Medical Device Manufacture


Warning Letter: Failure to validate computer software (ucm538430)

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Failure to ensure that when computers or automated data processing systems are used as part of production or the quality system, the manufacturer shall validate computer software for its intended use according to an established protocol, as required by 21 CFR 820.70(i). For example, your firm’s [redacted] software has not been validated for its intended use. This software is used for documentation and tracking of product design and design change projects, as well as for quality related activities such as complaints, corrective and preventive actions and nonconformances.

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Warning Letter: Failure to establish and maintain adequate procedures (ucm515974)

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Failure to establish and maintain adequate procedures for implementing corrective and preventive action (CAPA), as required by 21 CFR 820.100(a). For example:

a. Your firm’s CAPA procedure, [redacted], only requires that nonconformances will be reviewed every [redacted]. However, the procedure does not require analysis of quality data, including quality records, complaints and returned products, for potential CAPA.

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Warning Letter: Inadequate spreadsheet (ucm406826)

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Also, your firm tracks complaint data on a spreadsheet that contains free form text fields that are not standardized, resulting in an inability to adequately trend the data. For example, when using complaint data from January 1, 2011 to February 19, 2014 to trend for “Description of Failure” for “6090,” fourteen complaints are shown. However, the spreadsheet contains several different descriptions of the same part failure that when totaled resulted in a total count of forty complaints related to the inline coupler, part #6090.”

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Warning Letter: Failure to validate computer software (ucm265239)

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Failure to validate computer software for its intended use according to an established protocol , as required by 820.820.70(i). Your firm uses the [redacted] for in-process and final product testing for the [redacted] and the [redacted]. Your firm conducted software validation for the [redacted] and the results are included in the Software Validation Report, dated February 11, 2010.

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Warning Letter: Failure to establish procedures (ucm224014)

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Failure to establish and maintain adequate procedures for verifying or validating the corrective and preventive action to ensure that such action is effective and does not adversely affect the finished device, as required by 21 CFR 820.100(a)(4). For example, no protocol, including acceptance criteria, was established for the validation of Change Request [redacted]. Additionally, there was no documentation showing that this change was validated.

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