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Top 10 Medical Device
Citations
Regina A. BarrellFood and Drug Administration
Office of Regulatory AffairsOffice of Enforcement
Division of Compliance Management and Operations
QSIT Approach to Inspections
Level 1 – Abbreviated –
� 2 subsystems;
� Corrective and Preventive Actions (CAPA)
plus Production and Process Controls (P &
PC) or Design Controls.
QSIT Approach to Inspections
Level 2 – Comprehensive –
� 4 major subsystems;
� Management Controls, Design Controls,
CAPA and P & PC.
QSIT Approach to Inspections
Level 3 – Compliance Follow-Up –
Special – For Cause –
Special – Risk Based Work Plan -
As directed by inspectional guidance and elements of QSIT.
QSIT Approach to Inspections
Compliance Follow-Up, For Cause and Risk Based Work Plan are dictated by the previous FDA-483 findings and other regulatory information and may differ from the typical QSIT approach.
2011
1. 820.100(a) – Corrective and Preventive Action (Procedures)
2. 820.198(a) – Complaint procedures
3. 803.17 – Written MDR procedures
4. 820.100(b) – Corrective and Preventive Action (Documentation)
5. 820.75(a) – Process Validation
2011
6. 820.181 – Device Master Record
7. 820.50 – Purchasing Controls
8. 820.90 (a) – Control of non-conforming
product
9. 820.22 – Quality Audit procedures
10. 820.30 (i) – Design Change procedures
Total Turbo Citationsvs.
2011 Citations
Total 2011
1 820.100(a) 820.100(a)
2 803.17 820.198(a)
3 820.198(a) 803.17
4 820.100(b) 820.100(b)
5 820.75(a) 820.75(a)
Total Turbo Citationsvs.
2011 Citations
Total 2011
6 820.22 820.181
7 820.22 820.50
8 820.30(a) 820.90(a)
9 820.30(i) 820.22
10 820.50 820.30(i)
TOP FIVE FDA 483 CITATIONS
FOR MEDICAL DEVICE FIRMS
Number One
21 CFR 820.100(a)
Procedures for corrective and preventive action have not been [adequately] established.
21 CFR 820.100(a)
For example:
� Failure to analyze processes, service records,
quality audit reports, complaints, returned
product, and other sources of quality data to
identify existing and potential causes of
nonconforming product;
21 CFR 820.100(a) contd.
�Cause of nonconformities relating to product, processes and the quality system are not investigated;
�Actions needed to correct and prevent recurrence of nonconforming product or other quality problems are not identified.
TOP FIVE FDA 483 CITATIONS
FOR MEDICAL DEVICE FIRMS
Number Two
21 CFR 820.198(a)
Procedures for receiving, reviewing, and evaluating complaints by a formally designated unit have not been [adequately] established.
21 CFR 820.198(a)
For example:
�Complaints are not processed in a uniform or
timely manner;
�are not documented; or
�have not been evaluated for MDR applicability.
TOP FIVE FDA 483 CITATIONS
FOR MEDICAL DEVICE FIRMS
Number Three
21 CFR 803.17
Written MDR procedures have not been [developed] [maintained] [implemented].
21 CFR 803.17
For example:
�Your firm’s Complaint Handling procedure states that complaints shall be reviewed for MDR reporting per 21 CFR 803, however there are no additional MDR procedures.
21 CFR 803.17 contd.
For example:
� Your procedure does not contain a standardized process for determining when an event meets the criteria for MDR. There are no instructions for how your firm will evaluate information about an event to make MDR reportability determinations in a timely manner.
TOP FIVE FDA 483 CITATIONS
FOR MEDICAL DEVICE FIRMS
Number Four
21 CFR 820.100(b)
Corrective and preventive action activities and/or results have not been [adequately] documented.
TOP FIVE FDA 483 CITATIONS
FOR MEDICAL DEVICE FIRMS
Number Five
21 CFR 820.75(a)
A process whose results cannot be fully verified by subsequent inspection and test has not been [adequately] validated according to established procedures.
21 CFR 820.75(a)
For example:
� Storage conditions were not defined or monitored for the chemical indicators used in the Ethylene Oxide validation study as well as during routine processing.
21 CFR 820.75(a) contd.
For example:
� There is no process validation study for the radio frequency welding process used to weld flanges onto the bladder that is a component of the X device.
FDA Enforcement Statistics
Summary
Fiscal Year 2011
Seizures 15
Injunctions 16
Warning Letters 1720
Recall Events 3640
Recalled Products 9288
Debarments 16
CDRH Enforcement Statistics
Summary
Fiscal Year 2011
Seizures 1
Injunctions 0
Warning Letters 175
Recall Events 1,271
Recalled Products 3,211
CDRH Seizures
By Fiscal Year 2007 - 2011
1
0
2
1
0
1
2
2007 2008 2010 2011
CDRH Injunctions
By Fiscal Year
4
1
2
00
1
2
3
4
2007 2008 2010 2011
CDRH Warning Letters
By Fiscal Year
155 152
204
175
0
25
50
75
100
125
150
175
200
225
2007 2008 2010 2011
Total Recall Events by CDRHFiscal Year 2007 - 2011
664
831 876
1,271
0
200
400
600
800
1000
1200
1400
2007 2008 2010 2011
Class I, II and III
Total Recall Products by CDRHFiscal Year 2007 - 2011
1,279
2,4722,634
3,211
0
500
1000
1500
2000
2500
3000
3500
2007 2008 2010 2011
Class I, II and III
FDA Recalls – All ClassesFiscal Year 2007 - 2011
664831 876
1,2711,279
2,4722,634
3,211
0
500
1000
1500
2000
2500
3000
3500
2007 2008 2010 2011
Events Products
Recalls: Definition of Class I
Class I recall: a situation in which there is a reasonable probability that the use of or exposure to a violative product will cause serious adverse health consequences or death.
CDRH Class I Recalls –
Fiscal Year 2007 - 2011
26 1449 5045
131
334
427
0
50
100
150
200
250
300
350
400
450
2007 2008 2010 2011
Events Products
Recalls: Definition of Class II
Class II recall: a situation in which use of or exposure to a violative product may cause temporary or medically reversible adverse health consequences or where the probability of serious adverse health consequences is remote.
CDRH Class II Recalls –
Fiscal Year 2007 - 2011
540709 753
1,1511,102
2,178 2,208
2,665
0
500
1000
1500
2000
2500
3000
2007 2008 2010 2011
Events Products
Recalls: Definition of Class III
Class III recall: a situation in which use of or exposure to a violative product is not likely to cause adverse health consequences.
CDRH Class III Recalls –
Fiscal Year 2007 - 2011
98108
74 70
132
163
92
119
0
20
40
60
80
100
120
140
160
180
2007 2008 2010 2011
Events Products
QUESTIONS??