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8.2 SHORTCOMINGS OF TRADITIONAL TEST METHODS<br />

8.2.1 HYGIENIC HANDWASH AND HANDRUB; HCW HANDWASH AND HANDRUB<br />

A major obstacle for testing hand <strong>hygiene</strong> products to meet regulatory requirements is<br />

the cost, which can be prohibitive even for large multinational companies. Cases in point<br />

are the extensive and varied evaluations as specified in the TFM 135 . The TFM requires in<br />

vitro determination of the antimicrobial spectrum of the active agent, of the vehicle and<br />

of the final formulation by assessing the MIC with approximately 1000 microbial strains,<br />

half of which must be freshly recovered clinical strains. Furthermore, time-kill curves have<br />

to be established and studies on the development of resistance have to be done. In vivo,<br />

at least 54 volunteers are necessary in each arm to test the product and a positive control,<br />

hence a minimum of 2 x 54 subjects. The immense expenditure would, however, be much<br />

smaller if the same subjects were used to test both formulations concurrently in two runs in<br />

a cross-over fashion, as described in EN 1499 and EN 1500 137,138 . The results could then be<br />

intra-individually compared, thus allowing a considerable reduction in sample size at the<br />

same statistical power.<br />

Another shortcoming of existing test methods is the duration of hand treatments which<br />

require volunteers to treat their hands with the hand <strong>hygiene</strong> product or a positive control<br />

for 30 seconds 135 or 1 minute 137 despite the fact that the average duration of hand cleansing<br />

by HCWs has been observed to be less than 15 seconds in most studies 70,148-153 . A few<br />

investigators have used 15-second handwashing or hygienic hand antisepsis protocols 93,154-<br />

157 . Therefore, almost no data exist regarding the efficacy of antimicrobial soaps under<br />

conditions in which they are actually used. Similarly, some accepted methods for evaluating<br />

waterless antiseptic agents for use as antiseptic handrubs such as the reference hand antisepsis<br />

in EN 1500 138 , require that 3 ml of alcohol be rubbed into the hands for 30 seconds,<br />

followed by a repeat application of the same type. Again, this type of protocol does not<br />

reflect actual usage patterns among HCWs. However, it could be argued that equivalence<br />

in the efficacy of a test product with the reference is easier to prove with longer skin contact<br />

because, if a difference in the efficacy exists, it is greater after longer application times<br />

and therefore easier to detect. Or, inversely, to prove a difference between two treatments<br />

of very short duration, such as 15 seconds, under valid statistical settings is difficult and<br />

requires large sample sizes, i.e. numbers of volunteers. Therefore, a reference treatment<br />

which has usually been chosen for its comparatively high efficacy may include longer skin<br />

contact than is usual in real practice if the aim is to demonstrate the equivalence of a test<br />

product with economically justifiable sample sizes.<br />

A further shortcoming relates to the requirements for efficacy. The TFM 135 for instance,<br />

requires a hand <strong>hygiene</strong> product for an HCW handwash in vivo to reduce the number of the<br />

indicator organisms on each hand by 2 log within 5 minutes after the first wash and by 3 log<br />

after the tenth wash. This requirement is inappropriate to the needs of working in a healthcare<br />

setting for two reasons. First, to allow a preparation to reduce the bacterial release by<br />

only 2 log within a maximum time span of 5 minutes seems an unrealistically low requirement,<br />

as even with unmedicated soap and water a reduction of 3 log is achievable within 1<br />

minute 1,158 . Furthermore, 5 minutes is much too long to wait between two patients. Second,<br />

the necessity for residual action of a hand disinfectant in the non-surgical area has been<br />

challenged 159-161 . The current group of experts does not believe that for the aforementioned<br />

purpose a residual antimicrobial activity is necessary in the health-care setting. Rather, a fast<br />

and strong immediate effect against a broad spectrum of transient flora is required to render<br />

hands safe, not only in a very short time, but also already after the first application of the

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