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AABB Letter to The Joint Commission Regarding Proposed Blood Transfusion Service and Donor Center Standards

October 20, 2010

Mark Chassin, MD
The Joint Commission
One Renaissance Blvd.
Oakbrook Terrace, IL 60181

Ann Scott Blouin, PhD, RN
Executive Vice President
Division of Accreditation
and Certification Operations
The Joint Commission
One Renaissance Blvd.
Oakbrook Terrace, IL 60181

Dear Dr. Chassin and Dr. Blouin:

AABB is writing to express grave concern over The Joint Commission's proposed Blood Transfusion Service and Donor Center standards and to request a meeting between our leadership at the highest levels to better understand The Joint Commission's strategic motivation in developing these standards.

While we have many concerns with the language and content of the proposed standards, including the fact that the "requirements" include both requirements and recommendations, AABB's primary concern is with the creation of a separate set of standards for Joint Commission-accredited hospitals. We do not believe, as stated in the preamble of the proposed standards, that the proposed requirements in The Joint Commission's Blood Transfusion Service and Donor Center section accurately "reflect the AABB standards." We do strongly believe that the proliferation of overlapping, but potentially divergent, standards for transfusion services and blood banks is a disservice to hospitals and will actually decrease patient safety as hospitals work to adhere to two separate sets of standards. Further, the time and resources that will be required to ensure that the proposed standards do accurately reflect AABB standards, now, and in the future, are significant.

AABB standards for blood banks and transfusion services have been in existence since 1958 and are widely recognized and adopted throughout the United States and globally as the highest standards for safety in blood collection and transfusion. These standards are reviewed on an 18 month cycle by a committee composed of experts appointed by AABB's Board of Directors and representatives from other organizations involved in blood safety, including the federal Food and Drug Administration. Over the years, these standards, and the process through which they are developed, have been strengthened and refined. We believe that AABB's standards for blood banks and transfusion services advance our organizations' mutual commitments to patient safety.

AABB was extremely pleased to hear of The Joint Commission's appointment of Jennifer Rhamy as Executive Director, Laboratory Accreditation, and believed that we had had a very productive discussion during a conference call in March of this year concerning closer collaboration between AABB and The Joint Commission. AABB was also pleased to see that The Joint Commission had incorporated AABB standards in its last published standards. For that reason, AABB was both surprised and dismayed to see that The Joint Commission has determined not to incorporate AABB standards into its most recent proposed standards, but rather to draft a separate set of blood standards applicable to hospitals accredited under The Joint Commission's laboratory accreditation program.

We respectfully request that The Joint Commission reconsider its decision to promulgate yet another set of standards in this field. Specifically, we request that The Joint Commission retain its existing standard which requires that "The laboratory has written policies and procedures for the blood transfusion service that are consistent with AABB standards," and that AABB be granted contractor status to develop these standards, as discussed in our March telephone conference call. To ensure that The Joint Commission's concerns are addressed, AABB would be pleased to invite the participation of a Joint Commission representative in the AABB Blood Bank and Transfusion Services Standards Program Unit. Finally, to address longstanding AABB concerns with Joint Commission surveyor interpretation of AABB standards, we propose that AABB and The Joint Commission engage in active discussion about ways in which to educate and train Joint Commission surveyors who are responsible for assessment of the blood bank and transfusion service. AABB stands ready to work with The Joint Commission in pursuit of our common goal of improving patient safety and we look forward to a positive response to our request for a meeting.


James P. Aubuchon, MD
  Karen Shoos Lipton, JD
Chief Executive Officer


Jennifer Rhamy, MBA, MA, MT(ASCP) SBB
Executive Director, Laboratory Accreditation

Jean Otter, MT(ASC) SBB
Division Director, Standards, Accreditation and Educational Programs