Specific Criteria 2-1
Specific Criteria 2-1
MS ISO 15189
1 Introduction
1.1 This document describes the requirements for accreditation of medical molecular testing
laboratories involved in nucleic acid testing in a broad variety of human samples.
1.2 This document should be read in conjunction with the MS ISO 15189 standard.
1.3 Clause numbers correspond to those in the standard which require elaboration.
2 Scope of accreditation
2.4 Immunogenetics
2.5 Pharmacogenomics
(i) Medical molecular testing laboratory - any services in the molecular analysis of nucleic
acid derived from human tissue or fluid or any other product of the human body.
(ii) Result - data without clinical interpretation and may have a descriptive comment.
Examples of descriptive comments:
a) Medical molecular testing
- point mutation detected
- deletion detected
- xx mutation not detected
b) Quantitative analysis
- 10,000 copies/ml
- 2.4x risk of having colorectal cancer
- normal allele detected with approximately 32 CGG repeats and no expansion in
the FMR1 (NM_002024.4) gene
(iii) Report - interpretative report issued containing clinically relevant inferences from test
results or analytical findings.
Example:
- Fragile X diagnosis is unlikely but not ruled out (approximately 1% possibility of
point mutation or gene deletion)
- Duchenne muscular dystrophy gene mutation with in-frame deletion of the gene
(v) Person authorised to receive laboratory test result and report (Clause 5.8.3 of MS ISO
15189) - The person authorised to receive the laboratory test result or report shall be
the authorised requester or his/her authorised designee.
(vi) Subject Matter Experts (SME) is a person with knowledge and expertise in a specific
subject or technical area.
4 Management requirements
The laboratory director shall be the person-in-charge of the services of the laboratory and
should be resident to the laboratory. There may be more than one laboratory director if the
scope of services provided by the laboratory extends over more than one specialty of
pathology such that a single laboratory director may not have the competence to assume
responsibility for all the services provided. Where national regulations apply, statutory
requirements with regard to competence, qualifications and experience of the laboratory
director (person-in-charge) shall be complied with.
Note: ‘Resident’ connotes that the laboratory director works in-house and the laboratory is
the main place of professional practice.
a) Medically qualified pathologist (i.e. a medical practitioner registered with the Malaysian
Medical Council, with a postgraduate qualification in pathology approved by the
Government of Malaysia) and a minimum of three (3) years working experience as a
pathologist; or
The laboratory director and his designees are regarded as key personnel. Key personnel
shall normally include:
(a) Where there is insufficient or no resident SME to provide the clinical input or advisory
services required in Clause 4.7, the services of a visiting SME with relevant experience
should be engaged.
(b) The laboratory shall engage the services of technical personnel trained in medical
molecular testing under the scope of accreditation. Where resident technical personnel
are unable to cover all the services offered, suitably qualified and experienced part-
time technical personnel shall be engaged.
(c) There shall be at least one (1) technical personnel present in the laboratory, during all
working hours.
4.4.1 Where a laboratory is a part of a hospital and provides in-house services to the hospital,
the internal arrangement between the hospital management and the laboratory
management may be considered as an agreement and the requirements of this clause
apply. The agreement may be in the form of a request form, memorandum, manual,
circular, letter, minutes of a meeting, etc. which shall be controlled.
This clause does not apply where a sample is to be examined by another laboratory, as
arranged by a requester and the pathology laboratory merely acts as a handling centre on
behalf of the requester. The examination results of such samples shall not be issued under the
name of the pathology laboratory and the laboratory shall not make any statement on its
accreditation status regarding the examination results.
SMEs should be available to provide relevant advice prior to test ordering and to advise on
the interpretation of test results. A laboratory handbook provides guidance to authorised
requester on the choice and cost of tests.
(a) test repertoire, including standard testing profiles, reflex testing, procedures for follow
up and confirmatory testing;
(c) recent update and advances in relation to the identification of previous variants of
unknown clinical significance emerging as being disease associated.
4.13.1 A copy of examination results and reports issued shall be kept in the record system or it
shall allow one to be reproduced upon request.
4.13.2 Minimum retention periods for patient records and specimens shall conform to relevant
national guidelines / regulations where available such as College of Pathologists, Academy
of Medicine Malaysia Guideline on Retention of Pathology Records and Materials.
4.14.1 - 4.14.4
As in MS ISO 15189
Auditors shall have adequate knowledge in MS ISO 15189 and receive relevant training to
conduct internal audit.
The elements to be audited may include but not limited to the following:
The laboratory shall identify and document potential failures in its quality management
system including the pre-examination, examination and post examination work processes
which affect examination results using methods such as Failure Mode and Effect Analysis
(FMEA) or similar risk assessment tools. Periodic evaluation of one or more of the following
indicators may be conducted:
(a) Specimen;
(c) Reagents;
(d) Environment;
(e) Personnel.
(d) MS 2370 – Medical Laboratories – Reduction of Error through Risk Management and
Continual Improvement.
5 Technical requirements
5.1 Personnel
5.1.1 General
The laboratory shall have documented procedures and maintain records that includes
recruitment, appointment and assignment of all managerial, clinical, scientific and technical
personnel and their performance appraisals based on predetermined individual targets. The
recruitment and qualifications of laboratory personnel shall be in compliance with relevant
existing laws in the country.
The competency of personnel is a major aspect of each laboratory assessment as the standard of
performance depends heavily on the competence of the laboratory’s personnel.
a) Technical personnel
A technical personnel refers to staff who perform molecular technical work. They shall have
suitable qualifications and training with sufficient experience and ability to perform the
required task. This shall be evidenced by:
b) Scientific personnel
A scientific personnel refers to staff who perform and evaluate advanced and high-end
technical work. They shall have suitable qualifications and training with sufficient experience
and ability to perform the required task. This shall be evidenced by:
The laboratory shall ensure that technical and scientific personnel assigned to perform new or
rarely used techniques undergo appropriate training. Records of training and assessments of
competence shall be kept. These shall include records of results of examinations/tests
performed during training and competence assessments. The validity of results produced by
technical personnel, particularly in the first six months after completion of training in new techniques
shall be monitored.
Personnel who are physically challenged may affect the performance of certain types of
laboratory tests. It is the responsibility of the laboratory management to assign duties and
take appropriate steps to ensure that validity of results and laboratory safety are not
compromised.
c) Clinical personnel
Clinical interpretation of test results shall be provided by a medically qualified person who
has obtained post graduate qualification in appropriate specialty plus two (2) years post
graduate laboratory experience in molecular genetics.
A service medical officer can also provide clinical interpretation provided they are under the
direct supervision of a medically qualified person as mentioned above.
Visiting pathologists
The visiting pathologist shall be qualified in the specialty where he/she is providing services
and shall comply with the competence requirements of clinical personnel.
A formal and written arrangement between the laboratory and the visiting pathologist shall be
established. The arrangement shall ensure that:
(i) an effective working relationship between the laboratory director and visiting
pathologist is established;
(ii) advices and recommendations of the visiting pathologist are acted upon within the
required timeframe;
(iii) the frequency and duration of visits are defined and appropriate to the volume and
scope of work undertaken by the visiting pathologist. This may take into account
the availability of electronic links, which enable remote supervision of laboratory
output;
(iv) the functions, roles and activities of the visiting pathologist as well as his/her
authorities and responsibilities are clearly defined;
(v) records of input by the visiting pathologist are kept, the means by which the
visiting pathologist can be contacted in cases when his/her advice is required urgently
is established;
(vi) an effective system to allow the provision of clinical advice as well as signing of
examination reports by the visiting pathologist within a timescale appropriate to the clinical
situation is in place; and
(vii) liabilities of the examination results and their interpretations are clearly defined.
d) Management Personnel
The quality management team shall include the relevant key personnel and at least a medically
qualified personnel as mentioned in para (clinical personnel) who may be a visiting pathologist.
The technical manager of the laboratory (or section) may be a medically qualified
personnel, a scientist in the relevant areas, or medical laboratory technologist with
specialised training and/or appropriate experience in molecular genetics.
The suitability of personnel in performing their management shall be assessed. Aspects that
will be considered include:
(b) the workload of the laboratory and the range of tests offered;
(c) the contact that managers maintain with subordinate staff; and
(d) the involvement of managers in the development of methodology and adoption of new
methodology within the laboratory.
Persons with supervisory roles shall have sufficient authority, skills and experience to train and
supervise subordinate personnel.
Contracted personnel
When a laboratory uses contracted personnel irrespective of the duration of the contract and whether
the contracted personnel member is employed on a full-time or part-time basis, the laboratory shall
ensure that the requirements for staff competence are met. Evaluation of the competence of these staff
shall be carried out and records kept. Where necessary, training shall be provided, particularly with
regard to those parts of the laboratory quality management system that are relevant to their assigned
duties. Direct supervision may be required initially to ensure that the contracted personnel are competent in
carrying out their duties.
A position in the staff organisational chart which provides for the authority to
implement necessary changes in the laboratory operation to ensure the integrity of
test results is maintained.
The necessary expertise and experience to be aware of, and understand, any
limitation of the test procedures, and to understand fully the scientific basis of the
procedures.
(ii) Key personnel can be given both the responsibility and authority to:
Design quality control programmes, set action criteria and take corrective action
when these criteria are exceeded.
(iii) Clinical, scientific and technical personnel who are not engaged full-time could also be
appointed as key personnel. However, the circumstances in which they are called upon
to exercise their key personnel responsibilities and their access to and knowledge of
the laboratory’s operations, should be such that they are able to take full responsibility
for the work they undertake, authorise or oversee.
The competency of all clinical, scientific and technical personnel to perform assigned tasks
shall be reassessed, at least once in two years. Personnel who undertake duties after a
significant period of absence as specified in the laboratory policy are expected to undergo
reassessment and retraining if necessary. Records of training and competency attainment
shall be endorsed by both trainer and trainee.
External
Internal
As a guideline for a minimum level of participation, all clinical personnel would be expected
to spend at least 42 hours in a year and all technical personnel would be expected to
spend at least 20 hours in a year participating in these activities, unless otherwise directed
by the accreditation body following a peer-review assessment.
The testing laboratory should be flexible in meeting increased sample volumes, process
changes and new technologies.
The laboratory shall comply with the relevant statutory procedures for accommodation,
environmental conditions, radioactive handling and waste disposal. The laboratory should
be designed to ensure a comfortable and safe working environment. Reference may be
made to the following documents:
Occupational Safety and Health (Use and Standard of Exposure Chemical Hazardous
to Health) Regulations 2000 (USECHH Regulations);
Safety
While safe laboratory practice forms an important part of providing a quality service and will be
necessary to achieve the standards required for accreditation, an assessment does not constitute a
formal safety audit.
National authorities are responsible for occupational health and safety in laboratories. However, it is
an expectation of the standard that all applicable standards and guidelines relating to medical
laboratories in Malaysia, and recognised best practice, shall be implemented. Attention shall be
drawn to any unsafe practices that are encountered. Where instruction and advice related to safety
are written into test methods covered by accreditation, these shall also be observed.
A safety manual detailing the laboratory’s policies and procedures in relation to health and safety
shall be readily available to staff.
Due consideration shall be given to separating certain procedures from the main work area for the
safety of workers, the protection of the environment and to maintaining the validity of the result. Such
procedures include but are not limited to:
(a) those that may pose a hazard to other staff (e.g. tests using potentially carcinogenic
reagents, contagious specimen, volatile substances, radioactive materials); and
(b) those procedures which may be affected or influenced by not being segregated (e.g. tissue
culture, PCR work).
Reference should be made to SAMM Policy 2. Test or calibration equipment that has a
significant effect on the reported results and associated uncertainties of measurement
(including, where relevant, instruments used for monitoring environmental conditions) shall
be calibrated by (one or more) of the following:
Standards Malaysia may expect reduced, or accept extended, calibration intervals based
on such factors as history of stability and accuracy and precision requirements. It is the
responsibility of the laboratory to provide clear evidence that its calibration and
maintenance system ensures confidence that the equipment is maintained. Recommended
calibration and/or performance check interval are available in Appendix 2: Table 1.
Reference may also be made to ILAC G 24- Guidelines for the Determination of Calibration
Intervals of Measuring Instruments.
The selection and collection of sample materials are important elements in medical
molecular testing methods. The general requirement for sampling shall closely follow the
MS ISO 15189 document.
5.4.3 All specimens accepted by the laboratory for testing shall be labeled in accordance with
procedures defined. As a minimum, the specimen label shall carry the following:
Two unique identifiers (e.g. name of patient and patient identification number);
Type of sample (e.g. body fluid, tissue) and anatomic site of origin; and
5.4.4 Each sample received shall be uniquely identified and matched to the accompanying
request form by at least two unique identifier. Where two or more samples accompany a
request form, these shall be distinguishable from each other in both the labels and request
form.
5.4.6 Sample identification should be traceable constantly at all stages of sample processing
(e.g. specimen receipt, nucleic acid extraction, endonuclease digestion, amplification,
electrophoresis, photography and storage).
5.5.1.1 General
Each procedure shall be authorised and dated by the responsible key personnel.
Review of methods shall be documented. Where there are no changes, a date and
signature will be sufficient. Some manufacturers provide method documentation (product
inserts) with their product and these may be included in method manuals. These shall be
authorised as above. Where this information is not sufficiently detailed to cover all required
elements it shall be supplemented by the laboratory. Inserts for new batches received shall
be checked for changes in procedure and a copy of the new insert placed in the manual.
Where a test may be performed by more than one method, there shall be documented
criteria for method selection. Where relevant, the degree of correlation between the
methods shall be established and documented.
In additional to Clause 5.5.3 a) - t) of the MS ISO 15189 standard, this information shall be
included:
(a) Type of sample (e.g. body fluid, tissue and blood) and anatomic site of origin, where
applicable; and
Positive (including low positive) and/or negative controls shall be run for every batch of
analysis. Its performance shall be reviewed based on acceptance or rejection criteria and
the analytical problems rectified.
Note: For panels with multiple targets, systematic rotation of controls may be acceptable.
5.6.3.1 The laboratory shall subscribe to at least one external quality assurance programme or
inter-laboratory comparison (national or international) for each test or related group of test
or test method where relevant under the scope of accreditation.
Where such ILC programmes are not available, the laboratory shall develop appropriate
quality control activities in compliance to MS ISO 15189 Clause 5.6.3.2.
All samples shall be retained in accordance with national guidelines e.g. College of
Pathologists, Academy of Medicine Malaysia Guidelines.
5.8.1 General
Approvals for providing interpretations and signing Skim Akreditasi Makmal Malaysia
(SAMM) endorsed reports containing interpretations will be granted to those personnel who
are found to fulfill the relevant requirements. The responsibility for interpretation of the
laboratory’s test results remains with the approved person(s). This responsibility cannot be
delegated to other persons. The person giving the interpretations shall authorise the release of
the report containing his/her interpretation personally.
For medical molecular testing report shall follow international guidelines such as:
Even though, transcription of results are not encouraged, when data are transcribed
manually into an electronic database or otherwise, there shall be a means of checking the
accuracy of transcriptions and entries. Wherever relevant, checking should be performed
by an independent operator.
It is essential that the integrity of data and confidentiality requirements are met during the
transfer of results by any electronic system.
Where the clinician requests the electronic transmission of results from the laboratory to a
remote location, the responsibility for ensuring the integrity of data transfer to the referring
clinician and other designated addressee, rests with the laboratory.
Appendix 1
i) Sanger sequencing
iv) Genetic testing for constitutional gene variants (diagnostic and carrier testing)
vii) Genetic testing for mosaic gene variants (cancer and somatic mosaicism)
xi) Calculated estimate of risk of inheritance of an unknown mutation (Bayesian and linkage
calculations)
Appendix 2
References:
2. American College of Medical Genetics – Standards and Guidelines for Clinical Genetics
Laboratories 2008 Edition.
8. ILAC G 24- Guidelines for the Determination of Calibration Intervals of Measuring Instruments.
10. MS ISO 15189 – Medical Laboratories – Requirements for Quality and Competence.
14. Occupational Safety and Health (Use and Standard of Exposure Chemical Hazardous to
Health) Regulations 2000 (USECHH Regulations)
(http://www.dosh.gov.my/index.php/en/legislation/regulations-1/osha-1994-act-154/522-pua-
131-2000-1/file).
15. Occupational Safety and Health (Classification, Labelling and Safety Data Sheet of Hazardous
Chemicals) Regulations 2013 (CLASS Regulations)
(http://www.federalgazette.agc.gov.my/outputp/pua_20131011_P%20U%20%20%28A%29%2
0310-peraturan-
peraturan%20keselamatan%20dan%20kesihatan%20pekerjaan%20%28pengelasan%20pela
belan%20dan%20helaian%20data%20keselamatan%20bahan%20kimia%20berbahaya%29%
202013.pdf).
Acknowledgements
11. Prof. Dr. Roslan Harun KPJ Ampang Puteri Specialist Hospital
16. Prof. Dr. Rosline Hassan Hospital Universiti Sains Malaysia (HUSM)