Nitrogen flush #4 |
29.9 |
14.7 |
0.25 |
30.8 |
1089.8 |
| |
Postevacuation #5 |
14.3 |
7.0 |
0.30 |
30.8 |
1120.6 |
| |
Final air inbleed |
29.9 |
14.7 |
0.25 |
30.8 |
1151.4 |
| |
Total cycle time (min) |
|
|
|
1151.4 |
1151.4 |
Process
Phase |
Cycle
Segment |
Partial
Pressure
Air (psi) |
Partial
Pressure
Inerts (psi)
(nitrogen
and steam) |
Partial
Pressure
EtO (psi) |
Total
Partial
Pressures
(psia) |
| Cycle start |
|
14.70 |
0.00 |
0.00 |
14.70 |
| Air removal |
Evacuation 1 |
7.00 |
0.00 |
0.00 |
7.00 |
| |
Nitrogen purge 1 |
7.70 |
0.00 |
14.70 |
47.62 |
| |
Evacuation 2 |
3.33 |
3.67 |
0.00 |
7.00 |
| |
Nitrogen purge 2 |
3.33 |
11.37 |
0.00 |
14.70 |
| |
Evacuation 3 |
1.59 |
5.41 |
0.00 |
7.00 |
| |
Nitrogen purge 3 |
1.59 |
13.11 |
0.00 |
14.70 |
| |
Evacuation 4 |
0.76 |
6.24 |
0.00 |
7.00 |
| |
Nitrogen purge 4 |
0.76 |
13.94 |
0.00 |
14.70 |
| |
Evacuation 5 |
0.36 |
6.64 |
0.00 |
7.00 |
| Humidification |
Steam injection |
0.36 |
7.74 |
0.00 |
8.10 |
| EtO inject |
EtO injection |
0.36 |
7.74 |
5.70 |
13.80 |
| |
Nitrogen overlay |
0.36 |
8.44 |
5.70 |
14.50 |
| |
Gas contact |
0.36 |
8.44 |
5.70 |
14.50 |
| EtO removal |
Postevacuation #1 |
0.17 |
4.07 |
2.75 |
7.00 |
| |
Nitrogen flush #1 |
0.17 |
11.77 |
2.75 |
14.70 |
| |
Postevacuation #2 |
0.08 |
5.61 |
1.31 |
7.00 |
| |
Nitrogen flush #2 |
0.08 |
13.31 |
1.31 |
14.70 |
| |
Postevacuation #3 |
0.04 |
6.34 |
0.62 |
7.00 |
| |
Nitrogen flush #3 |
0.04 |
14.04 |
0.62 |
14.70 |
| |
Postevacuation #4 |
0.02 |
6.68 |
0.30 |
7.00 |
| |
Nitrogen flush #4 |
0.02 |
14.38 |
0.30 |
14.70 |
| |
Postevacuation #5 |
0.01 |
6.85 |
0.14 |
7.00 |
| |
Final air inbleed |
7.71 |
6.85 |
0.14 |
14.70 |
| |
Total cycle time (min) |
|
|
|
|
Process
Phase |
Cycle
Segment |
%Volume
Air |
%Volume
Inerts
(nitrogen
and steam) |
%Volume
EtO |
%Volume
Total |
| Cycle start |
|
100.00 |
0.00 |
0.00 |
100.00 |
| Air removal |
Evacuation 1 |
100.00 |
0.00 |
0.00 |
100.00 |
| |
Nitrogen purge 1 |
52.38 |
0.00 |
100.00 |
7.00 |
| |
Evacuation 2 |
47.62 |
52.38 |
0.00 |
100.00 |
| |
Nitrogen purge 2 |
22.68 |
77.32 |
0.00 |
100.00 |
| |
Evacuation 3 |
22.68 |
77.32 |
0.00 |
100.00 |
| |
Nitrogen purge 3 |
10.80 |
89.20 |
0.00 |
100.00 |
| |
Evacuation 4 |
10.80 |
89.20 |
0.00 |
100.00 |
| |
Nitrogen purge 4 |
5.14 |
94.86 |
0.00 |
100.00 |
| |
Evacuation 5 |
5.14 |
94.86 |
0.00 |
100.00 |
| Humidification |
Steam injection |
4.44 |
95.56 |
0.00 |
100.00 |
| EtO inject |
EtO injection |
2.61 |
56.09 |
41.30 |
100.00 |
| |
Nitrogen overlay |
2.48 |
58.21 |
39.31 |
100.00 |
| |
Gas contact |
2.48 |
58.21 |
39.31 |
100.00 |
| EtO removal |
Postevacuation #1 |
2.48 |
58.21 |
39.31 |
100.00 |
| |
Nitrogen flush #1 |
1.18 |
80.10 |
18.72 |
100.00 |
| |
Postevacuation #2 |
1.18 |
80.10 |
18.72 |
100.00 |
| |
Nitrogen flush #2 |
0.56 |
90.52 |
8.91 |
100.00 |
| |
Postevacuation #3 |
0.56 |
90.52 |
8.91 |
100.00 |
| |
Nitrogen flush #3 |
0.27 |
95.49 |
4.24 |
100.00 |
| |
Postevacuation #4 |
0.27 |
95.49 |
4.24 |
100.00 |
| |
Nitrogen flush #4 |
0.13 |
97.85 |
2.02 |
100.00 |
| |
Postevacuation #5 |
0.13 |
97.85 |
2.02 |
100.00 |
| |
Final air inbleed |
52.44 |
46.60 |
0.96 |
100.00 |
| |
Total cycle time (min) |
|
|
|
|
Table II. Process calculations for cycle 2—shallow-vacuum type.
A comparison of the two cycles illustrated in Tables I and II shows that the
deep-vacuum cycle completes the air-elimination phase and arrives at the start
of steam injection in 38.1 minutes, whereas the shallow-vacuum cycle requires
277.2 minutes.
STEAM INJECTION AND CONDITIONING DWELL
Product loads are typically preconditioned in a room or chamber in which heat
and humidity are controlled to predetermined levels until the load reaches
equilibrium with the surrounding conditions. This process occurs prior to moving
the load into the sterilizer. When it is transferred to the sterilizer and
subjected to the air-removal phase, the load can lose a significant amount of
moisture, which must be replaced before introducing EtO. This is accomplished by
adding steam under vacuum until the chamber atmosphere is humidified—normally
to a range of 40—80% relative humidity (%RH)—and then holding the humidity
stable for a period of time (static conditioning dwell). Sterilizer relative
humidity is the ratio of the water-vapor pressure in the headspace to the
saturation vapor pressure at the same temperature and pressure.
The final pressure set point of steam addition depends on the desired level
of relative humidity, which is determined during process validation. The
steam-injection rate depends on the physical characteristics of the product and
packaging. Heat-resistant products in breathable pouches can withstand rapid
steam-injection rates, whereas more-delicate products will require slower rates.
The process engineer must monitor the level of relative humidity in the
sterilizer during the phase of conditioning dwell. RH inside a sterilizer can be
measured in three ways: by pressure- and temperature-based calculation,5
by dew-point calculation, or by direct headspace analysis (gas chromatograph or
infrared analyzer, electronic RH sensor).
The first method is used to calculate the relative humidity achieved by the
static steam-injection phases in Cycle 1 and Cycle 2, using the following
formula:
where %RH = percent relative humidity, Pt = final steam-injection
pressure, Pi = conditioning vacuum final pressure, Tdc =
temperature at the end of steam injection, and Pss = pressure of
saturated steam, at Tdc, as reported by the saturated steam table.6
The second method, known as dew-point calculation, is also based on process
data:
%RH = 100x(exp[4098x(D — T)/((D +
237.3)x(T + 237.3))]),
where %RH = relative humidity, D = dew point in °C, and T =
temperature in °C.
The process engineer must consider a number of factors when designing the
steam-injection and conditioning-dwell phases. For example, the higher the
injection set point (targeted relative humidity level), the greater the physical
force (pressure and RH gradient) available to drive the moisture across each
layer of packaging. Because the addition of steam will add heat to the
sterilizer and product load, one must be aware of the expected temperature of
the load prior to its entry into the sterilizer, the approximate amount of load
heat and humidity that will be lost during the vacuum/nitrogen sequences, and
the amount of heat and humidity the load will absorb from the steam-injection
phase. The amount of heat transferred to the load is directly related to the
steam-injection rate and the pressure differential. In other words, a faster
steam-injection rate coupled with a greater pressure differential will result in
a greater heat transfer to the load. In the case of a heat-resistant product,
this is a desirable effect, since heat and humidity are conducive to
sterilization. However, because heat-sensitive products may be susceptible to
damage, a lower, more gradual steam addition may be required.
Once steam injection is complete, the load dwells for a period of time,
allowing it to equilibrate to the new conditions inside the sterilizer (e.g., %RH
and temperature). Prolonged steam dwell times (>60 minutes) are conducive to
achieving a more uniform spread of temperature and humidity across the load.
Greater steam-injection differentials and long conditioning dwell times may
cause the primary packaging to absorb excess moisture, creating both physical
problems (softening of packaging materials and seals) and chemical problems
(higher EtO, EG, and ECH levels) on postprocessed product. Factors that
influence steam-injection rates include:
- Complex devices containing different types of components and materials.
- Dense product load configurations.
- Devices with nonvented components.
- Physical obstruction of moisture penetration by multiple layers of
packaging or product containers that have limited permeable surface area.
Under any of these conditions, a slow steam-injection phase together with a
long conditioning dwell time (>2 hours) may be selected to allow the load to
achieve a higher and more-uniform level of temperature and humidity.
Ultimately, the time required for conditioning dwell can be empirically
determined through process development and then validated. Placing relative
humidity sensors directly inside the primary packaging will allow the
humidification of the product load to be profiled.
Product loads can also be conditioned dynamically, using two methods that
require deep-vacuum processes. After the sterilizer is evacuated to 0.5 psia or
less, steam is introduced and evacuated. The first method alternates the
addition of steam and the evacuation of the sterilizer to create a pulse/purge
action. Steam is pulsed into the sterilizer and then purged by the vacuum pump.
During each purge, both steam and air are removed. Eventually, the volume
percentage and partial pressure of air inside the sterilizer are reduced to
zero, and the load is allowed to achieve a uniform level of both temperature and
humidity.
The second method is different in that it activates both the steam-injection
and vacuum-pump systems simultaneously. A laminar flow of steam is injected into
one side of the sterilizer and evacuated simultaneously from the opposite side.
The sterilizer is kept under deep vacuum, and the rate of steam entering it is
balanced—through the use of proportional valves—to equal the rate of
evacuation. Ideally, one sterilizer volume per minute of steam should be
injected into and evacuated from the sterilizer.7 This second method
also requires certain sterilizer equipment upgrades. A detailed technical
information report (TIR No. 15—1997), which has been published by the
Association for the Advancement of Medical Instrumentation (AAMI), provides
formulas and instructions for performing the calculations necessary to determine
relative humidity during either method of dynamic conditioning.
ETO INJECTION AND GAS DWELL
Liquid EtO is first heated to form a gas phase inside a volatilizer connected
directly to the sterilizer with a valve assembly. The volatilized EtO is usually
injected into the sterilizer through the recirculation header for uniform
distribution. The decision to use a particular EtO concentration is based on
examination of the product and packaging as well as flammability concerns.
Microbial lethality depends on the delivery, to the product load, of all
elements of an EtO cycle, with gas concentration being one of the factors that
directly affects lethality. Therefore, higher EtO concentrations will allow the
load to achieve its target SAL in less time.
The rate of EtO injection depends on the nature of the product and the
equipment. Products that absorb EtO and chemically react rapidly may require
fast EtO injection rates in order to avoid excessive EtO absorption. The ability
of the product load to withstand rapid ramp rates will be a determining factor.
On the other hand, a slower ramp rate may be a better choice for product loads
consisting of certain devices. For example, a load consisting of large kits that
contain many different kinds of devices may require a high concentration of
sterilant that it absorbs slowly from the sterilizer headspace. By using a
slower injection rate, allowances can be made for load absorption of EtO during
injection, which will ultimately increase the total amount of sterilant injected
into the sterilizer.
For EtO addition, the single-charge method is preferred, for safety reasons.
In this method, EtO is added after conditioning dwell until a preprogrammed set
point is achieved; there is no further sterilant addition for the remainder of
the cycle. The set point can either be based on final pressure or on a
calculated EtO concentration value.8
However, there are cases of high load absorbency in which EtO depletion
becomes a concern. In these instances, a "makeup" method is used: as
the load absorbs gas, the sterilizer headspace pressure drops below set point.
EtO can then be added to the sterilizer to restore the headspace pressure to its
original set point. The number of makeup injections may vary, with some systems
allowing the addition of makeup gas every time the sterilizer pressure drops
while others allow only a preprogrammed number of makeups. The process engineer
must be aware that each time an EtO makeup is performed, the partial pressure of
EtO increases and it becomes impossible to calculate the new
concentration—which raises major safety concerns. Safe conditions can be
maintained by installing a gas analyzer (chromatograph or spectrometer) that
periodically samples the sterilizer atmosphere and determines EtO concentration.
The EtO injection temperature should be regulated by controlling both the
operating temperature of the volatilizer and the gas flow rate. The temperature
of the EtO entering the sterilizer should be at or above the sterilizer process
temperature. This is especially important to protect those parts of the load
closest to the EtO injection ports. Low injection temperatures can cause parts
of the load to cool down, thus interfering with microbial inactivation.
Conversely, EtO that has been volatilized to a high temperature can rapidly
desiccate the outer layers of a pallet, which can adversely affect the integrity
of the process.9 Sterility failures, inconsistent sublethal results,
and product damage are possible as a result of localized heating.
Following EtO injection, an inert gas overlay (N2 ) can be added
to further reduce the volume percentages of both the sterilant and the residual
air inside the sterilizer. The data in both Tables I and II show that the simple
addition of the inert overlay prior to sterilant dwell will reduce volume
percentages of air and EtO. The greatest effect, however, is in the deep-vacuum
cycle (Table I). When an inert overlay is applied, neither the EtO concentration
nor the relative humidity is altered. The sterilizer atmosphere is rendered
safer, and increasing the pressure in the sterilizer headspace will create a
greater headspace/product pressure gradient, thus assisting sterilant
penetration into the load.
In both types of cycles, the nitrogen overlay is programmed to end at 14.5
psia—or 0.2 psi below atmospheric pressure which, in this exercise, is assumed
to be 14.7 psia. The objective is to keep the sterilizer under slight negative
pressure during times in which there is EtO inside. Under negative pressure, the
only consequence in case of a leak (such as a broken valve or gasket) would be
to draw ambient air into the sterilizer, preventing EtO from escaping into the
employee work area.
It is at this point that the process engineer, having thus far planned the
cycle on paper, must perform the necessary safety calculations. Organizing the
volumetric data for each phase of the process will encompass plotting the volume
percentages of air, inert gases, and EtO on an EtO-specific flammability chart
to determine if the cycle is within the chart's area of flammability at any
given time. Should the proposed cycle be flammable, additional vacuum/nitrogen
sequences should be added during the air-removal phase, and the cycle should be
reprojected on the flammability chart.10 Although designing only
nonflammable cycles is an obvious safety choice, it must be stated that there is
no industry regulation preventing the use of cycles which, when plotted on a
flammability chart, enter into the flammable region of the chart. Certain
cycles, for example, may enter the flammable region temporarily during EtO
injection, only to reenter the nonflammable region following application of the
nitrogen overlay; other cycles may lie in the flammable region throughout gas
contact. (All decisions regarding the use of flammable cycles are the
responsibility of the facility management team, which should review state and
local regulations as well as insurance policy requirements when determining
operating policy.) At completion of the inert blanket application (i.e., start
of gas contact), the process engineer should again plot the volume percentages
of air, inert gases, and EtO to reconfirm the nonflammability of the cycle.
The phase of gas dwell—also referred to as sterilant dwell—is a
time-related event. Following EtO injection and the application of the inert
overlay, the ambient environment in the sterilizer is maintained within a
constant temperature range for a period of time determined during process
development. In planning the parameters of gas dwell, the process engineer
should examine the anticipated temperature of the product load as it begins the
gas-dwell phase. The most efficient technique in planning the process- and
load-temperature specifications for the gas dwell is to raise the product load
temperature as close as possible to the temperature set point targeted for the
gas-dwell phase. The closer the product temperature is to the process
temperature, the less heat is required and the more stable the cycle becomes.
Preconditioning is the first opportunity to add required heat to the product
load; the next is during steam injection and conditioning. Thus, by
strategically selecting temperature and RH set points; injection ramp rates; and
dwell times for preconditioning, steam injection, and conditioning, the product
load can be gradually brought to the targeted gas-contact temperature set point.
For example, an efficient process plan could begin by bringing the product load
to 110°F during preconditioning, planning the characteristics of steam
injection and conditioning so as to raise the product load temperature to 120°F,
and then programming in a temperature set point of 120—125°F for gas dwell.
In some facilities, the sterilizer is used for all three
phases—preconditioning, sterilization, and aeration. In this case, it is
easier for the user to set and maintain one optimal process temperature
throughout the cycle. This is an old practice, however, and is not often used
anymore except when dynamic environmental conditioning can be used to condition
the load and steam distillation for sterilant removal.
GAS PURGE AND AIR INBLEED
Subsequent to gas contact, the main objective of the process is to displace
the EtO from the sterilizer headspace until the level of EtO falls below the
lower explosion limit (LEL) established for EtO (3% or 30,000 ppm). The
procedure for gas removal follows the same principle that was presented in the
earlier air-removal phase. A series of postvacuums, each followed by a nitrogen
backfill, are programmed. A maximum vacuum-depth set point must be established
for each specific product family. During the gas-dwell phase, the combination of
heat, humidity, and EtO has ample opportunity to soften some packaging and
product materials such as glues and adhesives. Therefore, the process engineer
must be careful in selecting the appropriate set points and ramp rates for this
final stage in the process.
Following each vacuum/nitrogen sequence, the volume percentages of air, inert
gases, and EtO must be calculated and recorded. The process must be designed so
that, by the last vacuum, the sterilizer headspace level of EtO is below 3%. As
Tables I and II show, process efficiency in removing EtO is augmented by using
deeper vacuum set points. In cycle 1, a single postvacuum/nitrogen flush from
14.5 to 2.0 psia reduces the %volEtO from 39.3 to 5.35% in 25.2
minutes. In cycle 2, one shallow postvacuum from 14.5 to 7.0 psia only reduces
the %volEtO from 39.3 to 18.7% in 60.8 minutes. To protect facility
personnel and equipment, the processes are planned to continue evacuating and
purging with nitrogen until the level of EtO is brought below 3%. This is
achieved in the deep-vacuum cycle 1 after two nitrogen flushes and 50.6 minutes
and in the shallow-vacuum cycle 2 after four flushes and 245.6 minutes.
In either cycle, once the EtO level is reduced to less than 3%, a final
postvacuum is performed, followed by a phase in which ambient air is drawn into
the sterilizer. The rate at which the ambient air is allowed to bleed into the
sterilizer should be controlled at the same rate as that programmed for the
nitrogen flushes. The air should be filtered to ensure that debris is not also
drawn into the sterilizer.
In the two examples of EtO processes presented in the tables, the number of
postvacuum/nitrogen sequences was based exclusively on the need to reduce the
sterilizer headspace EtO level to less than 3% in order to add air and unload
the vessel. However, depending on the product configuration and facility
equipment, an EtO process engineer might plan this part of the cycle
differently.
When EtO processes are performed inside an empty vessel—as is the case
during equipment-qualification studies—the dynamics of air and gas addition
and removal can be accurately predicted through calculations. Once a product
load is placed inside, however, the dynamics of gas removal change dramatically.
Basically, the EtO contained within a fully loaded sterilizer can be categorized
as follows:
- Headspace EtO, which occupies the vapor space surrounding the product
load.
- Packaging EtO, which occupies the vapor space within every layer of
packaging (master cartons, shelf cartons, unit packages, and so forth).
- Absorbed EtO, which is bound to the humidity of the load through weak
hydrogen bonds.
- Adsorbed EtO, which adheres directly to the product itself through
chemical bonds whose strength depends on the particular product's materials
of construction.11
An EtO process that is optimized for the maximum reduction of all four types
of poststerilization EtO will offer maximum worker protection, reduced aeration
time, and increased plant productivity. The first type, headspace EtO, is
readily eliminated during the postvacuum phase, since there is nothing to stop
the gas from being drawn out by the vacuum pump. The second type, packaging EtO,
is easily and effectively reduced by increasing the depth of each vacuum,
programming a slower vacuum ramp rate, and increasing the overall number of
postvacuum/nitrogen sequences in the process. EtO residing in the vapor space of
the packaging must cross several layers of porous packaging in order to reach
the sterilizer headspace, where it is removed by the vacuum pump system. The key
variable in this step is time. When the vacuum rate is reduced, one allows more
time for the packaging EtO to cross all packaging layers. Additional postvacuum/nitrogen
sequences—beyond the number necessary for safety reasons—may be added to
more effectively reduce the packaging EtO residual levels.
To reduce the remaining two types of EtO—absorbed and adsorbed—the
process parameters for temperature, postvacuum set point, and vacuum hold time
must be considered. The optimum postvacuum technique is to raise the temperature
of the sterilizer, program the deepest vacuum set point permitted by the load,
and then dwell (or "soak") at those pressure and temperature
conditions for a brief time. During this postvacuum dwell period, the physical
conditions inside the sterilizer are conducive to the release of absorbed and
adsorbed humidity, which will facilitate the dissipation of absorbed and
adsorbed EtO. During a postvacuum dwell, EtO will desorb from the load and
occupy the sterilizer headspace. This flow of residual EtO from the load to the
headspace will continue only until an equilibrium is reached in which the
headspace concentration of EtO approaches the concentration of EtO contained in
the load. Therefore, it is necessary to periodically backfill the sterilizer
with nitrogen and perform an additional postvacuum dwell. The optimal number of
postvacuums and dwells, and the time programmed for each one, depends on the
particular load characteristics and can be determined through process
development studies and related EtO-residual product test data.
Another important factor that must be considered when planning an EtO cycle
is the constraint placed on process design by the facility's emission-control
system. Except for facilities that use less than 2000 lb of EtO per year,
federal law requires that the output of the sterilizer vacuum pump and the
sterilizer rear exhaust vent (or "backvent") be connected to an
emission-control device such as a wet scrubber or catalytic oxidizer.12
Wet scrubbers function by diffusing the vacuum-pump stream into acidified
water; the acid catalyzes the reaction of water and EtO to generate ethylene
glycol. Dispersion tubes, with a specified capacity for gas-stream flow, aid in
dissolving the EtO component into the water. The process engineer therefore
needs to know the maximum vacuum-pump rate that can be tolerated without
damaging the dispersion tubes of the scrubber. Packed towers, another form of
wet scrubbing, can guarantee certain efficiencies only if the maximum flow rate
of gas entering the unit is in accordance with the manufacturer's tolerances.
With either wet-scrubbing technology, an excessively high vacuum rate may damage
the control equipment and reduce emission-control efficiency.
Catalytic oxidizers receive the gas stream from the sterilizer vacuum pump,
dilute it with 22 parts of air until the concentration of EtO in the stream is
below the LEL, heat the diluted gas stream to approximately 300°F or greater,
and then pass the stream over catalytic beds to convert the EtO to carbon
dioxide and water vapor.13 Catalytic oxidizers are sized according to
each specific facility: upon installation, there is a preset maximum EtO flow
rate that the oxidizer can safely handle. Consequently, every postvacuum must be
designed so that the rate at which EtO is pumped from the sterilizer to the
oxidizer does not exceed the capacity of the oxidizer. Because many oxidizers
employ a natural gas—fired heating system, improperly designed EtO processes
that channel streams with excessively high concentrations of EtO to the oxidizer
can result in explosions within the oxidizer.
AMBIENT-AIR FLUSH
Before a sterilizer can be unloaded, two potentially dangerous situations
must be eliminated by flushing the sterilizer vapor space with ambient air.
(This ambient-air flush is not illustrated for the cycle shown in Tables I and
II.) Performed at atmospheric pressure, an air flush involves admitting fresh
air into one end of the sterilizer through a valved intake or by partially
opening the door while a sterilizer exhaust fan is activated. The air sweeps
across the load and exits through the exhaust vent, removing residual EtO from
the sterilizer vapor space. As detailed on the tables of process calculations
for both the deep and shallow cycles, the sterilizer atmosphere at the end of
the final air inbleed is not flammable but does contain enough EtO to present a
human health hazard. In addition, despite the air inbleeds, neither cycle will
have restored the sterilizer atmosphere to 100% air, and the
resulting residual EtO and lack of sufficient oxygen poses a danger to
personnel.14 The process engineer must therefore plan to perform an
ambient-air flush following the final air inbleed. The minimum required time for
the air flush will depend on the size of the sterilizer and the capacity of the
exhaust unit. The stronger the unit, the quicker the sterilizer vapor space is
cleared of EtO and restored to a breathable status. Once the minimum required
time has elapsed, the air flush may even continue throughout the unloading
process.
ULTIMATE SAFETY THROUGH DIRECT ANALYSIS
A critical factor to consider is that, in most sterilization systems in which
the sterilizer rear exhaust empties into a catalytic oxidizer, the gas stream
vented through the sterilizer rear exhaust must be engineered to contain less
than 3% EtO by volume. This gas stream is not diluted with air but is vented
directly to the oxidizer. Therefore, if the sterilizer rear exhaust is activated
when there is more than 3% EtO inside the vessel, a fire hazard or potentially
explosive situation could be created. It is absolutely critical that the
sterilizer headspace level of EtO be less than 3% before activation of the rear
exhaust.
Since the 1994 adoption of ANSI/AAMI/ISO 1135, there has been discussion
within the medical device manufacturing industry regarding the need to install
analytical hardware to perform direct on-line analysis of the sterilizer
headspace content. Parametric release of EtO-sterilized medical supplies is
possible provided that, during select portions of the process, the headspace
levels of EtO and the RH are accurately determined through direct analysis.
Recently, however, the need to install such direct analyzers has been prompted
by major safety concerns. EPA requirements for EtO emission control have caused
many facilities to install catalytic oxidizers capable of reducing EtO emissions
to the atmosphere by 99%.12
The volumetric calculations described in this article allow the process
engineer to predict the changing composition of the sterilizer atmosphere.
However, these calculations are only accurate under ideal conditions—that is,
an empty sterilizer. Once a sterilizer is loaded with product, the elements of
packaging EtO and of absorbed and adsorbed EtO alter the behavior of the process
in such a way that it is impossible to indirectly predict (through paperwork
calculation) the composition of the sterilizer atmosphere. The only way to know
with certainty—before activating the sterilizer rear exhaust—that the
sterilizer atmosphere contains less than 3% EtO is through direct sampling and
chemical analyses such as chromatographic and spectroscopic technologies.
Interlocking the gas analyzer with the rear exhaust control system can prevent
the activation of the rear exhaust fan when the EtO level inside the sterilizer
is greater than 3%.15
CONCLUSION
Before actual experimentation can begin, the physical parameters of a 100%
EtO sterilization process require careful planning. Sterilization engineering
begins with a conscientious examination of each and every physical step of the
process. The phase of process design input must simultaneously include all
process elements (temperature, ramp rates, EtO concentration, and relative
humidity) and balance them against limitations imposed by the product,
packaging, and equipment. Although calculations can be used to verify the safety
of an EtO process inside an empty sterilizer, the dynamics will change once the
sterilizer is loaded, and the safety of the process design should be verified
through direct EtO monitoring. The principles of cycle design will directly
affect the efficiency and profitability of the operation, the safety of
sterilization personnel and integrity of equipment, and, ultimately, the
well-being of the end- user of the EtO-sterilized medical device. It is
imperative that these principles be adopted into employee training programs and
understood by everyone managing the EtO sterilization process.
ACKNOWLEDGMENTS
The authors would like to express their gratitude to Stephen A. Conviser of
AlliedSignal, Inc., Morristown, NJ, for reviewing the volumetric calculations
and process data presented in this article.
REFERENCES
1. Matthews IP, Gibson C, and Samuel AH, "Enhancement of the Kinetics of
the Aeration of Ethylene Oxide Sterilized Polymers Using Microwave
Radiation," J Biomed Mat Res, 23:143—156, 1989.
2. The reader is advised to consult NFPA 77, Recommended Practice on
Static Electricity, National Fire Protection Agency, Quincy, MA, 1993.
3. 1984 Flammability Data on EtO-N2-Air Mixtures at 1
Atmosphere, Danbury, CT, Union Carbide, 1984.
4. Regardless of the amount of air displaced from the sterilizer, EtO will
autoignite at 804°F, thus producing its own supply of oxygen. The reader is
advised to consult the material safety data sheet for EtO.
5. Relative humidity can be calculated by using the saturated steam tables.
The required cycle data are the pressure rise due to steam injection and the
process temperature. The reader is advised to consult the appropriate EtO
sterilization TIR from the Association for the Advancement of Medical
Instrumentation (AAMI) for step-by-step instructions.
6. ASME Steam Tables, New York, American Society of Mechanical
Engineers, 1983.
7. Ethylene Oxide Sterilization Equipment, Process Considerations, and
Pertinent Calculations, AAMI TIR No. 15-1997, Arlington, VA, 1998.
8. EtO concentration can be calculated using the ideal gas law of PV = nRT.
The required cycle data are the pressure rise due to sterilant addition and the
process temperature. The reader is advised to consult the appropriate ethylene
oxide sterilization TIR from AAMI for step-by-step instructions.
9. Morrissey RF, "Cycle Development—Physical Parameters," in Proceedings
of the Seventh Annual AAMI/FDA Conference on Medical Device Regulation,
Arlington, VA, AAMI, pp 18—20, 1980.
10. The data for the EtO processes illustrated in this article were plotted
on a flammability chart, courtesy of AlliedSignal, Inc. (Morristown, NJ). The
flammability chart used was developed specifically for 100% ethylene oxide with
nitrogen processes, operating at or less than atmospheric pressure and not
exceeding 45°C. Once this process exceeds atmospheric pressure and/or 45°C,
the area of flammability on the chart increases.
11. Buonicore AJ, Desai PR, and Magone MA, "Post-Evacuation Cycle
Modifications to Reduce Ethylene Oxide Residual Levels and Worker
Exposure," in Proceedings of the Medical Design and Manufacturing East
'84 Conference and Exposition, Santa Monica, CA, Canon Communications, 1984.
12. "Environmental Protection Agency—National Emission
Standards for Hazardous Air Pollutants for Ethylene Oxide Commercial
Sterilization and Fumigation Operations," Code of Federal Regulations, 40
CFR 9 and 63.
13. Ethylene Oxide, Material Safety Data Sheet, Danbury, CT, Union
Carbide Industrial Gases, Linde Div., April 1991.
14. The reader is advised to consult the safety bulletin published by the
Compressed Gas Association (Arlington, VA): CGA SB-2, Oxygen Deficient
Atmospheres, which is also recommended for employee training.
15. Regarding catalytic oxidizers and EPA regulations, a safety committee has
been formed within the Ethylene Oxide Sterilization Association (Washington, DC)
for the purpose of eventually publishing a document to be titled "EOSA
Safety Considerations for Ethylene Oxide Sterilization." The reader is
advised to consult this document once it becomes available.
Paul J. Sordellini and Vincent A. Caputo, of Quality Solutions, Inc.,
Annandale, NJ, and Susan Edel Satter, of Satter & Associates, Inc., Boulder,
CO, are consultants serving the medical device manufacturing industry.
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