Design Validation Inadequate


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Warning Letter: Insufficient approval signatures (s6679c)

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No approval signatures and dates were documented for the Validation Report , [redacted]. The only approval signatures that were documented were that of the [redacted] and [redacted] from Isotron Ireland. 6. Failure to adequately establish and maintain procedures to control all documents to assure that all documents meet the requirements of this part. Those documents should include the signature of the individual(s) approving the documents and shall be documented, as required by 21 CFR 820.40(a).

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Warning Letter: Failure to follow procedures (s6655c)

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Your firm failed to establish and maintain adequate procedures to control design validation , including software validation and risk analysis, where appropriate, as required by 21 CFR 820.30(g). For example: a. Because you failed to follow your procedure, the acceptance criteria were not complete prior to the performance of validation activities. Specifically, [redacted] for ECAT scanners introduced an error in the scan start time used in the decay correction algorithm. This error was most pronounced in the TTTT/EEEE mode which was not tested during the validation of the software update.

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Warning Letter: Employees not adequately trained (ucm076532)

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Failure to establish procedures for identifying training needs, ensure that all personnel are trained to adequately perform their assigned responsibilities, and document training, as required by 21 CFR 820.25(b). For example: “a. Training records for a sterilizer operator and packager were requested at your Asheboro, NC, facility during the 2007 FDA inspection. Out of five (5) training records requested for the sterilizer operator, only two (2) were available. Two (2) training records were requested for the packager and only one (1) record was available.” “b. A number of documents were collected demonstrating that employees were not adequately trained, at your [redacted] facility.

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Warning Letter: No validation protocol (g6139d)

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"Failure to use the design process for the design changes made to the Biad nuclear imaging system and failure to have written design change control procedures. [21 CFR 820.30(i)] Specifically, the design change (retrofit) your firm made to the Biad nuclear imaging system as a result of a complaint that the detector head on the Biad nuclear imaging system fell and trapped a patient (See item #1 above) was not performed using design controls. There is no formal approval of the change, no risk assessment was documented, and there is
no verification/ validation protocol
."

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Warning Letter: Failure to indicate reason for change (ucm075728 )

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Failure to indicate the reason for change in automated data entries [21 CFR 58.130(e)]. In several instances, entries in the [redacted] collection/notes and audit trails failed to provide the reason for changing raw data. For example, audit trail entries for study [redacted]demonstrate that observations of “normal” were removed without an explanation.

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Warning Letter: Failure to validate computer software (s6643c)

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"5. Failure to adequately
validate computer software
used in an automated process for its intended use according to an established protocol, as required by 21 CFR 820.70(i). For example, no person from your firm reviewed or approved the third party approval test resultsfor the original " [redacted]
Complaint System Validation
" used in your firm's quality system."

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